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MONITORING AND REPORTING PROGRAM NO. R5-2003-0049 4 FORWARD INC. AND ALLIED INDUSTRIES FOR OPERATION OF FORWARD CLASS II LANDFILL SAN JOAQUIN COUNTY 2. Constituents of Concern The constituents of concern include all the waste constituents, their reaction products, and hazardous constituents that are reasonably expected to be in or derived from waste contained in the Unit. The constituents of concern for all Units at the facility are those listed in Tables I through IV for the specified monitored medium, and Table VI. The Discharger shall monitor all constituents of concern every five years, or more frequently as required in accordance with a Corrective Action Program. a. Monitoring Parameters Monitoring parameters are constituents of concern that are the waste constituents, reaction products,hazardous constituents, and physical parameters that provide a reliable indication of a release from a Unit. The monitoring parameters for all Units are those listed in Tables I through V for the specified monitored medium. 3. Concentration Limits For a naturally occurring constituent of concern, the concentration limit for each constituent of concern shall be determined as follows: a. By calculation in accordance with a statistical method pursuant to §20415 of Title 27; or b. By an alternate statistical method acceptable to the Executive Officer in accordance with §20415 of Title 27. Concentration limits for detection monitoring have previously been established at old Forward landfill on an intrawell basis and at Austin Road Landfill on an interwell basis. A corrective action evaluation procedure has been adopted for Austin Road Landfill (see Evaluation Procedures for Proposed Corrective Action at Austin Road Landfill). The physical separation between old Forward and Austin Road units means that monitoring results from the two areas can be evaluated independently. Detection and evaluation monitoring programs should continue under the existing protocols. All monitoring results for both areas should be submitted in a single integrated monitor report. Intra-well concentration limits at Forward wells are calculated in the Revised Post Closure Maintenance Plan (November 4, 1994) by Kleinfelder. Parametric or non-parametric tolerance limits with a 95% confidence factor. These confidence limits will continue to be used at the Forward detection monitor wells.