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Foothill Sanitary Landfill <br />IModule LF -2 - Liner Performance Demonstration <br />San Joaquin County <br />n <br />C <br />0 <br />-7— <br />Appendix E <br />Table 1— Please include other alternatives for cost comparisons, such as a bottomflinerwith a double <br />composite system and a pan-lysimeter under drainage systems in the landfill. This would give several <br />other options for liner system cost calculations that could be included in a liner design. <br />In studies done by USEPA it has demonstrated that approximately half of all composite liners leak to <br />some extent. The majority of these problems appear to be either the liner being compromised during <br />construction or poor design. To reduce the risk of holes or rips _during "construction; as proposed above, <br />some type of electrical testing would be appropriate over the entire liner. In addition, at many landfills <br />the impacts to groundwater appear to be in the gas phase transporting volatile organics compounds to <br />groundwater. It appears prudent to construct and operate a gas collection and control system as the <br />landfill is being filled. With an extensive electrical testing of the liner system, a landfill gas extraction , .. <br />system and addressing our comments in this letter, staff believe we can support a single -composite liner - <br />to the Board. - <br />Please address the above issues in a revised liner demonstration document. <br />Conclusions <br />The County must submit the following documents in response to these co ants: <br />Task . <br />Compliance Date <br />Submit revised Evaluation Monitoring Plan in accordance by 1 October 2002 <br />with Title 27 <br />Submit Final Closure Plan for Module LF -1 in accordance _ by 1 January 2003 <br />with Title -27 _ <br />A Report of Waste Discharge must be submitted which incorporates the revised Liner Performance <br />Demonstration in order for staff to revise WDRs for consideration by the Board. ...... _ <br />If you have any questions, comments, or would like to schedule a meeting fo discuss the issues, please - <br />call me at (916) 255-3137. <br />KIM A. SCHWAB, RG <br />Associate Engineering Geologist <br />cc: Robert McClellon, San Joaquin County Environmental Health Division, Stockton <br />Permitting and Enforcement Division, Solid Waste Management Unit, CIWMB, Sacramento = <br />Yas:Foothiu ModlLinerDemo <br />