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4. The ACAP testing, the design modeling, and the performance monitoring demonstrate <br />that Forward's alternative cover design is at least equivalent to a Title 27 prescriptive <br />cover. <br />Title 27 Section 21090(a) states in part the following: "...The RWQCB can allow any <br />alternative final cover design that it finds will continue to isolate the waste in the Unit from <br />precipitation and irrigation waters at least as well as would a final cover built in accordance <br />with applicable prescriptive standards under ¶(a)(1-3)." Therefore, staff finds that the <br />alternative cover complies with Title 27 requirements. Staff understands that Forward will <br />continue to operate the cover monitoring stations and we look forward to reviewing <br />observations collected through at least one average or greater than average precipitation year. <br />Some adjustments to the cover thickness may be necessary based on further data collection, <br />however, based on data collected to date this seems unlikely. <br />If you have any questions, please call me at (916) 464-4614. <br />Ross D Atkinson <br />Engineering Geologist <br />Title 27 Unit <br />cc: Robert McClellan, San Joaquin County LEA, Stockton. <br />Gary Lass, Geologic Claremont <br />Luis Mariscal, Geologic, Claremont <br />Lochlin Caffey, Forward Inc. <br />RDA; W:\staff\atkinsr\mydocuments\forward\Etcover2ndYR.doc <br />