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SEP 1 6 2008 <br />Mr. Robert McClellan ENViRCINP'IAENT �jF T�1 <br />September t 2, 2008 RERMi1T/SE-RVI <br />Page 2 <br />� i • <br />SCS compared the current perimeter probe migration monitoring network to the requirements <br />stipulated in the revised CCR Title 27 Article 6 regulations. A summary of the findings are <br />presented in a section -by -section basis below. <br />Section 20921— CIWMB Gas Monitoring and Control <br />This section of the regulation was modified to include the requirement for a gas monitoring and <br />control program to be submitted by the disposal site operator to the LEA and CIWMB for review <br />and approval. . <br />Section 20921 was also modified to provide a compliance schedule for different configurations <br />of landfills (active, closed, etc.). Section 20921 requires compliance with the new regulations by <br />one year from the effective date making the compliance date September 21, 2008. As such, one <br />of the purposes of this letter is to provide you with a status update and timeline on the site's <br />compliance with these revised regulations. <br />Section 20923 — Monitoring <br />This section of the regulation was modified to incorporate the disposal site facility boundary as a <br />point of compliance (as opposed to landfill property boundary) and included a provision to <br />consider the hydraulic conditions surrounding the disposal site when designing a monitoring <br />network. <br />Forward's monitoring network complies with the requirements set forth in section 20923. <br />Section 20925 — Perimeter Monitoring Network <br />Spacing Requirements — 20925(b) <br />This section of the regulation was modified to ensure that wells are installed near the permitted <br />facility boundary (as opposed to the property boundary) of a site and reinforces the 1,000 -foot <br />spacing rule that was in the previous version of the regulations. <br />The current distance between the wells are within the 1,000 -spacing limitation set forth in the <br />regulation, with the exception of the four wells indicated as marginal in the attached table. The <br />spacing at these well was estimated to range from 1,000 feet to 1,010 feet. <br />