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Mr. Robert McClellon <br /> December 8, 2010 <br /> Page 2 <br /> The design and specifications of the new landfill cell are in accordance with United States <br /> Environmental Protection Agency (USEPA) Subtitle D regulations and California Code of <br /> Regulations (CCR) Title 27 regulations. <br /> As part of the expansion, Forward will install new LFG monitoring probes which are <br /> proposed to be located between the property boundary and the limit of waste in the new cell. <br /> The design and specifications of the new LFG monitoring probes are in accordance with <br /> applicable CCR Title 27 regulations detailed below. <br /> CCR Title 27 Requirements <br /> The scope and requirements for LFG monitoring and control are outlined in the CCR Title <br /> 27, Division 2, Chapter 3, Subchapter 4, Article 6. Section 20925 outlines the requirements <br /> for the design of the monitoring probes, including the location of the probes with respect to <br /> the waste limits, the spacing and depth of the probes, and their configuration relative to the <br /> depth of waste. Requirements for LFG monitoring probes include: <br /> • Install around the waste footprint but not within the refuse; <br /> • Install at or near the disposal site permitted facility boundary; <br /> • Install within 1,000 feet of nearest monitoring probe; <br /> • Install adjacent to subsurface materials most conducive to gas flow; <br /> • Wellbore depth equal to the maximum depth of refuse; <br /> • Contain shallow (within 5-10 feet of surface), intermediate (around half the depth of <br /> the refuse), and deep (at or near the depth of the waste)monitoring intervals; and <br /> • Install above the permanent low seasonal water table, above and below perched <br /> ground water, and place adjacent to materials which are most conducive to gas flow. <br /> The new LFG monitoring probes have been designed in accordance with the above <br /> requirements. There are no requirements in Article 6 pertaining to the setback of LFG <br /> monitoring probes from the limit of waste. <br /> These new probes are being designed similarly to other existing probes at the Landfill which <br /> have been effective in detecting LFG migration. The probe design currently used at the site, <br /> an approximately 50-foot setback or less from the waste footprint, has been effective in <br /> detecting LFG migration and therefore can be used as a guideline for the placement of the <br /> new probes. A probe setback of 50 feet is typical at the site as it allows for traffic flow and <br /> equipment operations between the waste limit and the monitoring probes. <br /> The Landfill is located in the northern San Joaquin Valley where shallow sediment typically <br /> consists of fine-grained clays and silts with interbedded coarser grained sediments deposited <br /> in a meandering fluvial environment. A previous geotechnical investigation completed at the <br /> Landfill (Geotechnical Investigation Report, Forward Landfill Expansion, San Joaquin <br /> County, California, Geologic Associates, revised February 2008) characterized the upper 28 <br /> to 40 feet of sediment as highly interbedded sandy silt, clayey silt, silt, and clay. This soil <br /> matrix is underlain by a gray-brown interbedded sand, silty sand, and minor clay subunit that <br /> extends to approximately 53 to 75 feet below ground surface. The preliminary design of the <br />