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C 2. Has the LHA inquired into the reasons for the Landfill's recording a Notice of Nonrenewal for Williamson ActContrim No. 72-C1-348 covering the expansion lands? Why would the Landfill take this new land out of a Williamson Act contract, set to expire in March of 2015, if it does not plan to dispose of solid waste on this land in the future? The LEA has not taken into consideration the facility operators action regarding the Williamson Act Notice of Nonrenewal. This project concerns a minor boundary realignment. The Williamson Act is not a consideration that is necessary for this project. A change in the use of the property is not proposed as part of this project. There is no proposed landfill activity in the buffer area. This will be monitored monthly during the routine inspections conducted by the EHD staff. 3. What is the purpose of expanding the Landfill boundaries at this time without adding additional disposal capacity`? If the ultimate goal is to expand disposal to this site, what is the timeline for doing so? The boundary realignment will allow the facility to change to monitoring points for landfill gas. The current monitoring wells are located along the boundary of the site. Those monitoring points are in close proximity to the waste contained in the landfill. Maintaining compliance has been a challenge for the operator. Relocating the monitoring probes to the new boundary would help the operator to maintain compliance. The facility operator would be required to re -align the facility boundary in order to move the facility monitoring points to the new property. The time line for expansion is unknown. I would direct you to ask the operator. 4. It has been reported that the Landfill is currently taking gas measurements and performing its monitoring on this new site. Goes this fulfill all of the Landfill's permit and monitoring requirements, and do ineasureinents at this site produce accurate and reliable readings given their distance and elevatiolt from the actual disposal site? is this an attempt on the part of the Landfill to distort readings at the site in order to appear compliant with its various regulatory requirements'? The landfill monitoring is conducted by a third party consultant. The results are then check by the EHD staff during the routine inspection. The routine inspections for the Forward Inc. Landfill are conducted monthly. Title 27 CCR, Section 20925 (a) 2 (see below), allows the operator to establish at or near the facility boundary. Section 20926. CIWMB - Perimeter Monitoring Network. (a) Location (1) Perimeter subsurface monitoring wells shall be installed around the waste disposal footprint but not within refuse. In some cases the Installation of monitoring wells may not be necessary around the entire perimeter of the disposal site permitted facility boundary. In such a case, the operator shall demonstrate to the satisfaction of the EA that landfill gas migration could not occur due to geologic barriers and that no inhabitable structure or other property or land use, such as agricultural lands, within 1,000 feet of the disposal site permitted facility boundary is threatened by landfill gas migration. (2) Perimeter monitoring wells shall be located at or near the disposal site permitted facility boundary. The operator may establish an alternate boundary closer to the waste disposal footprint based on a knowledge of the site factors in Section 20923(a)(2). When compliance levels are exceeded at the alternate boundary, the operator shall install additional monitoring wells closer to the permitted facility boundary, pursuant to Section 20937. Page 2 of 5 December 2, 2011