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GeoLogic Associates Geologists, Hydrogeologists and Enginee L; •� • On April 26, 2002, the Central Valley Regional Water Quality Control Board (RWQCB) indicated that dischargers would be required to demonstrate that any proposed single composite liner satisfies the performance requirements of Title 27 of the California Code of Regulation (Title 27). Under performance criteria listed in CCR 27 20310(a), a Class Il Landfill shall be "designed and constructed to prevent migration of wastes from the Units to adjacent geologic materials, ground water, or surface water, during disposal operations, closure, and the post -closure maintenance period. However, the State Water Resources Control Board has noted in their November 9, 2000 response to the Central Valley Regional Water Quality Control Board's (CVRWQCB) Resolution 5-00-213 that: "The applicable performance standard for containment of MSW is that the MSW landfill not leak. We know of no liner design or scheme that will provide perfect certainty of achieving this goal. The RWQCB can approve any liner and final cover system that at least meets applicable minimum design standards and that provides reasonable assurance of meeting this performance standard. There are situations (e.g., landfill overlies a sole -source aquifer) where prudence dictates a more stringent design. " The SWRCB also stated in the same letter that when evaluating the liner performance standard "The RWQCB must consider all relevant design-, site-, and operation -specific factors in establishing the appropriate liner and final cover design for a given landfill. " This report is submitted as a demonstration by Forward, Inc. (Forward) to show that a single composite liner system constructed at the Class II Forward Landfill expansion (i.e., the combined and expanded existing Forward and Austin Road Landfills) in San Joaquin County, California will satisfy the intent of the performance criteria and will meet or exceed the minimum design standards. This report revises an earlier demonstration submitted by Forward Inc. (May 2002), and is intended to address concerns expressed by CVRWQCB staff relative to the leachate degradation rates that are anticipated during unsaturated transport through the liner and vadose zone underlying the landfill. In response to CVRWQCB comments, this report also identifies enhanced construction quality assurance measures that will be implemented to assure the integrity of the liner system before disposal operations begin. As discussed below, Forward's request for approval of the current project design is based primarily on the following factors: • The inherent protection afforded by a single composite liner, • The anticipated performance of a single composite liner at the Forward site, • The low volume and benign characteristics of Forward leachate, • Mitigating site characteristics, 1831 Commercenter East, San Bernardino, CA 92408 Phone: (909) 383-8728 Fax: (909) 383-8732