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& Bonaparte (1989), which concluded "negligible pollutant discharges to groundwater" would occur, overstated the risk of landfills leaking. It should also be noted that in the preamble to the "Subtitle D" municipal solid waste liner system regulations (56 FR 51009), the US EPA has concluded that: "the composite liner system is designed to be protective in all locations, including poor locations." When taking into account the clayey character of vadose zone soils beneath the site, construction of a single composite low permeability liner at the Forward Landfill is believed to provide adequate protection against water quality impairment. The buffer provided by vadose zone soils is significantly enhanced by the inherently low leachate constituent concentrations historically identified at the site. In addition to attenuation within the compacted clay layer and vadose zone, water quality protection will be enhanced by numerous systems and operational controls that will be implemented including: • Extensive construction and post -construction CQA monitoring and testing (as evidenced by the site's history of construction). • Leachate monitoring and treatment systems. • Groundwater monitoring and treatment programs. • Surface water drainage management systems. • Landfill gas collection systems and monitoring programs. • Hazardous Waste Exclusion Program (WEP). • Daily, intermediate and final soil covers. These project design features, when combined with Forward's excellent operations practices and closure and post -closure planning further reduce the potential for groundwater or surface water impacts from the landfill. The combined influence of the design and operations features, site specific geologic conditions, and site specific operational and maintenance practices will result in a facility that is fully capable of protecting the groundwater in the vicinity of the landfill and meeting the applicable performance requirement of Title 27. These systems are expected to last beyond the time period in which leachate and gas would be produced. This report is based on the data referenced herein. Our firm should be notified if conditions are found that differ from those described in this report, since this may require a re-evaluation of the conclusions and recommendations presented herein. This report has not been prepared for use by parties and projects other than those named or described herein. It may not contain sufficient information for other parties or other purposes. g Q12000-0481Forward Composite Liner Y3 .docl09/19!02 Geologic Associates