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WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2010-0123 -6- H.M. HOLLOWAY, INC. H.M. HOLLOWAY SURFACE MINE LANDFILL PROJECT KERN COUNTY 41.The Central Valley Water Board may specify a non-statistical data analysis method pursuant to Title 27 Section 20080(a)(1). Section 13360(a)(1) of the California Water Code allows the Central Valley Water Board to specify requirements to protect groundwater or surface waters from leakage from a solid waste site, which includes a method to provide the best assurance of determining the earliest possible detection of a release. 42. In order to provide the best assurance of the earliest possible detection of a release of non-naturally occurring waste constituents from a Unit, this Order specifies a non- statistical method for the evaluation of monitoring data. 43.The specified non-statistical method for evaluation of monitoring data provides two criteria (or triggers) for making the determination that there has been a release of non-naturally occurring waste constituents from a Unit. The presence of two non- naturally occurring waste constituents above their respective method detection limit (MDL), or one non-naturally occurring waste constituent detected above its practical quantitation limit (PQL), indicates that a release of waste from a Unit has occurred. Following an indication of a release, verification testing will be conducted to determine whether there has been a release from the Unit, or there is a source of the detected constituents other than the landfill, or the detection was a false detection. Although the detection of one non-naturally occurring waste constituent above its MDL is sufficient to provide for the earliest possible detection of a release, the detection of two non-naturally occurring waste constituents above the MDL as a trigger is appropriate due to the higher risk of false-positive analytical results and the corresponding increase in sampling and analytical expenses from the use of one non-naturally occurring waste constituent above its MDL as a trigger. DESIGN OF WASTE MANAGEMENT UNIT 44.Section 20080(b) of Title 27 allows the Central Valley Water Board to consider the approval of an engineered alternative to the prescriptive standard. In order to approve an engineered alternative in accordance with Section 20080(c)(1) or (2), the Discharger must demonstrate that the prescriptive design is unreasonably and unnecessarily burdensome or will cost substantially more than an alternative which will meet the criteria contained in Section 20080(b), or would be impractical and would not promote attainment of applicable performance standards. The Discharger must also demonstrate that the proposed engineered alternative liner system is consistent with the performance goal in accordance with Sections 20240, 20260, and 20310 of Title 27, and provides protection against water quality impairment equivalent to the prescriptive standard in accordance with Section 20080(b)(2) of Title 27. 45.Section 13360(a)(1) of the California Water Code allows the Central Valley Water Board to specify the design, type of construction, and/or particular manner in which