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Therefore, a hypothetical the release scenario includes: <br />1. Newly constructed cell is lined with geomembrane and subjected to construction quality <br />assurance including liner leak detection after installation of operations layer over liner and <br />LCRS. Penetrations detected during leak detection are repaired. <br />2. During placement of initial lift of waste over operations layer, heavy equipment operator <br />inadvertently penetrates base geomembrane at the side of the landfill. Based on our <br />experience in repairing such damage, the damage consists of rips and tears in the <br />geomembrane that are usually less than 10 feet long. <br />3. Landfill gas escapes through the penetrations and ultimately carries VOCs to the <br />groundwater. <br />Hypothetical Corrective Action <br />The following corrective action response was developed to mitigate the impacts envisioned under <br />the hypothetical release scenario. The extent and complexity of the corrective action response is <br />proportional to the environment threat of the release and is consistent with the type and magnitude <br />of corrective action mandated by the RWQCB at the time this document was prepared. <br />The corrective action envisioned is based on the following assumptions and premises: <br />The focus of the corrective action is source control. <br />2 The low level release of VOCs to groundwater will not require active groundwater cleanup <br />(pump and treat, air sparging, etc.). This approach is justifiable given the remoteness of the <br />landfill and absence of surrounding residences. <br />The performance objective of the corrective action is to primarily stop increases in VOC <br />concentrations in groundwater and secondarily to reduce VOC concentrations in <br />groundwater over time. <br />Corrective action taken to mitigate the hypothetical release scenario will include the following <br />activities: <br />1 A geoprobe investigation to estimate the location of the release will be conducted. This <br />process of location will not be very exact and may be limited to identifying a suspect <br />module. <br />2 Install nine additional LFG extraction wells designed to draw preferentially from deep <br />within the waste. The wells will be located according to the apparent location of the release. <br />Corrective Action Financial Assurance Cost Estimate 4 September 30, 2008 <br />North County Recycling Center and Sanitary Landfill Public Works/Solid Waste Div. <br />