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Foothill Sanitary Landfill -7— <br /> Module <br /> 7— <br /> Module LF-2 -Liner Performance Demonstration <br /> San Joaquin County <br /> Appendix E <br /> Table 1 —Please include other alternatives for cost comparisons, such as a bottom liner with a double <br /> composite system and a pan-lysimeter under drainage systems in the landfill. This would give several <br /> other options for liner system cost calculations that could be included in a liner design. <br /> In studies done by USEPA it has demonstrated that approximately half of all composite liners leak to <br /> some extent. The majority of these problems appear to be either the liner being compromised during <br /> construction or poor design. To reduce the risk of holes or rips during construction, as proposed above, <br /> some type of electrical testing would be appropriate over the entire liner. In addition, at many landfills <br /> the impacts to groundwater appear to be in the gas phase transporting volatile organics compounds to <br /> groundwater. It appears prudent to construct and operate a gas collection and control system as the <br /> landfill is being filled. With an extensive electrical testing of the liner system, a landfill gas extraction <br /> system and addressing our comments in this letter, staff believe we can support a single-composite liner <br /> to the Board. <br /> Please address the above issues in a revised liner demonstration document. <br /> Conclusions <br /> The County must submit the following documents in response to these comments: <br /> Task Compliance Date <br /> Submit revised Evaluation Monitoring Plan in accordance by 1 October 2002 <br /> with Title 27 <br /> Submit Final Closure Plan for Module LF-1 in accordance by 1 January 2003 <br /> with Title 27 <br /> A Report of Waste Discharge must be submitted which incorporates the revised Liner Performance <br /> Demonstration in order for staff to revise WDRs for consideration by the Board. <br /> If you have any questions, comments, or would like to schedule a meeting to discuss the issues,please <br /> call me at(916) 255-3137. <br /> KIM A. SCHWAB, RG <br /> Associate Engineering Geologist <br /> cc: Robert McClellon, San Joaquin County Environmental Health Division, Stockton <br /> Permitting and Enforcement Division, Solid Waste Management Unit, CIWMB, Sacramento <br /> kasToothill Mod 1 LinerDemo <br />