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STATE OF CALIFORNIA PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD- CENTRAL VALLEY REGION 3443 ROUTIER ROAD, SUITE A SACRAMENTO, CA 95827-3098 CEIVED PHONE: (916) 361-5600 FAX: (916) 361-5686 0 C T 1991 ENVIRONMENTAL HEALTH L- PERPONT/SERVICLS 16 October 1991 Mr. Greg Basso Forward Inc. P. O. Box 6336 Stockton, CA 95206 FORWARD LANDFILL, SAN JOAQUIN COUNTY (CASE NO. 2209) We have reviewed the design plans dated 12 September 1991 for the Class II land treatment unit prepared by Harding Lawson Associates (HLA). This unit is designed for the bioremediation of nonhazardous diesel contaminated soil. The plans and supporting calculations do not satisfy the requirements of Title 23, California Code of Regulations, Division 3, Chapter 15 or Forward's waste discharge requirements (WDRs). In addition, there are certain design features which can be readily changed to improve the water quality protection afforded by the waste management unit. Therefore, we do not approve construction of the land treatment unit for diesel contaminated soils as proposed by HLA. The deficiencies in the design plans and recommended improvements are outlined below. The HLA design plans need to specify the California registered civil engineer or certified engineering geologist who supervised the design work and who will supervise the construction and certify that the containment structures meet the prescriptive standards and performance goals of Chapter 15 and the project plans, as required by Discharge Specification B.14 in the WDRs. Discharge Specification B.12 in the WDRs requires all clay liners to have a hydraulic conductivity of 10-6 cm/s or less. The HLA plans and specifications do not address this requirement. Furthermore, there is no discussion of construction quality assurance (CQA) for the project. We recognize there is a CQA plan for clay liner construction at Forward, but it does not address construction of a clay liner over a flexible membrane liner (FML). And to our knowledge, there is no CQA plan for FML construction at Forward. For example, the HLA plan proposes chemical adhesives to seam the liner material. HLA does not discuss how the seams will be inspected or whether constituents in the adhesive will impact water quality monitoring at the facility. These CQA issues must be addressed by HLA and/or Forward prior to our approval of this project.