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Response: Forward Inc. is currently working with the RWQCB and their consultant to prepare the Liner Performance Demonstration. The document will be submitted under separate cover to the )TD. Comment 2: Plans for the Interim Final Cover to be installed on the existing unlined Austin Road WMU calls for, from bottom to top: a 24-inch foundation layer, a 12-inch low-permeability soil layer with a permeability of less than 10-5 cm/sec, a 12-inch protective soil layer and a drainage layer. Waste will be placed over the drainage layer. The Interim Final Cover should comply with the requirements for a final landfill cover in Title 27 Section 21090 which calls for a 12-inch thick Low Conductivity Layer with a hydraulic conductivity of 196. The)TD should be revised to comply with this requirement. Response: The interim final cover design has been revised to include a 1x106 low- permeability layer. Section 5.2.2.3 - Interim Final Cover has been revised to reflect this as has Drawing 6. Comment 3: In previous correspondence, dated & March 2000, and 29 November 2000, the Regional Board asked for plans with time schedule to close the existing unlined landfill footprint and install a cover. Closure with a cover of the unlined footprint is an important element in Corrective Actions to cleanup contaminant groundwater at Austin Road. The )TD with the changes noted complies with our request for a plan but fails to address the time schedule. Title 27 Section 22190 states that if the RWQCB finds that early closure of a waste management unit is necessary to prevent (or curtail) violation of waste discharge requirements (e.g., as a source control measure in corrective action) it shall adopt a Cease and Desist Order, which requires closure. At this time, Staff believes a Cease and Desist Order is unnecessary but the Austin Road WMU must be closed during 2002 construction season. Please submit as an addendum to the )TD, with a time schedule, to bring Austin Road to a grade that will insure drainage (no less than 3% positive slope), and complete installation of the Interim Final Cover no later than 1 October 2002. It may not be possible under permitted waste inflow rates to achieve the grading plan anticipated in the JTD. If this is the case, a revised fill/grading plan must be implemented so that the interim final cover is completed during the 2002 construction season. (L:\Allied\2000.193\Corres2002\Agency Res:05/23/02) 5