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Mr ' <br /> . Kevin Basso - 2 - 21 March 2001 <br /> defects per acre to arrive at 19 gallons per day or more likely(in staff's opinion) the average <br /> defect is some what larger. <br /> 4. The demonstration does not consider gas phase transport, gas phase transport occurs more rapidly <br /> with resulting less time to degrade. Board staff believes that gas phase transport is an important <br /> part of contamination transport at landfills that have releases. The discharger should demonstrate <br /> how a single composite liner or a double composite liner plus natural site conditions or a <br /> constructed gas control system would meet the performance standards. <br /> 5. The demonstration does not consider that over time the limited nutrients available to support <br /> bioremediation may become exhausted within a CCL. ` <br /> 6. The demonstration does not address inorganic constituents, the study assumes that the CCL will <br /> absorb all metals and does not consider TDS. Supporting data concern metal absorption in CCL <br /> should be provided and the fate of TDS must be considered. <br /> Forward should revise the demonstration in light of staff concerns listed above and provide additional <br /> site specific information, construction practices and operational practices that demonstrate why the <br /> Forward operation is uniquely suited to manage designated wastes. <br /> If you have any questions,please call me at (916) 255-3814. <br /> ROSS D. ATKINSON `" <br /> Associate Engineering Geologist <br /> cc: Mr. Robert McClellon, San Joaquin County LEA, Stockton <br /> Mr. Gino Yekta, CIMWB, Sacramento. <br /> Mr. Butch Stafani, Forward Landfill Operations Manager, Stockton. <br /> Ms. Sangeeta Lewis, Lewis Engineering, Piedmont. <br /> Mr. Curt Fuji, Forward Inc. <br /> RDA;C:\mydocuments\FORWARD\PerformApp2 <br /> s <br />