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Forward Inc. Landfill -3- 17 March 1988 <br />Inspection Report <br />I split VOC samples from MW -4 and 5A for analysis by the <br />Regional Board's contract laboratory. Samples from 5A were <br />collected three times, first on 22 February using the same <br />protocol employed by EBA and two times on 28 February when <br />VOC samples were collected using the EBA method as described <br />above and then using a disposable bailer following purging. <br />Test results are pending. <br />The sample collection procedures observed at Forward do not <br />comply with the ground water sampling and analysis plan dated <br />August 1988 and submitted to the Board by EBA for the Forward <br />facility. In particular, the sampling plan calls the air - <br />drive pump to be removed from the well following purging, <br />steam cleaned and rinsed with deionized water, then <br />reconfigured as either a bailer or a bladder pump. The <br />samples were to be withdrawn from the wells using either the <br />bailer or bladder pump configuration. The plan calls for VOC <br />samples to be collected first, followed by samples for <br />progressively more stable constituents. The consultants (EBA) <br />have not followed their plan submitted to the Board, nor have <br />they demonstrated that the method used does not jeopardize <br />sample integrity. The discrepancy between sampling plan and <br />field procedure needs to be rectified. <br />The landfill's daily fill operations and maintenance are <br />generally in compliance with the WDRs. Forward has violated <br />a provision of the WDRs pertaining to new construction in <br />that Board approval of the Class III expansion (WMU D 88) was <br />not obtained prior to waste discharge. Forward has <br />subsequently submitted the construction report for this unit <br />to the Board and it is currently under review. Although <br />construction of the surface impoundment is complete, liner <br />samples for background chemistry have not been collected and <br />the construction report has not been submitted for Board <br />approval. <br />The liquid waste discharge incident observed at the landfill <br />indicates more effort is needed in the load checking/waste <br />acceptance program. Ground water sampling needs to be <br />conducted in the manner specified in the sampling plan. <br />STEVE E. ROSENBAUM <br />Engineering Geologist <br />SER <br />