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ove4rhead/Lodi Door C* -2- 29 May 1987 Additional cross sections should be prepared to graphically represent the site hydrogeology. These should include the flow paths of ground water, based on measurements of vertical as well as horizontal gradients. Climatology No climatological information, required by Section 25208 . 8 (h) , was presented in the closure plan. The inclusion of this information was proposed in the HAR work plan, however. Vadose Zone A detailed characterization of the vadose zone beneath the impoundment is required in Section 24208.8 (i) of TPCA, to include soil moisture measurements and analyses for all chemical parameters that may potentially degrade ground water, in addition to the hazardous constituents present. These analyses should include standard minerals, TDS and electrical conductivity. Additional waste characterization is necessary to identify whether these parameters were present in the impoundment. In addition to more comprehensive chemical analysis, the vadose zone characterization presented in the closure plan should be expanded to include the entire thickness of the vadose zone beneath the impoundment. Monitoring System Section 25208. 8 (k) of TPCA requires a description of the existing monitoring system, and section 25208 . 8 (1) requires documentation that the system can detect seepage from the facility. Reliable, measurements of monitoring well reference point elevations, allowing accurate definition of ground water gradients, are necessary to satisfy these requirements. The existing monitoring wells, MW-1 through Mw-3, are probably perforated over too long an interval to accurately represent hydraulic or hydrochemical conditions at a discrete point in the water bearing zone. Migration from Impoundment Section 25208.8 (l) of TPCA requires a written statement indicating whether any constituents have migrated into the vadose zone, surface water or ground water, and whether any such migration is likely in the next five years. The information presented in the HAR must be adequate to support this statement. oualified Person It must be demonstrated that the person(s) preparing the HAR meets the requirement for a "qualified person" , as defined in Section 25208. 2 (t) of the Health and Safety Code.