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1 • • <br /> O/LDC -2- 13 July 1987 <br /> HAR WORK PLAN <br /> There was significant disagreement over the outcome of the last <br /> meeting between Dallas and RWQCB representatives. Dallas and JHK <br /> felt that all the inadequacies of the HAR work plan had been ironed <br /> out at that meeting, and that additional work could not be added at <br /> this time if they were to meet the 1 October 1987 deadline for the <br /> HAR. To attempt to rectify the areas of disagreement, point by <br /> point discussion of the comments of Bob Fujii (memo dated 25 <br /> February 1987) and myself (memo dated 26 May 1987) was undertaken. <br /> The following is a combined summary of the discussion on both sets <br /> of comments. <br /> Waste Characterization <br /> It was agreed that no further chemical characterization of wastes <br /> would be undertaken. All waste would be considered hazardous based <br /> on 1985 DOHS analyses. <br /> Physical Plant <br /> The proposed work should be satisfactory to complete the HAR. <br /> Climatology <br /> The proposed work should be satisfactory to complete the HAR. <br /> Surface Water <br /> The proposed work should be satisfactory to complete the HAR. <br /> Wells <br /> The identification of off-site wells within one mile of the facility <br /> is in progress. Currently, 50+ wells have been identified; 24 wells <br /> have drillers reports on file with DWR. <br /> JHK proposes to use stratigraphic evidence, from logs of off-site <br /> wells, to demonstrate that a continuous confining layer exists that <br /> would prohibit the migration of contaminants to lower water bearing <br /> units. We agreed that the reasoning behind the stratigraphic <br /> analysis was sound, if the quality and quantity of lithologic logs <br /> is sufficient. <br /> Chemical analysis of waters from off-site wells will probably not be <br /> sufficient, however, to demonstrate the migration of leachate from <br /> the SI or the lack thereof. <br />