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Andrew Keller - 2 - 2 December 2005 <br />Cove Gontractors, San Joaquin County <br />4. Plan states that the cover material placed to date meets the minimum permeability requirements <br />of the prescriptive standard. Staff does not concur with this statement. The intermediate cover <br />was not placed in accordance with an approved Quality Construction Assurance Plan. In <br />addition, two soil samples (soil sample S-5 does not meet the minimum conductivity) having a <br />minimum hydraulic conductivity of 1x10'6 cm/s is not considered representative of the entire <br />cover. <br />5. A one percent cover grade is proposed. Additional information needs to be submitted to justify <br />this grade. Information shall include details of how the cover will be constructed to prevent <br />ponding. The Plan shall also include a proposed design of an effective drainage system that will <br />divert surface water drainage. <br />6. For the initial groundwater monitoring investigation, the groundwater samples should be <br />analyzed for the following additional constituents of concern: electrical conductivity, hexavalent <br />chromium (USEPA Method 7199), total petroleum hydrocarbons gas and diesel (USEPA Method <br />M8015), polyaromatic hydrocarbons and PCBs (USEPA Method 8082). Each groundwater <br />sample to be analyzed for metals shall be filtered. The following methods should be used for <br />metals: <br />USEPA Method 6010B: Aluminum, Barium, Beryllium, Chromium, Cobalt, Copper, Iron, <br />Manganese, Molybdenum, Silver, Tin, Vanadium and Zinc <br />USEPA Method 7041: <br />Antimony <br />USEPA Method 7062: <br />Arsenic <br />USEPA Method 7131A: <br />Cadmium <br />USEPA Method 7421: <br />Lead <br />USEPA Method 7470A: <br />Mercury <br />USEPA Method 7521: <br />Nickel <br />USEPA Method 7742: <br />Selenium <br />USEPA Method 7841: <br />Thallium <br />Cove Contractors Facility closure shall be in accordance with the Title 27 Sections 20950 and 21090. <br />Regional Board staff will be preparing Waste Discharge Requirements for the closure and post -closure <br />maintenance of the Cove Contractors Facility. Post -closure maintenance will be required for a minimum <br />of thirty years after the Facility is closed. In addition, based upon the groundwater monitoring <br />investigation, corrective action for groundwater cleanup will likely be required. <br />Please submit the following by 16 January 2006: <br />A revised Closure Plan that address Title 27 Sections 20950 and 21090 and comments included <br />in this letter. <br />2. Report of Waste Discharge that includes information as outlined in Title 27 Sections 21710, <br />21720, 21750 and 22205. We understand that some subsections are not applicable, however the <br />Report of Waste Discharge shall include information as it relates to the Facility. <br />