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1 <br /> Mr. Horton <br /> Page 2 <br /> r <br /> Network) and section 15 . 0 (Installation of Landfill Gas <br /> Monitoring System) have been duplicated in the postclosure <br /> maintenance plans. Section 15. 0 was copied from EMCON's study <br /> report of landfill well installation (Appendix F) . The <br /> duplication and repetition of descriptions prompts Board staff to <br /> question the individuality and quality of information to specific <br /> areas in the Plans. However, we have reviewed information <br /> provided to us. The following is a compilation of detailed <br /> review comments from the Local Enforcement Agency (LEA) , the <br /> Central Valley Regional Water Quality Control Board (Regional <br /> Water Board) , and the Board. <br /> 1. Sheets 6 and 7 are difficult to read. Please submit clearer <br /> copies. <br /> 2 . 14 CCR 17774 - Construction Quality Assurance, 23 CCR <br /> Chapter 15. <br /> Trade Secrets - Kleinfelder states that the CQA Plan <br /> contains trade secrets as identified in Health and Safety <br /> Code Section 25173 . The Regional Water Board requests that <br /> the County identify the sections or pages of the CQA Plan <br /> which contain 01trade secrets10 related to hazardous waste as <br /> defined in Health and Safety Code Section 25173 . <br /> COA Team Organization - A clear description must be provided <br /> to show how nonconforming field tests will be handled and <br /> who has authority to order reworking/removal of <br /> nonconforming areas. <br /> The CQA organization chart shown in Figure 3-1 suggests <br /> field data from the CQA technicians could flow up three or <br /> four levels of management before corrective action could be <br /> ordered and passed down to the equipment operators. The <br /> second paragraph on page 13 indicates nonconformance will be <br /> reported directly to construction personnel. If the on-site <br /> CQA technicians (i.e. the lowest link in the CQA process) <br /> have the authority to order failing sections reworked, then <br /> this authority and responsibility must be clearly explained <br /> so the CQA technicians, the construction supervisor, and <br /> equipment operators are all aware of their duties in the CQA <br /> process. <br /> Experience with Ione clay suggests nuclear gages tend to <br /> over estimate the amount of water in the clay that is <br /> actually available to lubricate the compactive effort. <br /> Since moisture content during compaction is critical, the <br /> CQA technicians must be familiar with any differences <br /> between oven-dried moisture content and nuclear gage <br /> measurement of moisture content. The proposed test pad <br /> analyses should identify and provide correction factors for <br /> any differences between nuclear gage and oven-dried moisture <br /> content measurements. <br />