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Mr. Horton <br /> Page 3 <br /> Clay Cap Construction Design - The lack of adequate clayey <br /> soils at Harney Lane requires the County to mix local soil <br /> with imported clay to produce an admixture capable of <br /> passing the permeability tests. The CQA plan provides two <br /> options to perform the mixing. one is to spread the <br /> imported clay over a thick lift of native soil, mix with <br /> large rotor-tilling equipment, then compact in place. The <br /> alternative mixing method is to use a mixing table <br /> arrangement where the two soils are mixed in a specified <br /> area (the 'mixing table' ) then transported to the cap area <br /> for compaction. As described by Kleinfelder in the CQA <br /> plan, the in-place mixing process raises serious doubts <br /> regarding the County's (or any subcontractor's) ability to <br /> achieve a homogeneous, low permeability cap and provide <br /> adequate construction documentation. For the reasons <br /> described below, the Regional Water Board requests that the <br /> County prohibit the use of in-place mixing and instead use a <br /> mixing table system to prepare the clay admixture. <br /> Regional Water Board staff have observed construction of a <br /> clay barrier layer at another landfill using rotor-tillers. <br /> In that case the mixing process resulted in a heterogeneous <br /> mixture of clay clods and native soil. This was due to an <br /> attempt to mix Ione clay and native soils at a moisture <br /> content which was too high for rotor-tillers to be effective <br /> mixers. The goal of mixing is to achieve a homogeneous <br /> distribution of the clay and the native soil. <br /> Moisture Content - Moisture content is specified at three <br /> percent (3%) over optimum. Kleinfelder indicated that three <br /> percent (3%) over optimum at 95% compaction will result in a <br /> liner with acceptable permeability. A range of acceptable <br /> moisture contents must be specified. Otherwise, CQA <br /> personnel will not know when clay is in an acceptable <br /> condition for installation. The rationale for this range <br /> must also be given. <br /> Borrow Area Soil Tests - The CQA plan includes a summary of <br /> permeability tests on borrow area soils mixed with Ione clay <br /> (Table 2-1) . The Regional Water Board Staff is concerned <br /> that these laboratory permeabilities are so close to the <br /> regulatory requirements that small variations in mixing <br /> ratios, moisture content or compactive effort in the field <br /> may cause the finished liner to fail CQA testing. As <br /> Kleinfelder notes, there is not much cushion in the lab test <br /> results. Experience indicates typical construction <br /> techniques result in field permeabilities that are 10 to loo <br /> times higher than lab results. Given this relationship, a <br /> conservative interpretation of the results shown on Table <br /> 2-1 suggests that only one of eight samples tested (Sample <br /> 6) will meet the field permeability requirement. <br /> Kleinfelder recommends increasing the imported clay content <br /> from 15% as used in the laboratory tests to 20% in the <br /> field. This is a good recommendation, however, no test data <br />