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W. Michael Carroll -2 - 28 September 2005 <br /> San Joaquin County <br /> layer with non-woven geocomposite separator/filter; a 60-mil HDPE geomembrane; GCL and a <br /> prepared subgrade. The submitted design specification calls for a geocomposite drainage net and <br /> does not include a non-woven geocomposite separator/filter. The drainage net is required to have <br /> anon-woven geocomposite separator/filter component,please clarify this in the CQA document <br /> and drawings. <br /> 6. The proposed barrier liner design is not compliant with the WDRs or Title 27 for the side slope <br /> liner design. Construction Specification DA of the WDRs states: <br /> The Discharger may propose changes to the liner system design prior to construction, <br /> provided that approved components are not eliminated, the engineering properties of the <br /> components are not substantially reduced, and the proposed liner system results in the <br /> protection of water quality equal to or greater that the design prescribed by Title 27 and this <br /> Order. The proposed changes may be made following approval by the Executive Officer. <br /> Substantive changes to the design require reevaluation as an engineered alternative and <br /> approval by the Board. <br /> Staff cannot recommend that the Executive Officer approve the barrier liner design. <br /> ET Plan <br /> 1. The ET Plan states, "staff found that use of an ET cover would be acceptable for Module"P' <br /> (letter dated July 18, 2005) and requested that a test section of the proposed ET cover be <br /> constructed prior to the placement of the cap over Module "I"." Staff has stated in previous <br /> correspondence that the idea of utilizing anET cover is a viable option, but stated that a pilot <br /> study test pad would need to be installed and monitored over several seasons to verify that it can <br /> meet the performance goals of the prescriptive cover. <br /> 2. Two samples were collected and analyzed for particle size,plasticity, index,maximum dry <br /> density and optimal soil moisture. Hydraulic conductivity was determined from a composite of <br /> the two samples. The assessment and evaluation of the borrow pit area is an essential phase of <br /> the design and construction of an ET cover and two samples does not provide an adequate <br /> amount of testing. Refer to the guidance manual prepared by the Interstate Technology <br /> Regulatory Council(ITRC)entitled, Technical and Regulatory Guidance for Design, <br /> Installation, and Monitoring of Alternative Final Landfill Covers, December 2003. As stated in <br /> the ITRC guidance manual,proper design of an ET cover depends on a thorough understanding <br /> of three fundamental concepts: soil water storage, evapotranspiration and climatic factors, and <br /> critical design period. Additional soil sampling is warranted to demonstrates that the soil from <br /> the borrow pit is homogeneous and that the soil will be able to hold incoming precipitation until <br /> it is removed by evapotranspiration. Section 4 of the ITRC manual thoroughly details <br /> information that should be provided to support the design of an ET cover. <br /> 3. Soil specifications and corresponding soil sampling shall be provided in the CQA plan such that <br /> the soil placed within the ET cover is within specifications. <br />