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Ms. Molly White -2- <br />CHANGE IN BARRIER METHOD AND ADDITIONAL DOCUMENTATION FOR <br />FOOTHILL LANDFILL SITE IMPROVEMENT PROJECT, CAO R5-2004-0706 <br />2. With RWQCB approval of the submittals described in #1, we will: <br />a. Construct the ET test section in 2005. The test section 4egetation will <br />include advanced growth, to approximate performance after vegetation is <br />established. <br />b. Revise Module "I" ET cap soil specifications accordingly. <br />It is also our understanding that. we will continue to operate the ET Test Section through <br />2010 (5 years). After completion of the 5 years of testing, we will submit final <br />assessment reports to RWQCB. RWQCB's review of this report will be the basis for <br />RWQCB staff to either approve the ET cover design, or request modification of that <br />design. Such design revisions will likely require additional work on the seven -acre ET <br />cap installed on top of Module "I" in the Foothill Landfill Site Improvement Project, <br />MODULE Ul SIDE SLOPE BARRIER <br />We will submit the redesign of the Module "I"/1 side slope barriez to conform to the <br />directives of your email of October 21, 2005, requiring a composite liner with HDPE <br />gemembrane over the refuse of Module "I". This submittal will include: <br />a. Features to allow the escape of landfill gas. We may submit this detail prior <br />to other items. <br />b. Selected details, revised to show the use of the HDPE membrane. <br />c. CQA Plan text reflecting the inspection and certification of this new <br />component of the project. <br />We anticipate this will be submitted in November. We hope that this submittal can be <br />reviewed within two weeks of receipt. <br />Please let us know if our understanding is correct, or please call to discus any items that <br />require clarification. If our understanding and schedule are acceptable to Board staff, we <br />will proceed with this work immediately. And, if this meets with your approval, we <br />would appreciate acknowledgement in writing within two weeks. This will allow us to <br />proceed before we receive a revised CAO. <br />IMPACT TO SCHEDULE <br />With all due respect, we disagree that the WDRs were intended to apply to the barrier <br />between Module "I" and 1. We believe that recognition of this, and of the significant <br />concern for ballooning under a HDPE liner placed over refuse prompted previous <br />RWQCB staff to approve the barrier first submitted in the Project Design Report <br />(August 2004). Since that time, we adhered to the design decisions trade and approved <br />by Board staff, and made a conscientious effort to confirm the design concept in the <br />design details developed over the next year. We were therefore surprised to receive a <br />