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Attachment B <br /> The Marley Cooling Tower Company <br /> Closure Plan Modifications <br /> r <br /> The Marley Cooling Tower Company (MCTC) shall modify the subject <br /> Closure/Post-Closure Plan to meet the following requirements: <br /> 1. Include the financial responsibility requirements for the <br /> closure and post-closure costs. (A report of violation <br /> pertaining to financial responsibility was sent to the MCTC <br /> by the Department on March 8, 1988 . ) <br /> 2 . (Page 12 , Paragraph ld) Clarify this paragraph to ensure <br /> accuracy. The interim closure activities address removal <br /> and disposal of all fluids, sediments/sludges and the most <br /> highly contaminated soil, not "all hazardous waste in the <br /> impoundment" as written. <br /> 3 . (Page 14 , Paragraph 1f) Specify how rinsate samples will be <br /> analyzed. <br /> 4 . (Page 23 , Paragraph 2a) The necessity for removal of <br /> additional waste and the underlying soil from the <br /> impoundment (in addition to the sediments and most highly, <br /> contaminated soil already removed) shall be determined as <br /> part of the selection of the final site remedial actions, <br /> not when the site remedial actions have been completed. <br /> 5 . (Page 25 , Paragraph 2b(2) ) Use of American Society for <br /> Testing and Materials (ASTM) D698 standard is of concern. <br /> MCTC should use the ASTM D1557 methods for compaction <br /> control. <br /> 6. (Page 31, Paragraph 2b(2) (f) ) Also, perform in-situ <br /> permeability tests. _ <br /> 7 . (Page 31, Paragraph 2b(2) (f) ) The requirement to provide a <br /> compacted barrier layer around the site to a depth as low as <br /> the level at which the owner or operator has deposited <br /> waste, shall be accomplished unless subsequent soil sampling <br /> and analysis shows, beyond a reasonable doubt, that no <br /> migration of hazardous constituents can occur. <br /> 8 . (Page 32 , Paragraph 2b (2) (f) ) Conduct additional sampling <br /> as prescribed- in- the RemedialActionOrder. (RAO) to ___ <br /> demonstrate that lateral migration has- not occurred. <br />