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Re-Manufacturing Closure Plan -3- 19 September 1991 Post-closure maintenance shall extend as long as the wastes pose a threat to water quality. Because hazardous wastes are being disposed of at the facility, the owner's liability will be long term. Comment No. 8 We asked for a Construction Quality Assurance (CQA) plan. Re-Manufacturing responded by stating that they will submit a report after completion of the project detailing construction activities, including as-built drawings, final and interim grades, field testing methodologies and results, material volumes, laboratory test results and all other pertinent related information. However, in addition to a final report, we requested a plan for all of those items. The closure plan addendum submitted did contain some of the information we requested. However, more detail is necessary as discussed in Comments 3 and 4 above. Re-Manufacturing should also refer back to our 26 June 1991 memorandum for our original request. Comment No. 9 The surface impoundment will be closed as a Class I unit (i .e. hazardous wastes, as defined by Title 22, will be left in place) . Monitoring will determine the effectiveness of the closure. Early detection through vadose zone monitoring will determine if additional mitigation measures are necessary. If future problems occur, we will re-evaluate the closure. Comment No. 10 Quarterly ground water monitoring is proposed for one year following the completion of closure activities. However, ground water monitoring will continue as long as the waste poses a threat to water quality. The frequency of monitoring and list of constituents may decrease with time. The extent of ground water monitoring can be somewhat minimized by using early detection vadose zone monitoring for the presence of migrating fluids. According to the plan, fluid contact with capped materials will be monitored using a suction lysimeter to be installed after completion of the cap. One lysimeter is not adequate for the entire cap. We propose four lysimeters for this purpose. Re-Manufacturing proposed to monitor the lysimeter on an annual basis in the 16 August 1991 addendum. However, no monitoring schedule was included in the 3 September 1991 submittal . The lysimeters need to be monitored more frequently than annually. Quarterly monitoring would be more appropriate. Of course, if no fluids are detected, there will be nothing to analyze. Comment No. 11 According to the plan, at least eight samples will be collected from the surface impoundment floor, ten from the sidewalls, and ten from the embankment tops. All confirmation samples will be analyzed for total lead. Twenty-five percent of the samples, selected randomly, will be analyzed for soluble lead. We also asked for additional analyses for confirmation samples in four areas of the impoundment floor (see 26 June 1991 memorandum) . Those four samples should be analyzed for total petroleum hydrocarbons (using method GCFID/3550) , phenols (using method 8240) , purgeable aromatics and halocarbons (using methods 8010 and 8020 or 8240) , in addition to lead. It is not necessary to analyze for these constituents in every confirmation