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Andrew Keller - 3 - 17 January 2007 <br />precise than those of laboratory -performed ASTM D 5084. Conversely, literature <br />suggests that if soil smearing occurs during field-testing, then BAT results may lead <br />to an underestimation of the hydraulic conductivity. Therefore, tests performed via <br />ASTM D 5084 that do not meet the passing criteria of 1 x 10-6 cm/sec will be <br />considered failing test results. That portion of the cap will be removed or reworked <br />until the required criteria are met. BAT field test results are to be used as an <br />indicator of ongoing construction quality control. <br />3. Increase the Plasticity Index from 30 to 52. <br />Discharger Proposal: <br />Based on recommendations from their geotechnical laboratory, Condor Earth <br />Technologies (Condor), the Discharger proposed increasing the plasticity index (PI) <br />of the low -permeability material (i.e., the cap) from 30 to 52. However, Condor <br />cautioned the Discharger that excessive cracking of the cap may be a <br />consequence of increasing the PI with the resultant need to re -design, add <br />additional two to three feet of sand cover over the cap, remove and replace the <br />vegetative cover, irrigate the cover in dry months, and/or install a vapor barrier <br />layer. Condor cautioned that failure to closely maintain and monitor the progress of <br />desiccation and cracking might result in surface water entering the landfill. <br />Staff Comments: <br />Staff does not concur with the Discharger's proposed recommendation to increase <br />the PI to 52. As noted in Condor's letter, PIs larger than 40 may cause excessive <br />desiccation and cracking that leads to water intrusion into the landfill. Therefore, <br />the Discharger is encouraged to work with their clay materials -vendor and <br />geotechnical lab to determine a mix -formula for blending soils that have a final <br />product that meets both`the PI (<30) and hydraulic conductivity (1x10-6 cm/sec) <br />requirements. Therefore, by 28 February 2007, the Discharger shall provide a mix - <br />formula that will produce the material that meets the PI and hydraulic conductivity <br />requirements. <br />Discharger Proposal: <br />The Discharger stated the existing groundwater monitoring wells MW -2 and <br />MW -3 are not appropriately located for perimeter monitoring activities. The <br />Discharger proposed that these existing wells be abandoned and that two <br />replacement wells be installed eastward and at the property boundary. A proposed <br />monitoring well replacement map was sent to staff via email. <br />Staff Comments: <br />Staff concurs with the Discharger's proposed abandonment of existing MW -2 and <br />MW -3 and the replacement of those two wells with MW -2A and MW -3A. The <br />replacement locations shall be as shown on "Figure 1, Proposed Locations of <br />Replacement Wells" dated 22 December 2006, and received via email by staff. <br />Upon completion of installation, a Monitoring Well installation Report shall be <br />submitted to the Regional Water Board, as required by the CAO. <br />