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IL <br />This assumption was obtained from computer modeling regarding the <br />site. As is well established, output from a computer model is <br />dependent on input parameters. <br />If the input parameters do not accurately reflect conditions at <br />the site, then conclusions generated by the model will not be <br />accurate. Board staff feel that the following parameters were <br />not representative of conditions at the site: <br />1) There is approximately 264,000 cubic yards of <br />untreated ASW currently in place at the site. <br />The computer model is based on treated ASW. Treated ASW has <br />a PH of 11.0 to 11.5, much higher then untreated ASW. The <br />high PH of treated ASW in conjunction with the proposed <br />cementing agent will significantly reduce the mobility of <br />the metal contaminants in the treated ASW. Metals contained <br />in untreated ASW are more mobile than those in treated ASW. <br />For this reason, the Modeling using treated ASW is not <br />representative of the actual conditions at the site. A <br />complete characterization of the untreated ASW must be done. <br />Part of the characterization must be to sample the untreated <br />ASW and run the Waste Extraction Test (WET test) on the <br />waste to determine the actual mobility of the metals in the <br />waste and to determine if other hazardous constituents exist <br />at the site. <br />2) The computer model used a 12 foot clay separation layer <br />between the existing ASW and ground water with a <br />permeability of 1x10-5 cm/sec. Cross sections of the site <br />included in the 12/90 Report of Disposal Site Information <br />(RDSI) and a statement in the Solid Waste Assessment Test <br />(SWAT) indicate that ASW has been and currently is in <br />contact with ground water (Attachment 4). <br />Therefore, the clay separation layer must to removed from <br />the Model. <br />Other information submitted by Cove does not support the <br />conclusion of no impact on ground water for instance, levels <br />detected in monitoring well MW -5 located between the landfill <br />and Walker Slough exceeded the MCL for Barium (1 mg/1) and levels <br />detected in MW -9 located along the north property boundary, <br />exceeded the MCL for Cadmium (0.01 mg/1). A surface water sample <br />(SW -2) collected from Walker Slough exceeded the MCL for Barium <br />and Lead (0.05 mg/1) (SWAT). The location of the monitoring <br />wells and surface water samples are shown in Attachment 5. this <br />data does not corroborate the conclusion that no impact to ground <br />water or surface water has occurred. <br />The ground water model concluded that the site will not <br />significantly impact ground water for an additional 10 years. <br />' is .. incorrect <br />• parameters • the • _ <br />ntanalytical data, Board staff can not agree with Coves <br />• <br />of no significant impact on ground water. <br />2 <br />