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Y <br /> Miller Brooks Environmental,Inc, <br /> 2124 Main Street,Suite 200 <br /> .1 MM EM AYMOOKS Huntington Beach,CA 92649 <br /> Phone:714.500.5400 Fax:714.960.2462 <br /> Aw EMAIL: Infoemlllerbrooksenv.com <br /> WEB SITE: www.millerbrooksenv,com <br /> September 23, 2008 <br /> Mr. Tadese Gebrehawariat <br /> California Integrated Waste Management Board <br /> 1001 1 Street <br /> PO Box 4025 <br /> Sacramento, CA 95812 <br /> Re: Response to Letter "Methane Venting System Installation Workplan at Cove Contractors <br /> Landfill, Facility No.39-AA-0010" <br /> Dear Mr, Gebrehawariat; <br /> Miller Brooks Environmental, Inc., on behalf of Cove Contractors, has prepared this response to <br /> the California Integrated Waste Management Board's(CIWMB)letter regarding the Methane <br /> Venting System Installation Workplan (Workplan)at Cove Contractors landfill, dated August 29, <br /> 2008. <br /> Comment#1 <br /> Cove Contractors agrees with the CIWMB that the passive methane venting system was <br /> designated as the preferred corrective action alternative by the owner/operator, <br /> Comment#2 <br /> Cove Contractors agrees with the CIWMB that the system is considered a vent installation in fill <br /> rather than a true "passive system". <br /> Comment#3 <br /> Cove Contractors agrees with the CIWMB that the vents will be equipped with sampling ports <br /> where monitoring of the concentrations of landfill gas will occur(see revised Figure 4). <br /> Comment#4 <br /> Cove Contractors proposes one year of monthly monitoring to establish trend of methane gas <br /> concentrations from the perimeter gas probes(PGP). After the first year, if the methane <br /> concentrations are above the regulatory threshold of 5%but have established a declining trend, <br /> Cove Contractors recommends continuing monitoring for an additional six(6)months and re- <br /> evaluating the trends. If the concentrations remain above 5%after the first year and have not <br /> established a declining trend then Cove Contractors will work with the CIWMB to design and <br /> implement an active landfill gas extraction system. <br /> Comment#5 <br /> Figure 3 of the Workplan does not include PGP-4 and PGP-6 as part of the proposed methane <br /> venting system because concentrations of methane gas were non-detect(ND) in past <br /> monitoring events. However, if methane gas is detected in these probes during future <br /> monitoring events, an extension of the methane venting system to PGP-4 and PGP-6 will occur, <br />