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HARNEY LANE LANDFILL -3- 12 July 1991 CLOSURE PLAN REVIEW The County proposes to use in-house CQA personnel . The use of in-house Solid Waste Division staff to implement the CQA program is a conflict of interest. We recommend third party CQA, although we do not require third party CQA. Review of the resumes of County personnel proposed for CQA work does not indicate experience in the area of low permeability soils construction. Use of County staff to implement the CQA program could be a violation of the Business and Professions Code. The testing requirements of Title 14, Section 17774, are minimum requirements. Additional testing as required by each site's unique soil conditions require professional judgement. However, the CQA plan merely lists the testing requirements of Title 14. The CQA Plan and the cost estimates do not agree. The CQA Plan includes Boutwell permeameter tests and a Sealed Double Ring Infiltrometer test (SDRI) . There are no cost estimates for the Boutwell Permeameters or the SDRI. The County should note that the SDRI and ASTM D3385 (Double Ring Infiltrometer) are two different tests. ASTM 03385 is not equivalent to the SDRI and is significantly less expensive to conduct. The relationship between permeability, density and water content must be established through appropriate field and laboratory tests. Unless these relationships are established, moisture content and density specifications for the clay layer have no basis. The section on sheepsfoot compactor operation indicates that the compactor operator may have to run the water truck. This would seem to be a very awkward process. 4. AERIAL SURVEYS - In Part I, Section 9.0 on page 8, the Closure Plan indicates that two permanent monuments will be installed and every five years, aerial surveys, topographic maps, and iso-settlement maps will be completed. None of these costs are identified in either the Closure or Post-Closure estimates sections. 5. GROUNDWATER MONITORING COSTS - The Closure Plan does not include the cost of monitoring the existing wells during the closure period. If you have any questions concerning Regional Board review of the Harney Lane Closure Plan, please call Robert Evans at (916) 361-5672. cc: Ms. Lisa Babcock, Division of Clean Water Programs, SWRCB, Sacramento Mr. Ed Padilla, San Joaquin County Public Health Services, Stockton Mr. Gabe Karem, San Joaquin County Department of Public Works, Stockton