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Mr. -Tom Horton <br />Page 2 <br />Board Comments <br />1. The Preliminary Postclosure Plans Certification is not <br />signed in accordance with 14 CCR 18261. <br />2. Drainage calculations are not based on the 100yr-24hr <br />precipitation event per 14 CCR 17778. Include a sample <br />calculation for area M and indicate how each value in a <br />tabular column of the print out table was obtained and list <br />all assumptions.. Run-off coefficients used in the <br />calculations should be based on the assumption that the <br />vegetative layer is saturated prior to the commencement of <br />the 100yr-24hr precipitation event. Adjust closure and <br />postclosure cost accordingly. <br />3. Final cover cost estimates for future 20 acre cells which <br />will have composite liners and covers should include costs <br />for a gas extraction and control system which includes a gas <br />flare as minimum control measure. Include costs for <br />postclosure operation and maintenance of a gas extraction <br />and control system. <br />4. All plan estimates should indicate the base year and what, <br />if any, construction cost index and labor rate schedule were <br />used. Also, cost estimates must be based on using <br />independent third party contractors to prepare final <br />construction documents, perform the construction and perform <br />postclosure maintenance. <br />5. Modify the preliminary plans to indicate that permanent <br />perimeter gas probes for the current 80 acre unit, will be <br />installed at least three years prior to the anticipated <br />closure of the unit so that gas control measure can be <br />designed into the final cover if they are required to <br />prevent subsurface gas migration off-site. <br />6. Indicate who will perform the Postclosure inspection of the <br />cover and surface water drainage system. <br />7. Indicate that the leachate monitoring analysis costs are <br />based on testing for the same constituents required in the <br />Waste Discharge Requirements for the ground water monitoring <br />wells. <br />If you have any questions regarding the review process please <br />contact me at (916) 255-2332. For questions regarding the <br />financial mechanism, please call Allison Reynolds of the <br />Financial Assurances Section at (916) 255-2703. <br />