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3. Recharge of formation water into the wells was not timed. The EBA SAP indicated that well recharge will be timed; however, this was not mentioned in Addendum No. 2 to the Postclosure Permit. Kleinfelder does not see the value of repeatedly measuring recharge (which is very time consuming) and does not see how the value of that data could outweigh the significant increase in monitoring costs to Forward. 4. During sampling the bailer rope consisted of cotton and not nylon. The EBA SAP indicated that nylon rope will be used. Addendum No. 2 to the Postclosure Permit states that new rope will be used each time, but does not specify the rope type. Presently, Kleir feider is not aware of the use of cotto`ropy*iMes nylon rope affecting sample integrity. Because the factory disposal bailers used to obtain the samples are so light the additional weight of saturate cotton rope is beneficial to getting the bailer down the well. Cotton rope is also easier to handle and does not tend to become tangled. j. Sample bottles were not filled in the order specified in the plan. Although a sample order was specified in the EBA SAP, no order was addressed in Addendum No. 2 of the Postclosure Permit. In general, Kleinfelder field personnel fill volatile organic analysis (VOA) bottles first, followed by the other bottles. Unpreserved bottles are filled before preserved ones to reduce potential for cross - contamination. 6. Samples were not analyzed for TDS, radionucleids and coloform bacteria. Samples collected from Forward Landfill are typically analyzed for TDS and were specifically analyzed for this constituent in October 1991 as indicated in Kleinfelder's report, "1991 Annual Monitoring Report, Forward Landfill, San Joaquin County, California" dated February 7, 1992. Radionucleides and coliform bacteria are listed as analytes to be tested in the EBA SAP (pa®e 2). However, these constituents are not included in the analyte list in Table 1 oFAttachment S in the Postclosure Permit (as referenced on Page 17 of the Postclosure Permit, which takes precedence over the analytes in the EBA SAP We hope that this information will assist your resolution of the DTSC Report of Violations. We are enclosing copies of the revised Postclosure Plan for WMU A, Addendum #2, dated August 13, 1992. If you have any questions or need additional information, please do not hesitate to contact us. We appreciate your consideration of Kleinfelder. Sincerely, KLEINFELDE C. Alex M. Richards Staff Geol ist Tim Crandall, F.E. Project Engineer Enclosure FL2-92-227 Pagc 2 of 2 Copyright 1992 Klcinfeldcr, Inc. KLEI\FELDER 30" Fite Circle, Sacramento. CA QS827 19161 306-1701