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Mr. Greg Basso -2- January 25, 1988 <br /> 3 . There is no plan to test outside the trench area to <br /> determine whether any hazardous waste has been spread <br /> beyond the trench boundaries. DHS is aware that the facility <br /> has not taken waste since 1984, but there has never been a <br /> plan of this nature submitted to DHS. If a sampling survey <br /> has been conducted in the past to meet this requirement, <br /> the data should be included in the Closure Plan Addendum. <br /> If there has been no such sampling conducted, a plan must <br /> be submitted. The sampling data must include sample <br /> locations, depth, and lab analysis. <br /> -40 CFR 265. 112 (b) (4) <br /> 4 . The Closure Plan does not include a demonstration that gas <br /> will not be emitted from the trench area. A demonstration <br /> that includes all the possible chemical reactions inside <br /> Waste Management Unit A must be submitted, or a gas <br /> containment system must be designed. In addition, it must <br /> be demonstrated that incompatible wastes were not allowed to <br /> comingle within the trenches. <br /> -22 CCR 67409 <br /> 5. In the Kleinfelder Soil Stability Analysis it is not clear <br /> what specific areas -of the trenches were tested ; DHS is <br /> concerned that the north side of the trenches (2: 1 slope) <br /> were not considered in the analysis. We request the detail <br /> from this analysis, including the data input into the <br /> computer program, be included in the report. <br /> -22 CCR 67409 (a) (5) <br /> 6. The Closure Plan and the Kleinfelder Soil Stability Analysis <br /> Report must be signed and stamped by the responsible <br /> Registered Civil Engineer. The subsurface analysis, <br /> including the hydrogeology and groundwater monitoring <br /> subsection, must be signed by the responsible Registered. <br /> Geologist or Certified Engineering Geologist. <br /> - Professional Engineers Act, Article 3 (6735) <br /> - Geologist and Geophysicist Act, Article 3 (7835) <br /> 7 . The clay liner described in the cap does not have sufficient <br /> thickness. The clay liner in the cap must be at least 2 <br /> feet thick and may not be more permeable than 1 x 10-6 cm/s <br /> during any of the tests described in comment #8 below. <br /> - 40 CFR 265.310(a) (5) <br /> - 22 CCR 67409 (a) (1) <br />