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0 0 <br /> Mr. Greg Basso -4- January 25, 1988 <br /> 12 . There is no provision included to keep the clay liner moist, <br /> to insure minimum permeability, between lifts and before the <br /> next layer is placed. A provision to alleviate this problem <br /> must be included in the Closure Plan. <br /> - 40 CFR 265.310 <br /> 13. The placement of the soil liquid samplers (suction <br /> lysimeters) is not specified on a map of the facility. The <br /> location of the lysimeter should show their exact depth and <br /> placement in plan view. <br /> - 22 CCR 67188 (e) <br /> 14. The issue of erosion is not addressed in the Closure Plan. <br /> Erosion appears to be a problem on the north side (2: 1 <br /> slope) of the trenches. ' Documentation must be submitted <br /> demonstrating that erosion will not be a problem or an <br /> erosion control plan will have to be included as part of the <br /> Closure Plan. <br /> - 22 CCR 67288 (b) (3) <br /> 15. The Closure Certification included in the Closure Plan is <br /> not adequate. The Certification must be a final report <br /> that contains all of the testing done during closure. If <br /> any of the tests failed, documentation must be provided <br /> that describes the remedial action taken. In addition, the <br /> Certification should include all QA/QC work and field notes <br /> along with a data and construction summary. <br /> -40 CFR 265.120 <br /> -22 CCR 67215 <br /> 16. In the sampling and analysis section of the Closure Plan, <br /> the list of parameters is inadequate. The following <br /> parameters should be added to the list: <br /> a) tetraethyl lead <br /> b) vanadium <br /> c) phosphoric acid <br /> d) urea formaldehyde <br /> e) strontium <br /> -40 CFR 265.92 (b) <br /> 17 . The Quarterly Monitoring Reports should be sent to DHS as <br /> well as the Regional Water Quality Control Board. <br />