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Mr. Greg Basso -5- January 25, 1988 <br /> 18. The Closure Plan does not contain a post-closure cost <br /> estimate. A post-closure cost estimate is required by DHS <br /> in order to estimate financial assurance requirements. <br /> 19. Maintenance must be provided during the 30 year post-closure <br /> period for the following: all benchmarks, all monitoring <br /> wells, all suction lysimeters, the leachate collection <br /> system, the cover and cap system , and the drainage system. <br /> -40 CFR 265. 118 (c) <br /> -22 CCR 67409 <br /> 20. The Closure Plan does not address leachate removal or <br /> disposal. Provisions must be made for the testing and <br /> proper disposal of the leachate collected from the modified <br /> leachate collection system. <br /> -40 CFR 265. 111 <br /> -22 CCR 67409 (a) <br /> 21. The Closure Plan does not adequately define the uppermost <br /> aquifer. Although some good characterization has been <br /> completed, further hydrogeological study is needed to <br /> comprehensively characterize the uppermost aquifer. By <br /> using various pump and slug tests, further study should <br /> define aquifer characteristics and the degree of <br /> interconnection between the lower and upper zones of the <br /> aquifer. Four additional hydrogeologic cross sections <br /> should be drawn, with two parallel to groundwater flow and <br /> two perpendicular to groundwater flow. These cross sections <br /> should include water level data, well construction <br /> information (screened and filter pack intervals and total <br /> depth of drilling) , and data from all previous soil borings. <br /> -40 CFR 265.90 <br /> -40 CFR 270. 14 (c) (2) <br /> 22 . The Closure Plan does not adequately characterize annual , <br /> groundwater flow direction and rates. Horizontal and <br /> vertical gradients must be established using data from the <br /> new wells. It is recommended that graphic flow nets be <br /> constructed on each of the hydrogeologic cross sections. <br /> Changes in groundwater flow caused by local agricultural <br /> pumping, domestic pumping, and seasonal fluctuations must be <br /> examined and explained in more detail. <br /> -40 CFR 265.90-.91 <br /> -40 CFR 270. 14 (c) (2) <br />