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2020-08-05 Packet - Part 8-pgs-3500-3999
E, All installations!shall be secure and watertight, 103 PIPE 1N STALLATIO N A, Excavation, of' pipe trenches shall be in accordance with Section 02225 arenching and Backfilling)UffieseTechnical Specifications and as shown on the Plans. R The bottom of the trench shall be graded and prepared to provide a firin and unil"brm bearing throughout the entire, length of the pipe barrel. C Pil)c, fittings, and accessories shall be: installed in, accordance mrith nianufacturer's, histructions, Sealed joints shall be wateftight. D Pipe shall be placed to the lines and grades as shown on the Plans. E. The pipe shall be laid without break upgrade from structure to structure, with bell end upgrade for bell andspigot pipe, 1; The horizontal a]igflmen t of tbe pipe shall be laid such that any point sl1ail not vary more than 01,10 feet from the design al ignment cstablis,hed and shown on the Plans. G Pipe bedding material shall be placed at sides arid over top,of pipe in accordance with Section 02225 (Treriching and Backf lling), ofthese'rechnical Specifications and as shown on, the Plans. K Trench backfill above the Pipe bedding shall be in accordance with Section 02225(Trencliing and Backfilling)of these Technical Specifications and as shown on the Plans, Pipe shall not be displaced or damaged when,compacting. 104 CONCRETE' JUNCTION 13OXES A Excavation ror concrete junction boxes shall be in accordance with Sectioln 02222 (F`xcavatlooms)of these'T"eclinical Specifications and as shown on the Plans. B. Concrete junction, boxes shall be installed h'l accordance: with manufacturer's instructions. Placement of the conerete junction boxes into the excavation shall be performed in a manner that wi 11 not induce damage or compromise future stability, C1. Back-fill for concrete structures shall confortu to the provisions in Section 19-3 of the Standard Specifications, 3,05 LEACHA"FE SEDIMENT CHAMBER/WETWELL LINING A, Sequencing of this,task shall be after installation of the condensate discharge line fixmn the Mare station to the leachate wet well in order to,ensure that the new penetration is properly sealed by the lining application. B, 'The Contractor's Health and Safoty Plan shall be followed accordingly, including LIFU Lryrqjmt/07\Ta A 4-Tednical SPtTMC36Ww'S=1iOn p 5MO Leachile Oywflow C�ofkctm mdStomgc Syamndm RLM Clos=Commm,vion Tochnical Sp"ifloomimm 1-04 Ed4w4rvmv AuVist 2W,5 15500-6 Page 3500 of 4165 haz arils a,ind.po�ssible confi tied space entry(ie.,oxygen-deficient ahnosphere),for all J.ihases of'Work. C Prior to start of Work,provisions shall be made to divert leachate froni the existing leachate drain ftorn discharging into the leachate sediment charriber. 'rbe leachate may be diverted to the new leachate US1' (it'already installed) or collected in a temporary holding tank of sufficient size, D, Once discharge into the leachate sediment,chamber has been diverted, all leachate shall be ptimped From the leachate sediment chaniber and wet well. 'I'be pumped leachate may be discharged to the existing leachate AST',new leachate LISI'(if already installed),or temporary holding tank. E. If sediment is present at the base of the leachate sediment charriberayuVor wet well,provisions shall be made to rernove, all sediment. Removed sedirnent may be disposed of with refuse excavated from other site activities,or transported separately and d isp osed of at a permitted transfier station or solid waste disposal facility. R Existing purnpa and any other equipinenL/features that may inhibit application product shall be removed and stored in a dry and secure location. G, 1'he interior walls and base shall be cleaned to rernove all dirt,dust,corrosion prod UCLS,loose concrete,debris,grease,oils,growths,and foreigm matter and residues. Residual generated by the cleaning operations -,hall be reinoved and managed in the same inanner as, described previo usly for leachate and sedijuent, R Sufficient time shall be provided to allow the surfaces of the intcriorwalls and base,to dry. Drying time may be expedited by mechanical means. Coatings shall be applied only to a somid,clean surface profile consistent with the rnarruf,"acturer's published recommendation. L Cracks,joints,,eroded and damaged areas shall be sealed with a compatible grout/niorLar as recommended by the coating manufacturer prior to application of the coating in,aterial, Coating material shall be applied in a manner and thickness consistent with the fiia,nufacturer'spijbl�isliedre,co,m,iiie�ndation. (,oatingssliallbeappliedina iii,-ira.ier coii:sisterit with all applicable environinental and health and safety regulations, At a rnininnurn,during application, the applicatorssliall use protective clothing, eye protection, chemical resistant gloves,and air respiralors. Coating shall be applied to provide full and sufficient coverage of all interior walls and base and shall be five of blisters,pinholes,holidays,or discontinuities, Application shall be performed in strict accordance with recorr-nrnended manufacturer's procedures. K, Pumps and any other equiptnent/features that were ren,ioved shall be re-installed and normal operation offlie leachate sediment chamber/wet well restored per pre-existing conditions, 3.06 'FANK,HANDLING A Contractor Acceptwancc Inspection: "I'lie Contractor is responsible for dainage in shipment according to the checklist included in the tank shipment, Any discrepancies should be LApmjecul?(Mlask 3Jmkinivol SpxMrA6ou%s15e6oa 15500 syxtunAors Hnal Ckywe C"0116twettom I'mlinko SIXCHICaflorm MIA hk�;&rrrniw, A,ugusl 2,015' 15500-7 Page 3501 of 4165 reported to the Design Engineer. B, The tar ik shall not be dropped,rolled or impacted. The tank shall be set onsmooth ground, firee of rocks and foreign objects, and chock.tanks to prevent movement. 3,07 TANK INSI'ALLATION A. The tank excavation shall be large enough to provide: 1 2 feet of clearance between the tank sides and ends and the excavation walls in stable soil, 1 12 inches of bedding under the tank. R Excavation for the tank shall be inn accordance with, Section 02222 ([Excavation) of these 'rechnical Specifications and as shown on the Plans. Contractor shall slope or shore,sides of tank-hole excavation as required to COIT-1ply With the requirenients of"OSHA Construction Standards". (.11, The Wnk and all related piping and accessories shall be iristalled as per MaIIIA"hChn-er's printed instructions. 1. , Tank backfill shall' be as follows: I a Tank bedding rmiterial shall be evenly placed over bottom of the excavation to attain a minimum thickness of 12 inches. 2, A I 2-inch lift of tank backfil I shall initial ly be placed even]y aro and the tank, Care !shall be taken to Push backfill material completely beneath tank bottorn and Under end caps to provide necessaty tank support, without voids. 3, A SeCODd 12-inch lifloftank Sac ll shall be placedeverflyaroundthe tank usingthe sarm. procedures described above. 4. After completioni of the second lift,tank backfill can be brought tothetop, of the tank without actditicynal handwork. 5 17he tank shall never be left on the bed without tank backfill to the top oftank if there is any chance of more tbari 12 inches ofwater in the hole, 6. Once tank backfill inaterial has beeriplaced coalpletely over the tank to Ihe depth shown on the Plans,backfill the remainder of the tank excavation with engineered fill in accordance with Section 02224 (Engineered Fill) of' these Teclinical Specifications. 1018 PERFORMANCE TESTfNG A, UST Air Test: I Prior to setting the tank,the Contractor shall perform an acrostatic leakage test in,the presence of the Design Engineer. I Pressurizing the rellativelY small annular space between two(2)tank shells can occk,u very quickly. A pressure of over 5 psi may causes damage to the tank structure which may not be immediately apparent, For all such tests,an air gauge with.maximum V2 psi increments,shall be used. I 'The Contractor shall Provide an valve and marnfold arTarigernent with two (2), air gauges to perf'orm tests. 4, Testing shall be in accordmice wifli the tank manufacturer's instructions. 3-Techdcw sparlwWorm"Soclicn 05,00 Lmhmle OwTftw Collectm ad Swmge Symandw FlnA Ma mm Spocifica6ons MM B"meling 15500-8 Page 3502 of 4165 5 While tank is under pressure, the entire tank, includhig fittings, shoLdd be,wetted with a soapy solution to inspect for ininor leaf s which other-wise might not be evident. R Leachate Sedirrient Cbarnber/Wet Well: L Visual inqmction to verify a leak-free,uniforni appearance. 1 The applied wet film thickness sliall be verified, per ASTM D 4414, Standard Practice for Measurenlent of Wet Filni Thickness of Organic Coatin! s by Notched Gages,. 31, The leachate, sedirrient chamber and Nvet well shall bey operated after the fining application and re-assembly of the purrips and other equipment5eatu'res to verify that, the systeni is operating in accordance with pre-existing corrditions, C If tests, indicate Work does not rriect specified reqtfirernents, all Work shall be removed, replaced and retested at no cost u�)the C,ity. PART 4 MEASUREMENT AND PAYMENT 4.01 LEACHAT111 COLLECriON PIPING A. Leachale collection systein Piping shall be ineastired by the linear fool of collection piping installed and includes all piping, fittings, trenching, and backfilling. P'ayinent shall be included in the Contract Uhit Price per linear fbot installed fi)r the various sizes and types of "Leachate C011CCtion,Piping"addressed in this Sectiori and shall include full cornpensation for providing all niaterials, labor, equipment, tools, and incidentals required to install the leac:hate collection piping as shown on the Plans,as,specified herein,and as diTectedby the Design Engineer. No additional canapiensation will be allowed therefore, 4.012, CONCRETE RYNCTION BOXES A� Concrete jwiction boxes for the leachate collection piping shall be ineasured by each box i astalled and i tic lir de all trench i rig,ba,ckfi H,concrete, arid cover. Pay rune nt shall be included, in the Contract Unit Price per each unit installed for"Concrete Ruiction Boxes"addressed ill this Section and shall include ffill compensation for providing all rriatefials,labor,equipment, tools,and incidentals requircd to install tile concrellejunction boxes as shomm on the Plans,as, specified herein,and as directed blyflieDesignErigineer. No additional cornpensation will be allowed t1lerefore. 4.013 LE'ACHATE SEDIMENT'CRAM11 E R/WET WELL LfNIN(.3 A,. Measnrenmnt and paynient for fining of the leacllate sediment chuilheriwet well shafl be included in the Contract Lurnp Stim Price for "L,eachate Sediment Chainber[Wet Well L,ining" addressed in this Section and shall include fid"I compensation for providing all materials, labor, equipnient, tools, and incidentals reqnired to line the leachate sediment chamber/wet well as shown on the Plans,as specified herein, and as directed by the Design Engineer, No additional conipensation will be allowed theretbre. L. pToj=V907VI'ask 3 Tedaned 1500 Itsebair Owerflow Collmlion and Suoraqe Syvmmdoc RW Chiguro Coyonhudon TadupwA Speeffinwris 15500-9 Page 3503 of 4165 4,04 LEACHATE,UST A Measurement an(]paynient forthe leach ate LIST shall be included in theContract Lump Sum Price for,"L,eachate UST"addressed in this Section and shall include full cornpensation for providing all materials, labor, equipirnent, tools, general electrical work, and incidentals required to install the leachate LJSTand accessories as shown on the Plans,as specified herein and with in the tank.manufacturer's speciflications, and as directed by ffie Design Engineer. No additional compensation will be allowed flierefore. END,OF SECTION SpodfibuaknRiSecdon 15500 Lxuham Overflow 1701=60u)gild Stump syman'div HnOCIlomm,Comgrvcdon'redmu W SpotArkmbns ABA AuVW 20 p 5 15500-10 Page 3504 of 4165 ATTACHMENT CONSTRUCTION QUALITY ASSURANCE PLAN FINAL CLOSURE CONSTRUCTION Page 3505 of 4165 C ONSTRUCTION QUALITY ASSURANCE PLAN for the CITY OF UKIAH DEPARTMENT OF PUBLIC WORKS CITY OF UKIAH LANDFILL FINAL CLOSURE CONSTRUCTION October 2,013 Revised August 2015 EBA Job No. 02-907 Prepared by- EBA ENGINEERMG 825 Sonoma Avenue Santa,Rosa, CA 95404 (707) 544-0784 ES INEERING Page 3506 of 4165 TRUC710N QUALITY ASSURANCE DEAN CITY OF UKJAH tlljVNDFll,I, FINAL CLOSURE CONSTRUCTION TABLE OF CONTEN"I'S 'PAGE NO. DIVISION I - GENERAL INFORMATION 01.000 'NTT SDI,rC"ION .. .............w....., m,..,..,, ........... ......... ,........ ..,,,.,.. ,.,,,,.,. .. 9.000-1 O11010 OP'E OFF O " JCT'I ,, a..... .........ytl.,,.,., ,., ,...,,.µ, ... ..... ............ 40 — . 01039 PROJECT 1 EET1NG .... ..,................ ...M9..., .....,a.............. ,....,,,d „m,,,,,.,,.06039-1 01090 REFERENCES .,,,.,......—.... ................ .. ................... ............ ...... ............ 01.11910-1 01300 BMIl"TALS.......... ....... ................ .. .....§... ,,.,,.,,,,,.,, ,.,. ,,,,..... 0 13 00'—1 01400 DOCUMENTATION--... ......... ......... .......... .,.µ,..., ...,..... ...................... 14 0-1 DIVISION 2—CONSTRUCTION QUALI ASSURANCE CQ ':ED K 012201 GGREGATE, MATERIALS ......... ..... ..........4.... ..,.,,,., ,. ,, .,,.,.,., w....,,.....022tlT.1V. 02222, EX("r AT'JON ,...,, ,a........ ......... ........... ............02222-1 22�4 ENGINEERED FILL..... .......w.,.,rv.. ... u,,,.,..,,.,,........ ,.,,........... ...,,02224�—�1. O�222,5 TRENCHING AND BA(,KF.1L�L1NG,,,, ,,,,,,,,, ,,,,,,,.. .,.,...., .,,...... .,.,,.......022 —1. 02240 FOUND« rIO 023 10 ACCESS ROADS.—................... o,,.,..,, .,,,.,,w, ......... ........, .,...µ.., ...........,023 101-1 02722 DRAINAGE AND EROSION CONTROLS........ ............. ............O2 2-1 02771 1 I F RCEME ti'T' E,01" TILE,.,,,,,., ,.,,,,...d ,n„ ......... ......... ............O1 7 1-1 4� �rrcyj ct J R I tarn N"rw'�C1u;;,h&' Rnu[:.rcCr:�nH pril[W d 0amra Com aAruc4ion k.:Q k Man n Page 3507 of 4165 TABLE OF CONTENTS PAGE NO. DIVISION 2—CQA PROCEDURES (Continued) 02772 GEOMEMBRANE. ......... ......... 02772-1 02773 ENG[NEEREDTuRF.......... ......... ........ 02773-1 O�29,0 SEEDING AND FERTILIZING.. ......... ......... ...... 02900-1 02960 TEMPORARY EROSION AND SEDIMENTCONTROLS.... 02960-1 O�3300 CONCRETE ..... ...... 03300-1 15100 LANDFILL GAS (LFG) EXTRACTION WELL,S............... .......--......... 15 100-1 15200 LFG COLLECTION SYSTEM COMPONENTS ....... ....... 15200-1 15300 FLARE ST'A'r1ON... ........... .. -...... ........-......-........ .........-.-........— 1 00-1 15400 FLARE STATION ELECTRICAL AND'I'ELEPFIGNE F!",E1')---...—.... 15400-1 [5500 LEACHATE OVER FLOWCOLLECTION AND STORAGE SYSTEM.. 15500-1 USTOF APPENDICES Appendi ..............- ........... ............-....... Project Document Fonns Appendix B......--............ ............ ...... Soils, Monitoring FolIns Appendix C............... ... ...... Gcosynthetics Monitoring Forms Appendix D ..----....... ........ ........ ... Submittal Control L.0'9' 1'ur1'CQA llbmi't=AocIf'W(Immure 0mwrtwUrpn CQA ftn A'Bd byginpering, Augum 20�5 Page 3508 of 4165 DIVISION I GENERAL INFORMATION Page 3509 of 4165 (-;QA SECTION 01000 INTRODUCTION PARTI GENERAL 1.01 PROJECTI)ESCRIPTION A, The City of Ukiab Landfill is located fil, Mendocino County, Califbmia approximately two miles east of the City of Ukiah. "'I'lie Work site address is 3 100 Vichy Springs Road, Ukiah, Ca,lifomia ,9548,2 (Sheet 1). The City of UkJah Lalidfifl was, operated as a Class III solid waste disposal facility and is comp!rised of a single waste management unit that is approximately 40 acres in size. 1 . This Construction Quality Assurance (CQA)Plan applies to the final closure of the City of Ukiah Landfill, The final closure project encompasses approximately 65 acres in area and consists,of the following construction features: ,bite ft�pAcLtiqti: Refuse excavation and relocation, Interim cover pi.eparation. I'll in aL Co ver 5 ys,Lqm(J�Ligscending. A gL r 0 1-foot,thick fioundation layer. a Gas relief/venfing system. a LLDPE geomenbrane. 0 Engineered synthetic turf with specific grade sand in fi I l balas,t. Miscellaneous iterris: Drainage and erosion control IncaSLIMS, Sedimentation basin finprovernents. Access roads. General earthwork, including various excavations and fills. Leachate overflow colllection and,storage system,including installation of a leachate undergrcmd storage tanks(UST). Landfill gas,(1,FG)collection system, including condensate drainage components. Bon-ow area reclaniation, Seeding and fertilizing. Security fencing, C. A detailed scope of coin stnxtion for eaCh Unit Of 001IStIUCti0l)is presented in Section 01011,0 of this CQA Plan. 1.012 PURPOSH' A The purpose of t1lis CQA Plan is to provide a detailed guidance doctiment for correct and thor(,)ug]iCQAve:rificatioiiprocedures iti.ipletTici-ite:dduri,n,gconstructioii. This QA Plan is also, intended to identify, prevent, and correct problems and deficiencies that inay occur during construction. 71his COA Plan details general and specific requirements of tine CQA prograin that will be implemented during constrUction to verify and document that construction is in compliance with the contract documents and the design, intent. P19W4"QA W000 hAtodued"n duo Nnal Ckmum Cons(ruction CQA Men ETA rngineming ry 0 1000 — I August 20�5 Page 3510 of 4165 Requirm"nents of the CQA program include the following: L Product quality assurance verification testing to verify that all inaterials are in compliance with the"I"echmeal Spec ifications. 2. Construction monitoring and docurnentation to verify that each unit of construction is in compliance with the'Velchnical Specifications and that constmcfion was executed correctly using industry-standard construction methods and the proper materials. 3. Reviewariidapproval of product submittals to verff"y that constniction materials are in compliance with the"rechnical Specificatiolls. 4. Testing,to verify that installed or constructed components are in compliance with the Tecirrnical Specifications, 5. CQA documentation consisting of Daily SUITImary Reports,CQA field logs,testing forms, instal kation, logs, docurnent control binders, material control logs, testing reports,, photographic documentation, technical revisions, design modifications, record as,-built drawings,and corrective action deternlination and verification reports, 6 Preparation of the CQA Certification Report that documents the CQA program intplamented during construction and that construction was completed in cornphance with the contract documents and the design intent. The CQA Cer-fification Report wit] be submitted to the California Regional Water Quality Control Board, North Coast Region(RWQCB�). 13® Although the (,,,QA Plan provides as foundation for the CQA Program, Illis plan may be iii,odifieda,vidrevisedasa,pproptiat,epiiortoan(:Iduritigcon!structioii. All n-rodificationsand revisions to the CQA prograrri wil I be documented in the CQA Certification Report 1 03 PROJECTORGANIZA"HON A. Tbe City of Ukiah, Department of Public'Works((-,,,ity)is the owner auid operator of the ;it ofUldah Landfill and has ultimate responsibility for the 1.1roject, including overall project inanagement and project funding. For purposes of this CQA Plan,the City,will be referred to as "Owner". "['be Owner has, contracted with the following organizations to complete construction in accordance with the project:documents listed in Part 1,02 o Nection 0 10,90 (References)of this CQA Plan. I. EBA Engineering,(EBA) - Design Engineer and CQA vertu rying Engineer. I I'o flee Determined---Construction Cuntractor and Subcontractors. B. EBA is the Design and CQA Certifying) Engineer for the Projeci. As the Desi&qn E'ngineer, E13A is Tesponsible for the desigm and site engineering related to the design. Site engineering includes: 1) review and approval of product and construction subinittals required by the coMract documents; 2), technical issues related to construction; ) interpretation of the Technical Specifications and the Construction Drawings(herein after-refeiTed to as"Plans"); and 4)design modifications and ,teclinical revisions. For purposes ofthis(.,QA Plan,E, A 13 will be referred to as"Design Engineer"when functioning as tine Design Engineer. As the CQA Certifying Engineer, EBA is responsible for certirying to the Owner and RWQCB that construction is in compliance with the contract docunients and:, the design intent, Specific responsibilities of the CQ Certifying Engineer include: 1) providing a profe,:ssional engineer or certified engineering geologist registered in the,state of C'alifbrnia;2) inalflernenting and managing the CQA program outlined in Part 1,02 of this Section;3)review of all CQA documentation; and 4)preparation ofthe CIQA Certification Report, EBA will provide an on-site CQA Tearn to implement and inanage:the C QA progyrain consisting of a CQA Officer, CQA Monitors, a CQA Surveyor,and Geosynthetics and Soils CQA Testing Laboratories, For purposes ofthis CQ,A Phui, EBA will be referred to as"CQA Officer" I'uxfCQA PlavACQA 0104,H)kAroduruODAIDC Foal C30mire Cbngtrua031 CQA Plim L"N 1"qMewing 01000- 2 Augmt 20�5 Page 3511 of 4165 when,feu nctioning as the CQA Cedifying Engineer. (1, I'he Construction Contractor is responsible for ovcrall perRumance of the earthwork, including const!ructio n of drainage and crosion control meas-ores, in accordance widi the contract,documents and as shown on the construction drawings, For puq)oses ofthis CQA Plart, the Constniction Contractor will be referred to as"Ciontractor". D, The Project Organization for CQA is shown,on Table 01000-1,CQA Organization Chart 1.04 CQA PLAN FORMAT A. This CI QA Plan closely parallels the format of the'rechnical Specifications in the contract documents. The intent of this paraflel fornuit is to avoid discrepancies between the two documents, therefore preventing misinterpretafluns and misunderstandings between, the Owner, Contractor, Design Engineer and CQA (,7erfifying Engineer. Tbis Ibrulat also organizes all iiecessaryqtja,lity,assut-atice verification procedures for eachunitof construction into a single section. B, Division I of this plan presents general information about the construction project and the CQA program. C Division 2 ofthis plan provides detailed and specific CQA procedures to be implemented by the CQA Officer for ea6h unitof construction. Dlivision2iswritteiiiiistitictiotiaii,ddireletio�n, for meniblers of the CQA Team. END OF CQA SECTION 01,0100 INTRODUCTION rur((X)A Man'�,.QA 010010 lnuoduc6on doe RW Omqum("mawdom CQA Plan PJ,M Exgineering Augum 20�5 01000 - 3 Page 3512 of 4165 LO 0 M LO M i� }1Lul _. w ww. cc CD 65 tu CD CL a C� v s C� rL 0 '110 wI m tLL ' 0 c m 0 as � 0 ;z m £ � , a Z CQA SECT[ON 010 10 SCOPE OF CONSTRUCTION PART I GENERAL 1.01 SE(_.'T10NSt..)'M_MAR,Y A. Work to be perl'ormed by the Design Enghwer B, or to be Performed by the Owner. C Contractor's scope of work, 1,02 WORK'ro BE PERFORM1,10 BYTHE',DESIGN ENGINEER A,. 'rhe Design Engineer will provide three (3) reference control points with benchniark elevations, in the vicinity of the Work site. All ather necessary control or refierence points, needed to perforin construction will be established by the Contractor. 1.03 WORK 'TO BE Pl.R17,ORMEJ') BY THE OWNER A The Owner will provide the following construction juaterials and services: 1. Material for engineered fill, 2. Material for the foundation layer, 3. Skid-niounted packaged combustion system, including totally-enclosed vertical ground flare. 4. ExterlSiOn of adequate over and telephone service to the location of the skid- mounted packaged combustion systern. I 1�04 (',O. N SC'1RAc'ro,R, S OPE OF WORK A, The Contractor's scope ol'work includes the f�,bllowing. I. Mobilization of construction equipment and personnel. 1 Excavation of on-site borrow material for construction of final cover systern soil components, as well as siediment,,itiori basin lnlprovements. 1 Construction of final cover system, including, interim cover preparation and placeinent/histallation of foundation layer, geomernbrane, engineered tUrf, hydrbinder, and sand ballast. 4, Seeding and fertilizing of disturbed areas and on-site bonr ow a�rea. 5 Excavation and construction of, and SLIPPly of rnaterials for, drainage and erosion control measures, 6, Construction of,and supply of materials for, aecess roads, 7'. Construction of,and supply of materials for,,leachate overflow collection and storage system, including installation of new leachate Us'r and lining of existing leachate sedinient charnber and wet well. 8, Construction of, and supply materials, for, L1,G collection and control system,, including installation of LJ-'G extraction wells, LFG collection system piping and condensate drainage components,. PWr,0X,,QA MID S,Qopc oFCors1ruv6on,doc FhO C'kmm Consuvon CQA Plan EPA 1vq"4ne'vft 011010 - 1 Aujpa(20 15 Page 3514 of 4165 9, Installation of0wrier-supplied skid-mounted packaged conibustion systmi,hiclding totally-enclosed vertical ground flare. I Oi, (,bristruction of,and supply otniaterials for, security fencing. END OF CQA SECTION 01010 SCOPE OF CONSTRUCTION PlankjCOA 01010 scqlc off"Onstruvuan do.C lirW Clmmm C%inxkmfiort(*A Mon 01010 - 2 Augum'2,015 Page 3515 of 4165 CQA SECTION 01039 PROJECT MEETINGS PALRT 1 GENERAL LO] SECTION SLTMMARY A. Communication and coordination between the Design Engineer,Contractor,,,urd CQA'Fcarn are most important to achieve the corninon goals of quality construction and Successful completion of the project. B. A series of' projecl 'meefings will be held for the purpose of establishing a successful environment ofcommunications, coordination, and overall tearnwork; the meetings will be administered b�y the CQA Officer to: 1) clearly define responsibility and authority ofeach organization involved in the prqject;2)msolve communication problerns,misunderstandings, and misfiiterj�retations; 3) Find 90kifi(YnS to unanticipated developtnents; and 4) identify,, prevent, and correct problerr-B and deficienicies that nmy occur during the construction process. C. Prqject mectings include the following. I Preconstruction meeting. 2, Progress meetings. 3. preparatory meetings. L02 PR.I..ICONST'Rljc,rlC)N MEEIING k A preconstruction meeting will be held to,discuss topics relating to the commencement of the project. B. 'The obJectives of this,meleting are to: 1)clearly define the roles,responsibility,and authority ofeach organization and individual involved in theproject;2)review specific requirein.ents of the CC" program; and 3) establish a foundationi of cooperation to achieve quality coillstruction, 'I"'he following agenda, as related to CO'A, will be addressed the Design Engineer: I Introduce and discuss rol,es,authority,and responsibilities of each organization and individual involved in tfie project. 2, Establisli lines of communication. 1 Review'reehnical Specifications and Plans. 4. Distribution oftbe CQ,A Hall 5� Review of C. activities to be performed, 61, Discuss Contractor's construction schedule and workplan. 7. Discuss Contractor's Constniction Quality (011IT01 (CQC) procedures and responsibilities. 8, Discuss submitial review and approval procedur(;S. 9 Discuss non-conformance and corrective action procedures. M Discuss construction restrictions due to weather conditions. I I Discuss and schedule weekly progress meetings. 12, Discuss health and safety issues. 11 Discuss preparatory meetings. 7urrCQA T"Tan'CQA W 039 Prqjca M=higqAv Fund ClAnum Cavglruduori U.,M Plan EBA Eng netdng, Atqjxt 2015 011039, - 1 Page 3516 of 4165 C; A Meeting(Discussion Surninary Rep,ort(see Part 1.08 of Section 01400 of this CQA Plan) will be completed by the CQA Officer and distribLited to all parties in attendance, D, The following representatives firom each organization are required to attend the preconstruction ineeting: 1. City's ProJect Manager or representative, 2. Contractor's Pro'ject Manager and on-site Superintendent. 3, Installer's Project Manager and on-site Superintendent. 4, Design Engineer's Project Manager and CSC A Cw, fficer. 1,03 PROGRESS NIETTINGS A. The CQ,A Officer will schedule and administer weekly pro gress meetnigsThe objectivesof` these meetings are to: 1)maintain lines of corm-nunication;2)review work,progress,and CQA activities performed Previously;3)discuss upcorning consiTuction and related CQA activities; and 4) maintain arad improve the established foundation of cooperation to achieve duality constriction. The following agenda will be addressed by the CQA Officer, 1,. Review minutes,of previous progress meeting, 1 Review work-progress. I Revi ew a,nd update con struction scheidule and obtain a 2-weeklook-al'icad selieldu le from the Contractor. 4 f iscuss CQ and CC", C related Field observations, testing results, problems, decisions, and conflicts, 5�. Review and update Submiffal Log. B. A Meeting/Discassion Surmnary Report (see Section 01400 of" this CQA Plan) will be cornpleted by the CSC A Officer and distributed to all Parties in attendance, The following representatives from each organization are required to attend the weekly progress ineetings. I City's Project Manager or representative. 2. Contractor's on-site Superintendent. 3,. Installers on-site Superintendent(during geosynthetics installation), 4. Design Engineer's Project Manager and CQA Officer. 1,04 PREPAR.KrORYMEETINGS, k The CQA Officer will schedule and adtninister informal preparatory meetings pfior to beginning c(.)�ristniction/iinplemelitatioii of the following items. 1. Refuse excavation and interim cover preparation. 1 Foundation layer placement. I Geomembnane Placement. 4" Turf installation. .5� Sand ballast placement, General earthwork, drainage and, erosion control, and access road construction, as needed. T Sedimentation basin improvernents. 8. Leachate overflow collection and storage system irlstallation, 9" LFG collection system installation. 10 Borrow area reclaination. H. Seeding and fertilizing, CQA Ma'C(JA 0039 Prq*R Meairkss,doc Hrwd 00SWO Cx,mtriwflon CQA,Man EBA Eagumering Auguo 20 15 0103,9 - 2 Page 3517 of 4165 & flie objective of these preparatory meetings is t�o establish a complete understanding of the upeorning unit of construction and CQA activities that will be, implernented cluting construction. 'Fo achieve this,ohjective,the following agenda will be addressed b,ythe CQA Officer. L Review"Products"pant of the applicable section of the'rechnical Specifications, I Review"Execution"part of the applicable section,oft he 1'eichnical Specifications. 3. Discuss any construction and grade control stakiiig needed to perfiorm arnd complete the Work. 4, Discuss CQ testing, observation, and stin,eying to be perfornied. 5 Verity that all submittals have blecn, or will be, received by the CQA Officer and approved by the Design EngiMer in accor(lance with glue schedtfle, 6 Discuss,Contractor's CQC responsibilities. T Discuss Contractor's coordination, scheduling, and sequencing of the work,. K Discuss Contractor's proposed equipment and inanplower. C. A Meefing/Diicussion Surninary Report (see Section 01400 of this CQA Plan), will be completed by the CQ,A Oflicer and distributed to all parties,in attendance, D. 'I'he following representatives froin each organization are required to attend the preparatory meetings. I, Design Engineer's Project Manager or representative. 2. Contractor's on-site Superintelident. I On-site Superintendent of any Subcontractor, as, applicable to the unit of constmction. 4. CQA Officer. 5 CQA Monitor(s),as applicable to the unit of construction, END OF CQA SECTION 01039 PROJECT MEETINGS LArmajecOOTClosum TarfCOA P1uWCQA 01039 Pmjecl:MectinpAx Flmd(Inum Cims9ruaim CQA Plan FBA Enpnaefing, Augus�20 H 01039 - 3 Page 3518 of 4165 CQA SECTION 01050 GENEIIAL REQUIREMENTS PART ]. GENERAL 1,01 Sl-,�VTIONSLTMMARY A. C",onforritance testing. B, Construction monitoring. C. Construction testing. D, Project meetings. E. Subrnittal review and approval. K Documentation. 1.02 "ON FORMANCEITSTING A. Prior to using a product or niatierial in constniction, sampling and testing will be peribrrned to, veril that construction products and materials to; be used are in contbrTTIWIGO', with the Technical Specifications. R Conformance testing reqUirernents,methods,and sampling frequencies are given foTeach Linit of construction in Division 2 of this CQA P'lan. All product arid,mi',iterial conformance test safriples ww illll be recorded on the appropriate Master Testing Clantrol Log,assigned a simiple nUmber,and processed by the(..'Q,A Officer for either on-sate or off-sate testing, T'he Master"Festing Control Logs document: 1)sarnple nunibers,2) product or rnaterW types; 3) required testing; 4) sampling locations and dates; 5) testing personnel,or organization;6),testing coinpletion dates;and 7')a briel"surnmary of the!testing results. The Master Testing Control L,og for soils are presented in Appendix C. D, At the request athe Design Engineer,conforniance test samples will be archivedat the:Work site or an alternate location determined by the Owner for a period of one year. Archived sainples will be stored in, sealed plastic containers tagged with: 1) the sample number; 2) prodUCt Or material type;3)the project name and number 4)sample date and location;and 5) the date for discarding the sai�npte. E, The following,products oi-materials require confonnance testing, I, Miscellaneous aggregate materials. I Engineered fill. I Foundation soil layer, 4. Geornernbrane, 5. Engineered tUrf. 6, Erosian-resistant layer. 7, Concrete. U'qwojevN)0TCbsure or I` NeCQA 010,50(knerat kvTjWgvn=aA doe FlnvO Cos=ConWruc4on CQA Man EBA Engrnevipvg As guse 2015 fp 1050 - I Page 3519 of 4165 1.03 CONSTRUCTION MONITORLNG A Each urfit of construction 'will e mon,itored to verify comphance with the Teclinical Specifications and th�at construction was executed COITCCtly using indastry-standalrd construction methods and the proper materials. 13, Monitoring guidelines and procedures are specified for each construction unit in Division 2 of this CQA Plan and include the following, I. Field tests. 2. Observations. 1 Field surveys, 4. by measurements, 1,04 `:;1NSI"1 I1 ,"IOf T'ESI"'ING A, (',,onstruction testing will be performed during installation and construction to vefif� compliance with the Technical.Specifications. & Construction testing may be perfibmied by the Contractor, I)esign Engineer, or CQA personnel as.required for eacli construction anit in Division 2 of this CQA Nan and iricludes the following: L Engineered fill, 2, Foundation layer. 1 AggTegate base for arecess roads. 4. Geomernbrane, 5 Engineered turf'. 6, and ballast, L05 PROJECT MEET]NGS A, In accordance with Section 01039 of t1iis CQA Plan. 1.06 SUBMITTAL REVIEW AND APPROVAL A, In accordan ce w i.th Section 0 13 00 of this(.,fir Plan, 1.07 DOCUMENTATION A. In accordance with Section 01400 of'this CQA 11 Ian, END OF C1QA SECTION 01050 GENER/ALL REQUIREMENTS I jrrC`QA MWO)A 9',7 050(kmml qikucrrmmL&dcc FuW Cli mane,CormiTuman CQA Mn ATA 6nginerdng A upev 20 5 01050 - 2 Page 3520 of 4165 CQA SECTION 01090 REFERENCES PARIA GENERAL 1.011 SECTIONSUMMARY A. Project Reference Docurrients, R Industry Standards and,'Fechnical Refierence Documents, Soils'resting Standards and Methods. Geosynthetics,res(ing Standards,and Methods. E. Landfill Gas Collection, System Testing Standards and Methods. J"'. Concrete Testing Standards and Methods. G. Acronyms. 1-1, Contact Addresses and'I'elephone Numbers, 1.02 PROJECT REFEREN("T DOCUMENTS A, The following project reference documents provide support arid background information for use in conjunction witli this CQA Plan, I Joint Technical Documentjbr City qftlkiah Landfill,Mendocino(..ounty, EBA F'.ngincering, January 2008. 2. RavPonse to RWQCB CopmnenLv Dated February 21, 2008, Joint Technical Document, City ql' Ukiah Landjifl, Mench.xino County, Cal lbrnia; EBA 141"tigineering, April 21,2008�. 3. Janua?y 20108 Joint Teehnical Docwntent Addendum, Response to Regmlalory Comments, Final Closwm and Pamdovure Maintenance Plans, City qf Ukiah Laneffill, l ndocino County, Calclbrnial' EB,A Engineering, June 20', 2013, 4. Design,Plan for Landjill Gas Collec:fion and Corarol, yslem, C"i't y qf Ukiah Lan, Mendocino (,oun y, Ca ldlbrnia; EBA Engineering, October 2013. 1,03 INDUSTRY STANDARDS ANI)TEUINICAL REFERENCE DOCUMENTS A The 6ollowing industry standardi and technical reference docurnents were used 61 the preparation of this CQA plan, L AST Alf Standards and Other Spee4katirons awd Test Alfethod.v o,n the Quality Assurance Anierican Society for Testing and Materials, Current Edition. I Technical Gruidance Document, Quality As�surance and Quality(7ontrolfir Waste Containment Facilities [EI),41600IR-9311821. United States I`nvironrnerital Protection Agency, Septernber 1993, I Federal Regis'-ter (V(d' 50, ales. 190, pli. 50978 - 511-19). Part 11, En vironmental 11rotection Agency, 40 CFR Parts 257 and 258 - Solid Wiwe Di.yosalFacifity PWACQA W000 RefennomAn MW Closwo Commulion COA Plan ESA EngMeerft AugwU 20�5 01,090 - 1 Page 3521 of 4165 C`riterhy,- Final Rule j'EP/I/0STY-I",'R-91-004 FRL-40119,1 United Suates Environniental Protection Agency, October 9, 1991. 4. Cali mi i(7ode(#Regpilations, Title,27-CombipmecISWRCI11IC7W IBR,,�A/ qpdations Dhiisior�� 2, SubdNision 1, Chapter 3', Sullchap'er 2, Article 4, Section 203'24 Effective July 18, 1997, 5. California Departmen t of Transportation, 2010, & (,"alfrans,51,andaml Plans, Califon'iia Department of'Fransportation, 20 1,0, 7, Calybrnia Test Alefhodv. Cal�lbrnia Department qf Tran.sportation, Cument Edition. ff CalVbo-nia Building Co(le. (7urrent Editiom 1,,04 SOILS "I"E'S"I"ING1 S"I"AN DA RDS AND METI IODS A. "rhe following standard soils testing methods and procedures apply as referenced in the Technical Specificatioris and/or this CQA Plan, 1.. ASTM C 33 Standard Specification for Concrete Aggregates. 2, ASTM C 136 Sieve Analysis of Fine and Cloarse Aggregates. 3. AS'FM D 422 Standard"Fest,Method for Particle-Size Analysis of Soils. 4. ASTM D 1557 Test Method for Laboratory Compaction Characteri sties of Soil I-Tsing, Modified Effort ( 6,000 ftAbf/fl,' [2,700 kN- m/in 3p 5 ASTM D 2434 Standard Test Method fiir Permeability of'Granular Soils (Constant Head). 6. ASTM 1) 2487 Standard Classification of'Soils for Engineering Purposes (Unified Soil Classification System). 7, ASTM D 248,8 Standard Practice for Desciiptiorn arid Identification of Soils (Visual-Manual Procediire). K ASTM 1)2922 Standard Test Methods for Density of Soil and Soil- Aggregate in Place by Nuclea�r Methods(Shallow Deptli). 9. ASTM D 3017 Standard Test Method for Water Content of Soil and Rock in Place by Nuclear Methods(Shallow Depth). 10. ASI'M D,4959 Standard Test Method for Deternilination of Water (moisture),Content of hail by Direct Hewing, IL C]I M 229 Method of Test for Durability fndex. 11 CTM30 l Method for Deterriiiiiing the Resistance "R" Value ocf Treated and Untreated, Bases, Subbases, and Basetnent Soils by the Stabilometer. 1,05 GEOSNYTHETICS TES TING STAN DARDS AND METHODS A The fiollowing standard geosyntlietics testing methods and procedures apply as refierenced irl theTechnical Specifications and/or th is CQA Plan. 1, ASTM 1) 1505 Test Method for Density of Plastics by the Density- Gradient Technique. 2, A STM D 4218 Test Method for Carbon Black Content. I As'rM D 43 Test Method for Deterioration of Geotextiles from Exposure to IfItraviolet Lj&ft and Water. 4, ASTM 1)4491 Test Methods for Water Permeability of Gieotextiles by Perinittivily, 5 ASTM 1)4533 Test Method for,rrapezoid Tearing Strength of Geotextiles, 6. ASTM D 4632 'Test Method for Breakfiig Lo�ad a�nd Elongation of Geotextiles((Train Method)�. 7, ASTM 11 4633 Standard Test Method for Energy Measurement for Pkm'CQA QW4 Rdmences-dov RAW Omme ConMruuflori CQA Plan r0A A*qqacerft 01090 - 2 .Aug um:20�5 Page 3522 of 4165 Dynamic Penctrorricters. 8, AS TM 1)4716 Standard Test Method for Constant Head Hydraulic Transmissivity (N-Plane Flow) of Geotcxtiles and Geotextfle Related Products. 9, ASIM 1)4751, Test Method for Determining the Apparent Opening Size of a(31,cotextile. 10 ASTM D 4759 Standard Practice for Determining the Specification Conflormance of'Goosynthefics. IL AS TM D 4833 Test Method for Index Puncture Resistance of Geotextiles, Geornembranes,and Related Products,. 11 AS TM D 5035 Standard Test,Method for Breaking Force and Elongation of Texti 1e Fabrics(Strip Method). 13. AST'm'D 5199 Suandard. Test Method for Measuring the Nominal "I"hick-riess of Geosyntheties. 14, AS"'I'M 1) 5261 Test Methc)ds flcrr Mass Per Unit Area (weight)of Woven Fabrics. 15. A M D 5321 Standard rest Method for Determining the C..oefficient of Soil and Cieosyntbefic or Geosynthelic Fricticla by the Direct Shear WOW, 1, 010 LANDFILL Cj'A'S EXTRACTION SYSTEMTES'"I"ING STANDARDS AND METHODS A The following standard geosynthetics testing methods and proceidurcs apply as referenced ill the'rechnical Spec ifi cations and/or this CQA Plan. 1, AS]"M A 1913 Standard Specification for Alloy Steel and Stainless,Steel Bolting Miter'Ws for High Temperature Service. I ASTM A 325 Standard Spec i fication, f*(.)r Structural Bolts, Steel, Heat Treated, 120/105 KSI Minimurn'Tensile Strengit I ASTM 1) 1784 Standard Specification for Rigid PVC (',ompounds and Chlorinated PVC Compounds, 4, ASTM D 1785 Standard Specification For PVC Plastiellipe,Schedules 40, 80, and 120. 5. As'rm D 2404 Standard Specification for Threaded PVC Plastic Pipe Fittings, Schedule 80. 6. ASTM D 2466 Standard Specification l'or Threaded PVC Plastic Pipe Fittings, Schedule 40 T ASTM D 2467 Standard, Specification for Socket-Type PVC Plastic Pipe Fittings, Schedule 80. 8, AS TM D 2513 Standard Specification f6r Thlermoplastic Gas Pressure I'lipe,I'Libing, and Fittings. 9, ASTM 1) 2504. Stimulard, Spec i fication for Solvent Cernerits for PVC Plastic Piping Systerns, 10 As'rm,I 28 5 Standard Specification for Making Solvent-Cen.iented Joints with PVC Piple and Fittings, H. ASTM D 3034 Standard Specification for Type PS M Poly (Vinyl Chloride) (PVC)l Sewer Pipe an(] Fitfings. 11 ASTM D 3212 Standard Specification for Unts for Drain and Sewer Plastic Pipes,Using Flexible Etastomeric Seats, 13, AS"I'm D 3261 Standard Specification for Butt Heat Fusion Polyethylene (PE")Plastic]",ittirigs for Polyethylene(PE)Plastic Pipe and T'ubin& 14. ASTM 1) 3350 Standard Specification, for- Polyethylene Plastic Pipe and urfCQA PlanCQA 01090 P.Hurmcmdoc Fllu CIA)$=Cinminivi6on(,,,()A Pbll Augol 2013 Olt 090 - 3 Page 3523 of 4165 Fittings Materials, 15, ASTM D 378,6 Standard Test Melliod for Methoxyl iand Hydros yliropyl Substitution in Cellulose Ether Products by Gas Chromatography. 16, ASTM D 7001 Suindard Specification for Geocomposites for Pavement Edge Drains and Other filth-Flow Applicatiorm 17', ASTM F 477 Stmi(lud Specification,for Elastomeric Seals(Gaskets),for Joining Plastic Pipe. t& AS"I'M 172648 Standard Specification for 2 to 60 inch [50to 1500 niml Annu lar Comigated Piple Wall Polyethylene(P'E)Pipe and Fittings for Land Drainage Applications,. 1,07 CON(.RETE TESTING STANDARDS AND METHODS A 'Tbe following standard concrete testing methods and procedures apply as referenced in the 'rechnical Specifications andJor this CQA Plan, L AS TM C, 39, Standard Test Method fbr Compressive Strength of (','yUnd,deal Concrete Specimells. 2, ASTM C 42 Suandard Test Method fur Obtaining and 1'esting [)rffled Cores and Saweld Bearns of Concrete. 3. ASI'M C 143 Staridard 1"'est Method for Slump of PotiJand Cement Concrete. 4. AS TM C 150 Standard Specification l'or Portland Cement. 5. A SIM C'260 Standard Specillcation for Air-Entraining Admixtures for Concrete. & C'BC Section 17'01 1 Structural Tests and Special Inspections. 7. CBC Section 19015 Concrete Quality, Mixing and Placing. 1 08 SIEEL TESTING SIANDARDS AND METIJODS A. The following stmdard steel testing miethods, and procedures apply as, referenced in these Technical Specifications and/or the CQA Plan. I, ASI.'M A 36 Standard Specification for Carbon Structural Steel, I ASTM A 9�O 'Test Method for Weight (Mass) of`Coating on Ironand Steel rticics with Zinc or Zinc-Alloy Coating. 3. ASTM A 185 Standard Specifications for Steel Welded Wire Rein forceinent,Plain, for Concrete. 4, ASTM A 213 Spec i ficati on for ChrorniUln--Nickel Stainless and Heat- Resisting Steel Spiring'Wire. 5. AS TM A 3701-9�7a Test Methods and Definitions for MelchanicalTesting of Steel Products. 6, ASTM A 615 Standard Specification for Dekurrned and Plain Carbon- Steel Bars ror Concrete Refiiforcement. T AST A 641 Specification for Zinc Coated (Galvanized) Clarbon Steel Wire. 8. ASI'M A 764 Spec i fication for Steel Wire, Carbon, Drawn Galvanized "arid Galvanized at Size for Mechanical Springs. 9, ASTM A 97'5-97 Standard Specification for Double-'rwistcA flex a',Igona 11 Mesta Ga�bions and Revet Mattresses(Metallic-Coated Steel Wire, or Metallic-Coated Steel 'Wire: with Polyvinyl Chloride(PVQ Coatinig). Turf CQA PLui,CQA 01090 Ref6rmcrs,doc Frna(Imic Commiclian CQA N= EN Ragimering Aug um 2 0 h 5 011.090 - 4 Page 3524 of 4165 1,09 ACRONYMS A. 'Whenever the following acronyms for standards,institutes and societies are referenced in the Technical Specifications or this CQA Plan,the following ineanings apply: 1. AASH170 Anierican Association of State Higbway and Transportation Officials 2. AI SC Arnerican Insdrute of Steel Construction 3. ANSI Anierican National Standards Institute 4. ASTM American society for,resting and Materials 5, AWWA Arne dean Water Work's Association 6, CA('' na A Califo 'iidi-ninistrative Code 7 CFR Code of Federal Regtdations 8, CRSI Concrete Reinforcing steel Institute 9, CTM C,alffbtinaTest Metho<ds I 101. N EMA National Electrical NIdni u facturer's Association IL NE'C National Electric(.ode 12. NFPA National Fire Protection Association i 3, GSi-m Occupational Health,and Safety Administrwion 14� RW'QCB Regional Water Qual it Control Board 15. SWA NA Solid Waste Association of Nortli America, 16. SWRCB State Water Resources Control Board 17, [I'll Underwriters 1-aboratories Inc. I& LJS United States B. Whenever the following acronyms for inaterials and units are refierenced in the 'rechnicaq Specifications or this CQ�A Plan,the ft,)llowing rneanings apply� 1:„ AC acre 2. ,DWG Arnerican Wire Gaul 3. CM centirneter 4. CMP corrugated metal pipe 5. EPD � ethylene propylene diene nionorner 6. OF degree Fahrenheit 7. ft foot, 9 grarn ,9�. 11IM"T f I igh Density Polyethylene M H P horse power 1,1. hi incli 12, inch 13. k,,N kilonewtons 14, lb poulld 15. MAR.V minimum average roll value 1. . 111 meter IT nlru millimeter 18, nril I./1000 of I inch 0. ml milliliters, X Min minUte 21, No, number 22. oz ounce L.peer,�ccf,907'tCknum TarRQA T%n'CQA 0 r 090 XekwnvcsAxr F nM(30sum,ConsilucAkol CiQA PNJI TBA AupAl 2015 01090 - 5 Page 3525 of 4165 21 % percent 24. Psi" pounds per square foot 25, psi pounds,per square inch 26. Psig pounds PeTsquare inch gatige 27, PVC Polyvinyl Chloride 28, DR Standard Dinwrision Ratio 29. We Second 3O' TFE tetrafluoroethylene 3L TRM turf reinfiarcement niat 32. yd yard C. Whenever the following iniscellancous acronyrns are referenced in the Technical Specifications or this(,QA Plan, the following ineanings apply" I AST Above Ground StorageTank I @ at I BMII Best Managernent Practice 4, CQA Clonstruction Quality Assurance 5. CQ('w: Consti-uction Quality(,ontrol 6. (ISMIP Construction Storm Water Management Plan 7', EB BA Engineering 8, equals 9. GC L Geosynthetic Clay Liner I(),. GRL Gas ReliefLayer l 1. LFG Laridfifll Gas 12, max, maximLIM 'I I mim rninhnurn 14, MQC Manufacturer's Quality Control t 5, MSDS Material Data Safety Sheet 16 NO(] Notice of tntent IT NPDES National Pollutant Discharge Efinlination, System 18, PDF Portable Docurnent Format 19. POC Point of Connection 20 QSD Qualified SWIIIIIP Developer 2L QSf) Qualified SWPPP Practitioner 22, REAP Rain Event Action Plan 23. SAP Sloan Water Action Plan 24, SMARTS Storrn Water Multiple Application and Report Tracking,Systeryl 25, SPC Storni Water Pollution Control 2& Std. Standard, 27. STD PIP StorTn Water Pollution Prevention Pla'n 28, TEFC Totally Enclosed Fan Cooled 29. UST Underground Storage Tank 30. UV Ultra-violet 31. WDID Waste Discharge klenti.fication 32, VI/PC Water PoIlLition Control E,'VproJe4.09D7W'3x3o,ure I urf('jQA Plan,CQA OW90 Rckmums.60C Fmml Cbsure(Amoniclion Ca;�A Man L'BA Engineoving August 2015 01090 - 6 Page 3526 of 4165 IJO CON"I'AC'I'.AI)D f,"SAN'l)'['El.,EIIHONEN'[J'MBIERS A, The following are addresses,telephone nuinbcrs,and fax numbars lbr individual contacts at each organization involved in the ppqjcct,, City of tJki,,,ih Departnient Of P'LlbliC or 300 Seminary Avenue Ukiah, CA 95482 l7eljcpllolle� ('707) 463-6282 Fax: ('707)463-0204 EBA Engineering 825 Sonoma Avenue Santa Rosa, CA 954104 Contact Naine arnon F. Brown, P.G., C.E,G, CJ4g, 'relephone: (707) 544-01784 Fax: (707) 544-0866 END OF CQA SEC710N 0 1090 REFYRENCES TurfCQ)k Plm(-,QA W090 Rd.rmcci4,,d,)v, FuW Man J."nvineering August'2'Wli 011090 - 7 Page 3527 of 4165 CQA SECTION 01300 SUBMI,rTALS PART I GENERAJ, L0 l SEC140N SUMMARY A. Submittal Control Log. B, Submittal review and approval procedures, 1.02 SUBM11"I'ALCONTROLLOG A 'I"he SUbinittal Control Log lists all submittals required by the'rechnical Specifications, 7'he Submittal Control Log will be maintained by the CQA Officer in coordination witl'i the Contractor during,construction, 'rhe Sijbinittal Control Log documerim J)subnifttal number; 2)referenced specification section;3)subnaidal description;4)Kibmitter;5)date received;6') reviewer; 7)action taken determination; and 8)retum date. 1,03 SUBMIT'rAl, RIMEM AND APPROVAL PROCEDURES A. I'llree(3)copies of each submittal listed in the Submittal Control Log will be submitted to Ole CQA Ofticer by the Contractor in, accordance w[llh, the 'I'echnical Specifi-leations. 'I'lle submittals will be fbrwarded by the CQA Officer to the Design lingineer for review and approval. 'T'he l3esign Engineer rnay peiform a preliminaty review of submittals fbr comp I iance,with tlie'l'echnica l Specifications ind issue a verbal 41.,4provaj bi:( e to the CQ A Officer who, in ti.im,will notff the Contractor that no corrective action determinations were required prior to issuing a verbal App iL All subinittals which are not in compliance with the"rechnical Specifications must be inin'iediately forwarded to the Design! Engineer for review arid corrective action determinations. 11 At the compleflori oftbe review process,the Design Engineer will retuin two (2)copies of each submitta I to the CQ A Officer with Action Kok-(,eradetern�niti.ationsstan! alonboth copies of`the submittal, The Action, Taken detenminations and the return dates willbe recorded on the Subinittal C'ontrol Log. Onc copy of the reviewed subimittal will be returned to the Contractor and the other copy will be archived by the CQA Officer in the submittal docurnentation control binder. C. 'Flic Submittal Control Log will be reviewed arid,Updated in coordination with the Contractor at,the weeMy progress rneeting& END OAF CQA SEcriON 0130O SUBAUrTALS hul CQA KLmA,QA 01300 Finmv China,Cormlruc4on CX)A Mn EWA FaPineving A upas 2015 0 1 300 - I Page 3528 of 4165 CQA six,riON 014001 DOU"WENTASON PAIII' l C"ENERAL 1,10 l SECTION SUMMARY A, f aily Sumrnary Report, B Wfly Field Log(Inspection Data Sheet),. ("Onstruction monitoring Forms. D Uiboratory testing reports. E, Non-eonfortnance/Corrective Action Form, F. Acceptance Report. G, Meefing/Discussion Sununary Repom, 11. Photograph Log. 1. Document C,ontrol, J. As-built Relcor(I [Xicurnents. K CQA Certification Report. L Documentation archive storage. 1 012, DAILY'SUM"MARY REPORT A, A summmy rep or will be prcpaxed dafly by the CQA Officer. This repon will organize and surnmarize arll construction and CQA activities (nionitorhag and testing), coniplefed during eacb day. The Daily Suimiaary Report will contain or retorence tbe Following information: I Title block cmitaining: 1)project name; 2) prQject number- 3)project location;4) name cap"Owner; 5) naine of Contractor; 6) diate and (lay; 7) Document ContM Number(see Part I.10 of this Section); and 8)weatber conditioi'ls. I Surnmary of construction activities for each unit of construction including equipment, personnel,and subcontractors utilized for each unit of constrUction and identification of the general area(s)where construction look place. I General SUniniary of CQA activities(nionitoruig and testing)completed for each unit of construction with reference to attached Daily Field Logs (see Part 1.03 of this Section) which describe construction rrionitoring, construction testing resents, an(] quality control procedures and test,results. 4. General description of any mm-conforimance with the Plans or 'rechnical Specit"ications, and the corrective action nica,sureg taken with reference to attached Noi:i-cor-iforinance,�(.orrective Action Folms (see Part 1.06 of this Section) which contain a more detailed description of the non-conformance issue and its corrective I;',projec6907'0o&wc Turf CQA MaMCQA 01400 Documentallan,doc NoM 00SUIC Omwnctian CQA I'lan 1,'RA rngmewring 4upwIM 014010- 1, Page 3529 of 4165 action, 5. List of an inaterials received.and status o,f submittal(s), 6, List of project meetings or pertinelit discussions with relor nce to attached Meeting/Discussion Sunirnary Report(see Part 1.08 ofthis Section), 7 Other rniscellaneous information. & Si&plature of CQA Officer. & A saniple Daily Summary Report is included in Appendix A,project Documentation Forms, 1,(1 DAII,Y FIE1.1") I-OG (INSIIIECTIONDATA SlIEET) a Each CQA Monitor will maintain an indiviciLlal Daily Field Log(or Inspection Data Sheet) which will be assigned a cross-referencing Document Control Namber(see Part 1.101 of this Section)and contain daily entries ofthe CQ,A Monitor., & On the Daily Field Log,, the CQA Mornilors will provide as written account of construction activities, coristruction monitoring, construction testing, and quality control procedures performed during the day for the monitor construction unit(s),as well as,any observations (i.e., notes, charts, sketches, or pbotogralAl reference). Cl. Clonstruction monitoring (brms (see Part 1.04 of this Section) and laboratory testing forrns (see Part 1.05 of this Section)will be attaclied to, or referenced in, the Daily Field. Lo& 1,04 CONSTRUCTION MONITORINCi FORMS A. Constnictionactivities,construction rnonitoring,and construction testing will be recorded on appropriate construction monitoring forins, The'lollowing construction monitoring forrils,or shnilar forfris, willbe issued by the C,QA Officer for this pro'l.ect and are presented in tile foHowing appendices: I Soils, Monitoring Forms(Appendix 13) a. Soils"Test Request- Sample Custodyl.,og b luclear Density/moisture"lest Data I Gcosyndletics Monitoring f'orins(Appendix Q a. Geomernbrane Deli'veryand Control Log b. Fngineered'Furf Delivery and Control Log C. Geomembrane"fest Request -,Sarnple Custc)dy 1-09 d, Engineered'FurfTest leakiest— Sample Custody Log e. Geornembrane Deploynaent/Seaming Log f. Geornenabrane Repair Log & 1-:1ngineered Turt'Dej)loyn!iejit/Scaiilirig Lot h. Engneered Turf Repair I..A)g 13, Completed construction monitoring forms will be submitted by the CQA Monitorto the C"QA Officer for review with Daily l°ield Logs, or at the! completion of testing,, and will be addre�ssed by the C(,-)A Officer in Ille Daily Summary Repoils. 1.05 LABORATORY TESTING REPORTS A, I.aboratory testing reports will be issued by the Soils and Geosyntheties CQA Testing, I 1,,aboratories for conforalance and construction testing. Laboratory to reports will be issued for the following testing during the project. t, Moisture content,particle size,analysis,Atterberg limits,'Unified Soil Classification, I urfCQA Ku,CQ A W400 Docuaremation doe Fma�GmAre Construclion COAT'lan EBA EOVIdneeritig 4ups?,2015 01400 -2 Page 3530 of 4165 and/or moisture-donsity relationship testing 1br miscellaneous aggregale ater I in ia s g engincered fill, %Undation layer, and erosion-resistant layer materials. 1 Particle size analysis for sand ballast. 3. Conformance testing for geoniembrane. 4. C.,onforrnance testing, f6r engineered turf. 5, Con forniance testing for con crete, B Laboratory testing reports will be addressed by The CQA Officer in the Daily Summary Report on the date of'receipt. 1 1.06 Nt N-CON'F( R,MANCE/(,OR,RECIl'I'N E ACHON FORM A. A Non-coriforiv.i,-i.tice/(.,'oj-rective,Action Fomi will be issued by tlie Owner to the CQA OffiCCT 'Who will notify the Contractor or Installer of construction or materials not in compliance with the Plans or Technical Specifications, or for def'ective workmanship or materials even ff int cornpliance with the Plans and Technical Specifications. The Noii-coi�ifcarilianrce/(,oli-rect�ive Action Form will contain or reference the following infonnation: 1. Title block containing: 1) project name; 2) project number; 3) project location; 4) nanic of Owner; 5)narne of Contractor; 6),date,and day;and 7) Docarnent Control Number(see Part L 10 of this Section). 2. Description ofthe non-confonnance issue,construction unit,and location. 3. Reference to the tcchnical specification(s) and/or plan(s) for which triatedals or construction are not ili compliance. 4. Description of corrective action measures necessary to fully correct the area of non- conformance witb the blares andJor,rechnical Specifications as determined by the Owner, 5, Specification,variance or revisions to the As-built Record Drawings(see Part 1,11 of this Section)required. 6. If necessary,any'Daily Field Log,construction monitoring fomis, laboratory testing report ),Meeting/Discussion Stummmy Report,or Pbotqgraph Log penaining to,the non-comformance issue will be referenced by Document Control or Photograph Nurnber to fully substantiate the non-cortformance issue and coirrective action detemination. T Signature of the CQ Officer verify g that corrective rricasures determined by the Owner have been taken by the Contractor or Installer. & A samp�le N'oii-confb�i-i�iiance/CoTT,'ective Action Forin is included in Appendix A, Project Documentation Fonns. 1.07 ACCEPTANCE REPORT A as Acceptance Report will be prepared,for each Construction Unit to verify that all materiak, and constriiction are in compliance with the Plans and Technical Specifications. The Accelptance Repoil will reference all relevant Daily Surnmary Reports, Daily Field I..,()gs (Inspcetion Data Sliects),and Non-canformance/Corrective Action Forms by the Document Control Number. B, A sample:Acceptance Report is included in Appendix A, ProJect Documentation Fornis, TuO'C'QA Man"CQA WOO der NmMoqmv Constructon CQA 111Hn IA- A Engfneeyhv� Auger 20 5 O�14001 - 3 Page 3531 of 4165 1.08 MEETINGJASCU SS ION S UMMARY REPO R.T A, A Meeting/Discussion Surrilmary Report will be prepared foreacli scheduled ProjectMeeting (see Section 01 1039 of this CQA,VJaji)arid any pertinent discussion between tile Contractor and CQA personnel. The Meeting/Discussion SUITIrnaly Report will contain the following infinn'tation: I. Title block containing 1) prqject name; 2) Prqject nUrnber; 3) prtk�ect location; 4) naine o FOwner.- 5)narne of Contractor;6)datc and time;7)rneeting location;,ind 8), Docu ment Control Number(see Part p,10 of this Section), 2, Meeting narne or general discussion, sull.)Ject nlatleT. 3. List of meeting attendees or discussio,n pailicipailts. 4. Minutes of scheduled ProJect Meetings or synopsis of diiSCUSSi011, 5, List of any it erns,needing resolution resulting from the meeting or discussion. 6. Signature of CQA Officer. M A sample Meeting/DiSCUSSiOD S1,1111111ary Repon is included in Apperidix A, ProJect Documentation Fon-as, w Ptio'l-OG'KAPH LOG & All constructic)n activities, will be continually photog,,raphed to clearly show and define construction aiethods,and as-built conditions of completed units of construction, Photographs wHI include: 1)product or material s,ources;2)constrUction inethods in progress,for each unit of construction; 3) completed Units of construction; 4) daniaged, reJected, or substandard materials and construction; 5) corrective action, measures to rectify darrhiged, ruajected, or substandard construction;6)cornplieted units of construction after completion of corrective action ineasures; and 7) desig�n iniodifications. Photographs will be identified by nurnber, date, and time of the photograph, The (,,QA Of will rnaintain a cross-referencing photography log docuinenting the subi niatter of each photograph. B. A sample Pliotogriph Log is included in Appendix A, Project Documentation Forms, 1,10 DOCUMINT C'ONTROL A. A unique Docurnent Control Number will be assigned t�o all CQA documents generated during construction and irnpienienlation,of this CQA Plan. B. 'I"be Docunlent Control Number will organize and index all C documentation for Cross- referencing, to allow i access to all docrinlents, and to enable a reviewer to identify and retrieve original CQA docurnentation for any completed unit of construction. C Complete doc-unientation of all CQA activities will be conlyolled and secured in a series of 3- nrig binders niaintained I')y the CQA Officer with a duplicate copy maintained at the offices of the Ovvner, at the option of the Owner. This docurnentation coil tro l stricture organizes and indexes all CQA docurnents and is intended to allow casyaccess to all documents fbirreview and audit by the Owner, Design Lingii'icler, or regulatory agencies, The following is a preliminary li ut and contents of the C(,,),,4 Documentation Binder's to be established and niainita hied by the CQA Officer. 1, Title: L)WI, and Field dogs. Color code (optional)-, Blue. C',ontents: Daily Surnmary Reports prepared by the CQA Officer and Daily [°ield PWM,,QA W400 Doevnema6mdoc Final Clown Constrwfion COA Man ERA L'"Joneepiq, Augum 2015 014001 4 Page 3532 of 4165 Logs completed by the CQA Monitors. I ,rifle: Documentation. C,olor code(optional). Red. Contents-. Action Fornis, Acceptance Reports, Mecting/Discussion Summary Reports, Owner correspondence, Design Engineer correspondence, Contractor correspondence,and miscellaneotis correspondence, 3, Title, CeMfraclor Daily Field Rejwrts, Color code(optional): Green. Contents: Any gaily Field Reports prepared by the Contractor or Installer). 4, Title: Submittals. Color code (optional): purple, Contents: Updated SU bmittal Control Log,submittal trarismittal cover sheets,and all reviewed and approved(or 0her status)SUbinittak 5 Title: Soils CQA,. Color code (optional): White, Contents: (,,"onstruction as forms and laboratory testing reports 'for soils. 6. 'F itle: Gefx�ynlhefics CQA, Color code(optional): Ora,nge Contents: Consttuction, monitoring forrns and laboratory testing reports for geosynthetics. T Title: CQA P/am Color code(optional): "real, Contents, CQA Nam 8. Title: NotoV-qphy Log. ('7olor code(optional): Yellow. Contents: Construction and CQA photographs and cross-referencing Photograph Logs. Ll AS-BUJI.,TRECORD DOCUMENTS A, As-built Record DoclUments will be initintained by the CQA Officer and will be reviewedmid verified by the Design Engineer. B The As-built Record Documents will show actual as-built conditions of' construction, including an aerial topographic survey illustrating the final construction gyrades, and configirration, and will adequately reflect that constmclion, is in substantial compliance with the design intent of the Plans and Technical Spec ificat ions; irrelevant deviations in actual construction that(to not substantially affect the desigm,intent will not be incorporated into tbe As-bufft,Record Documents,but will be addressed in the CQA Certification Report(see Nat 1,12 of this,Section), C s-built Record Documents will be prepared dMing the construction process by making modifications,as,they occur to a single se:t of construction drawings designated as the Site As- built Record Doeurnents,;at tire corripletion,of construction the CQA Officerwi It incorp orate all as-built conditions into the Final As-huilt Record Doculnents. 1), "I'lle final As-built Record Documents will contain revision numbers, dates, and reviewer initials;and will be signed and stamped by the(,',QA Certifying Engineer, TurrCQ A R&KY)A01400 Dommunotionxim Fmal Closurc Conoftmakm(A)A Plan PF14 Engiapering Augwsx 20�5 01400 - 5 Page 3533 of 4165 1 12 CQA CER-171FICIMION R-IiPORT A. At tile conipletion of the project, the CQA Certifying Engineer will prepare a C"QA Certifilcation Report and sublinit it to Ilse Owner. The CQA Certification Report will con sist of information and data generated by the (.,,Q rogyani and will docunient that the firtal closure construction, is in co pfiance with Lae design intent of the Plans and Technical Specifications. At a rninimum, the CQA ('eLtification Report will contain the fiAlowing inf'onnatkm. 1, Summary of construction rneihods for each tin it of consirtiction.completed. 2. Sunirnaty of the CQ�A program iinplemented d-uring constrUction and specific,CQA activities(monitoring and testing)per1brmed for e,,ach unit of construction completed. 3 Results of confon-nancetesting and construction testing. 4, Revisions made to Plans and variances fi-on'i Technical S ecil ica t ions aflowed. 5 Final As-built Record Documents, 6. Statement of compliance with tic desigli intent of the Plans; and Technical Specifications,signed and starnpled by the CQA Cerfif3ring Engineer,a professional entn, neer or certified engineering byeo logist registered in the State of`C,al i forina, L13 DOCUMENTATION ARCHIVE STORAGF.' A, At the cornpletion of the pro,ject and.,'&er submittal of the CQ,A Certification Report and As- built Record Documents to the Owner,all original documentation generated by construction and the CQA faro gran:�,will be archived at the to ad mini strative office with duplicate copies stored at,the offices of the DesignErigineer and C'QA Cartifying Engineer. END OF CQA SECTION 01400 DOCUMENTATION L.Vlojocm\90M.305ure TUXITQA PkM,',jQA 0144A OmmenuakmmW NnW Ckwum Conwix-fian(,QA Plan VRA rnginerrinx Au�mxi 2015 01400 - 6 Page 3534 of 4165 FlFr DIVISION 2 CONSTRUCTION S E PROCEDURES Page 3535 of 4165 CQA SECTION 02207 AGGREGATE MATERIALS PART I GENERAL 1.01 SUNIMARY A. I'lie CQA Officer shall perl"Orm CQA procedares as outfined in this Section and follow guidelines for monitoring and testing to verify and d(icilment that the aggregate rmter als are in corn plialice with the Plans and'T'ecbriical Specification& 1,,02 SUBMT]"I"A A, Collect thi-ee(3)copies of each subinitial required in the Technical Specifications. B, Verif coinphance with the subinittal schedule and update Submittal Log, C Perform submittal reviewand approval procediires in Part 1.03 of Section 0 1300(Submittals) of this CQA Plan. PART 2 PRODUCTS 101 AGGREGA,rEMAI"ERIALS A. Verify that the following aggregate materialsniect the applicable: product requirerilents of Sectio,n 02207 (Aggregate Materials)ofthe'rechnical Specifications: 1, Aggregate base. I Pipe bedding. I Sand ballast, 4. Loose rock riprap. 5. Grouted rock riprap. 6, Gravel pack, 7. Concrete aggregatc., 8. Coarse role](for construction entrance. 9 Concrete sand. 101 Tailk bedding and backfill. 2.012 CONFORMANCETESTING A, Prior to aggregate lease,pipe bedding,tank bedding and tank backfill Placement operatio,ns, saniple these respective materials to be used at the Work site and send the samples to the Soils Testing Laboratory to perform following test as specified: I Moisture-Density Relationship(ASTM D 1557); one (1)persiource. & Prior to sand b�all,ast placenient operations,sample the actual sand material to be used:at the Work site and serid the sainples to tile Soils Testing Laboratory to perforin at least one(1)of' each of the following tests as,specified: I. Sieve Analysis (ASTM C 136)per every 10,000 cubic yards, Z Permeability(ASTM D 2434 [nlodified])per every 10,000 clibic yards. TuafCQA 111aiA4 QA 02207 Aggregate%lalenak&C Nwd Ormur,Conmuc6ou(XJA No FRA Aagkrerhff Auguo 2013 02207-t Page 3536 of 4165 C efi.t that the respective aggregate materials are derived firom the approved sources tbrotighout the Work, PART3 EXECUTION 101 STOCKPIL.ING A. Vefif that the (",ontractor Places all aggregate niaterials in the appropriate st�o,ckpile area, designated p l the Plans and in accordance with all rectuirements in the 'Fec4nical .�'pecifiications. 13, Verify that provisions are made to direct surfbee water away ftmn stockpile site(s) so as to p.revent crosion or deterioration ofmaterials, END OF CQA SECTION 02207 AGGREGATE MATERIALS Ka4'CQA 02207 Aggregate MmterWs.doc Foul Cbmut Conarunion CO A,Mzn 1""'UA ljjgMveryng Augum X)J I 02207-2 Page 3537 of 4165 CQA SECTION 02222 EXCAVATION PARI' l GrENERAL 1.01 SUMMARY A, I'he CQA Officer shall perfortrl, CQA procedures as outlined in this Section and follow guidelines for monitoring and testing to verif" and, document that all excavation work associatedwith the various construction tasks arc inicomplianice with the Plans and'Fechnical Speci fications, L02 SUBMITFALS A. Collect three(3)copies of the Contractor's Stonn Water Pollution Prevention Plan(SWPP11) as required in glee 'l.'echnical Specifications. & Collect certified weight tags isstied by the permitted transfier station or solid Nvaste disposal facility fbr all loads of refuse trwisported off-site fbr disposal. C. Verify compliance with die submiftal schedule and uPdate Submittal Log. D, Perform subii'iittal review and approval procedures,in Part 1,03 of Section 01300(Subinittals) of this CQA Plam PART 2 PRODUCTS (NOT USED) ART 3 EXECIJTION 3.01 PRE"PARMION A. Prior to begiiiniiig of any portion of general earthwork, hold as preparatory meeting in accordance with Part 1.04 of Section 01039(Pro.lect Meetings)of this CQ�A Plan, B. VerifY that the Contractor ihaaw located all UT)derground utilities prior to perfonning, any excavation for drainage an(Vor crosion control structures outside the limits of"Work shown on the Plans. 102 CLEARING AND GIZUBBI.M.3 k Verify that all areas delineated ror construction as shown on the Plans, iIICIUdJng irate-rim cover soil on the landfill surike and natural ground surface ww ithin.the limits of the on-sitc: borrow area, are cleared of all vegetative growth, such as brush, gras,s, weeds, or other deleterious material. t . Verify that cleating and grubbing is performed prior to beginning excavation ofany area. C. Verify that cleared and grubbed debris are stockpiled separately frorn excavated materiai in accordance with thereqUirernents set forth, in Part 3.05 of this Section, L�Vmjov,0907'10=Are l'urfC`QA PlmirCQA 02M E.Xcmalimdoc Final Oo sure Cansgrw vn CQN 1114m IIWA Anpm.rrInV hegmrs 2015 02222-1 Page 3538 of 4165 1 3,03 IUTUSE, EXCAVATION AND RELOCATIGN A, Verify that refuse bene,,fth the existing power fines, is excavated to the lines, grades and dimensions shown on the Plans. K Verify trimt the excavated refuse is relocated to the designated refuse relocation area shown on the Plains. C Verify that the relocated refuse placed within the designated refuse relocation area is spread fil uniform Efts not exceeding 2 f et in thickness and the each h ft is,compacted with a miriirnurn off" our(4)passes using a dozer. D. Verify that the relocated reftise lifts is covered with a minimum of 6 inches of soil at tfie crad of each working day to minirnize vector hmards and odor nuisance. E. Verify that,within five(5)working days of completing the rel'use excavation work beneath the existing power lines,the refuse relocation area is completely covered with a mininium of 12 inches of Prepared and compacted foundation layer material in accordance with Section 022,40 ('Foundation Layer) of these Technical Specifications. 104 131XIDENTAL REFUSE EXCAVATION AND DISPO,SAL A, Verify that refuse is excavated at the locations, and to the details shown on the Plans to accommodate the installation of drainage, LFG collection sys,teni, and condensate drain/discharge components, & Veri6f that excavated refuse is handled and managed in accordarice with the procedures outlined in Section 02222(Excavation)of the'I"ecimical Specifications, inctudingplacernent of reffise in roll-off bins or durnp trucks,covering ofroll-offbins or durnp trucks containing refuse at the end of each working day,and the removal of re�lluse from the site within 48 hotirs of being excavate(L C, Verify That the Contractor does not rnix excess,,surphis,or,waste niaterials From other general construction activities with the refuse derived from the excavation work, described in 'this Section, 3-05 S,OIL EXC.AVA,rtoN A Verify that excavation of swales for drainage and erosion control structures conforms to Section 194.01 of the Standard Specifications. 3.06 GRADING A. Verifythat the excavations For the on-site borrow area,drainage swales,sec dinientation basins and leachate (JS"l' are constructed i1i conforniance with the lines, grades, and dimensions shown on the Plans, 13 Verify that ansuitable rriaterials, as determined lily the Design Engineer, encomitered at the subgrade elevation are removed and stockpiled separately from excavated iriaterial or, disposed of inaccordance with Section 02222(]-,�xcavadorn)of the Technical Specification's. CQA MmaCOA 02222 ENoovation doc F"'imOi Omar ConstnxAon CQA Nov ABA Enpinee"fing A uKust 20 1.5 012222-2 Page 3539 of 4165 C. Verify that where excavation, is inadvertently carried below sub grade elevations, suitable provision is, madc by the t ontractor for ad]Listmen I of SUM as determined by the Des ign Engineer to meet requirements incurred by the deeper excavation;also,verify that fiiadvertent over-excavation in such locations is rectified by backfilling Nvith engineered fill and compacting to provide a firin and unyielding sub&n,ade in accordance with the requirements of the 1'echnical Specifications. 3.07 11AIJI,ROAD CON STR U(7"r[0N A. Verify that haul road locations have been approved by ITie Design Engineer. 3.108 DI)ST CONTROL X Verify that dust corrtrol measures are irriplernented fa, the(.,ontractor in accordance with the approved Dust C(,.)liitrol Plan and are effective inpreventing andcontrolfing the generation of' dust in constrtwdox'i zones, along haul roads, in eqUiP111C11t parking areas, and in other locations as may be required due to operations related to performing the Work, and as required by tine l)esign Enginexn% 3.0:9 f,R OSION CONTRO 1, X Verify that erosion and sediment control rneasures, are implemented by, the Contractor in accordance with the approved SWil,1111, and as, directed by the 'Design Engineer for a'lll. excavatior,i work areas including on-site borrow area, sedimentation basins, leachate C. stockpile areas,adjacent areas which have been disturbed, or any other affected areas. 3,10 DRAI.NAGE CONTROL A erif that the Contractor prov ides amplerneans said devices with which to promptly remove and dispose of all water frorn any s,(,):urcL, entering the stockpile area and any other active Work,areas,and inaintaitis these at all tirnes untit authorization for their rernowd is issuedby the Design Engineer. 3,11 CORRECTIVE AC,rl0NS A. Ir any p,ortion(s) of the excavation work does, not meet the requirements of the Plans and Teeb-nical Specifications,based on either field test results,observations,field survey,andJor physical measurernent,verify that that portion(s)is reworked or removed and replaced to meet the requirements of the Plans a�nd Technical Specifications and that the corrective actions implemented by the Contractor are in confbiniance with methods approved by the Design Engineer and the applicable StandaTd Specifications,, END OF CQA SECTION 02222 EXCAVAMN heal:VQA PWACOA 02222 Fxmnmkm.daU Final UoAurc Curigmefion CQA Nm ATA Em#YwerMN A ugusv 20 15 02222-3 Page 3540 of 4165 CQA SEC"riON 02224 ENGINEERED FILL I'MIT I GENERAL 1.01 SUMMARY A. The CQA Officer shall perform CIQA procedures as ouffined, in, this Section and follow guidelines for monitoring and testingto%,erifyai'tcidOCLIMClItUlaltengincered fifl niaterialsand construction methods are, in compliance with the Plans arid Technical Specifications. 1.012 SUBMITFALS (Not Used; PART 2 PRODUCTS 2A)l ENGINEERE"D FILL A. Verifythat the:engineered fifl materials meets flile applicable product requirernentsof Section 02224 (Engineered Fill)of the 1-1 echrdeal Specifications, 2.02 CONFOR MANCETESTING A %erify that engineered fill is obtained frorn one of the approved ori-site borrow sources, B. If engineered fill placement operations are b�eing pefl'orrned concurrently and 1rom, the same borrow source area as the l"buirdation layer or erosion-resistant layer constiuction,use results from the fot,undatioii./erosio�n,-r(,,s,istant layer confbrinance testing to determine rnoisture-density relationship for compaction, If not,sample the actual engineered fill material to be used and send the samples to the Soils"I"esting Laboratory to perforin the following test per the stated frequency of material to, be placed or a mininiurn ol"two(2) tests,whichever results in the greater nUmbeT Of WAS: 1, Moisture-Derisi try Relationship Curve(AS'rM r) 1557)per every 5,000 cubic yards, C. If engineered fill niaterial appearance or properties are difterent from those identi fled froln bon ow sottrve cluaracterization or change within the same location at 1he on-site borrow sourcle,based on visual observaflon,perform additional borrow source chanicterizalion tests in accordance with the aforementioned conformance testing faro gnuill. 11 Notify the Design Engineer of a change in materials and receive approval ftorn the'Design Engineer 15or use of the ntaterial,as engineered fill prior to excavating additional material froin that location within the on-site borrow source, PAR] 3 EXECUTION 3,01 1 PREPARATION A„ Prior to engineered fill placerneril operations,hold a preparatoty rnecting in accordance with Pail 1,04 of Section 0 10319 (Project Meetings,)of this CQA Plan. LAprojw'907,Cbxurn Tuji'CQA MmU,`QA 02224 EnginmCmd FA dac: FunW Clowe COns�rudmn Q)A Phn EBA Ea&bTecriq "4 ug'usy m) 02224-1 Page 3541 of 4165 13, Convey to the(.7ontractor that the nuclear testing Bann shafl be calibrated on a daily basis USiT1g The methods arid irrateria Is recoi,r iimerided'N-)y the gaga geiiiantifacturer."nie nuclear gauge serial n timber and the narne of the:s,oi I tech.nician,performing the soil density testing shall be rioted to demonstrate that both the technician and the nuclear gauge are certified. 102 PLACEMENT A. Verify that prior to placeinent of engineered fill on native ground,the subgrade is scatifled to a depth ofapproxit'nately 6 inches,moisture conditioned to within I to 3 percentage points of optimuni moisture content,and c(yrnpaeted to at least 90 percent of the ritaximuni(try density arms -s deterrnuned by ASTM D 1557. B, Verify that engineered fill material is Spread ill Unif'OrIll 100SC lifts not exceeding 8 inches in thickness. C Verify that each loose lift is moisture condifioned arid;thoroughly mixed to ensure a unifimnly distributed moisture content., 3,03 COMPACT,JON A, Veri ty that the final thickness of compacted, lifts does [lot exceed to inches. B. Pertbrin the following field tests at the frequency shown to verify that the compacted engineered fill has a minirriurn dry density of 9()percent of the maximiurn dry density aild is at a moisture content within I to 3 percentage p0ffitS OfthC OptifflUrn moisture content as deterinin.ed from ASTM D 1557: 1 Da,Densitv andHoisture Content-Aluclear(AST MD 2922'and D.30771 at least four saniples(4)per 1,000 cubic yards ofniaterial placed or ftnir sarnples per day. a. Por sedimentation basin improvements and lon'ner leachate pond backfill, perform at least one(1)test per every 5,000 cubic yards 2. Moisture Content(ASTAI D 4959 ; at, least one (1)test,per every ten (10) nuclear gauge tests, C. Record corresporiding dry density and nioistare content results on the Nuclear Density/Moisture Test Data f6rm. 3,014 CORRECTIVE ACTIONS A. If any portion(s) of"the engineered fill does not rneet the requirements of the Plans and "rechilical Specifications,based on either field test reSUIAS,observations, field stirvey,and/or physical measurement,verif that that'l),ortion(s),is,reworked or removed and replaced to niect the requirenients of the Plans and Technical Specifications and that flit corrective actions implemented by the Coatractor are in conformance with niethods, approved by, the Design I iMghrecr and the applicable Standard Specifications. END OF CQA SECTION 02224 ENGINEERED FfLL MaiiCQA 02224 Umpicaud Rldac Rnal C. Conmuniun CQA 111an EM4 f.,n�ivweriq, Augum WIS 02224-2 Page 3542 of 4165 CQA SECTION 02225 TRIENCIUNG AND BA(".'KFILLING PA11TI, GENERAL 1,01 SUMMARY A The CQA Officer shall perform CO A procedures as outlined in this Section and folllow guidelines ffnn®rnonitofirig and testing to verify and docurnent that all trenching and backfillitig work associated with the: various construction tasks are in compliance with the Plans and Technical Specifications. L02 SUBMITTALS (Not (Jsed) PAWF 2 PRODUCTS 2,01 PIPE BEI)MG, A Verify pipe bedding conforniance under CQA Section 0220�7 (Aggregate Matefiala) of this CQA Plan. 102 ENGINEERED F'TLL A, Verity engineered fill coafbrrnance under COA Section O 224 (Enghic=ed Fill)ofthis CQ�A Plan. 103 CON"l�'ORMAN("E'l,'I,'�.S'I'IN(-I A, Review rnoisture-density relationship confortnance test results for the pipe bedding and en gincered rill as detennined under CQA Section 0220�7 (Aggregate Materials) and CQA Section 02224 (Engineered Fill'),respectively,of this,CQ�A I?Ian. PART3 EXECUTION 101 TREMA I 111U."PARAT10N A, Verify diat the required points of connection,fines,levels,COMOUrs,and datlan locations have been identified by the Contractor, B, Verif"y that the Coritractor, has located all utilillies to avoid meclianical, and structural interference,, 3.02 TRL`,,N'C11 EXCAVATION A erify that trenches are excavated to the I ines and grades as s,hown on the Plans, B. Verify that any water or materials that interfere with the workiS TeMOVed. Verify that soft areas of trench subigrades not capable of compaction in place are cut out. Ph§&,CQA and Backfilling,doc fima�Closure Construawn C1QA Man ABA E"ngineeilng AUP "Wo 2015 02225-1 Page 3543 of 4165 D erify that trerich bottoms tire firm, continuous, relativelystnooth and free of rocks arid/or unsuitable material prior to the installation of pipe bedding or trench backfill material. 3.03 SHORING,SHEETING, AND 13RACING OFTRENCII A- Verify that the Contractor lias secured a trench perarit ftonr tbe Calilbriiia Division of Industrial Safety ptior to excavating any trench over 5 fM in depth. & Verif k ythat shoring and SlIeCtillgisremoved as bac fill isconipit,-te(iiiiaTnziriiier that willl 'not:darnage the, pipe or pet mit voids in the backfi 11, 3,04 PIPE/CONDUITTRENCII BACKFILLING A. Verify that trenches are backfilled to the lines arid grades as shown on thefllans. B, Verif�that the placement methods,ernployed do not disturb or damage buried drainage pipes and conduits hi the trench, C Verify that pipe bedding inaterial is placed tit trench bottoni in one continuous level layer not exceeding 6 inches,in compacted depth. D. Verify that pipic bedding is placied around the wales Carnal to the top,of the pipe/conduit,tarnped in place, and compacted. E. Verify that optitiium monsture content of pipe beddirig material is nudntained trr attain required compaction density. Perform tire fbflowing field tests at the frequency shown to verify that the compacted pipe bedding and engineered fill have a nn'nimum oby density of'90 percent of the inaxiinurn dry density and is at a moisture content within I to 3 percentage points of the:olitimurnn moisture content as determined from ASIM D 1557: 1 L)tT Densiji and Moisture Content-Nu(,h:,,qiL(I STAI 12 2 922 andL .301 ZJ; at least one(1)test per 100 linear feet per lift or at a change in rnaterial. 2, Moisture Con eat JAS'?."'A�f Q 49J; t least orne I test per eveyten (1,0) nuelear gauge test us. (J. Record corresponding dry density and moisture content results on the Nuclear Density/Moisture'lest Data fonn. UL Verify that trenches,are not jetted, un-less allowed by the Design Engineer, I For buried pipe that does riot,require pipe bedding or engineered fill(condensate drain pipe), veri fy that the trench backfill is placed in a maimer that will not damage the pipe and that the backfill is compacted to a firrn consistency consistent With SUITOLADding erosion-resistant layer material. 3.05 Al HORTRENCH BACK1711AING A. Verify that the placement rriethod employed does not dan'lage the gCorneMbrane/engineered turf in the trench. I uU.','0A P4n',X,',O,A 02225nrcnw.mng and Rackfiffing.doc FinA Closme Cowtructkwn CQA Pkn EBA Fn1,T�iovwrfYv&, 4u�,ma 2015 02225-2 Page 3544 of 4165 B. Verify that the poilion of the trench above the geoiniernbr,,iiie/ei,igiiiee:red� turf is backfilled with engineered fill and field tested consistent with the procedures described in Part 3.04 of this Section. C. Verity that trenches,are n0jetted, unless allowed by the Desigm Engineer, D Verify that the treriches are back fill ed, to the lines and grades as sbown on the Plans. 3,06 CORREcrivEACT'IONS A. If any portion(s) of the trenching aird/or backfiffing does not meet the mquireiments of the Plans, and Technical Specifications, based on either field test reSUItS, observations, field survey,andJor physical measurciment, wrify that t1wit portion(s) k reworked or retnoved and re laced to rtwet the requirements of the Plans and Technical Specifications and that Ole corrective actions implemented by the(,ontractor are in conAmmance with methods approved by flue Design Engineer aDd the applicable Standard Specifications. END OF CQ�A SECTION 02225 TRENS"11IN('T' A.ND BACKFILLING" P1mnWQA 01,225 Dmehing md Back fiffing,duc RnA Onum Connrucivn CQA Man KFU EngMee"rfng 012225-3 Page 3545 of 4165 CQA SEM'10N 022,40 FOUNDAITON LAYER PART 1. GENIMAL 1.01 SUMMARY A, The CQA OtTicer shall perform CQA procedures as outlined in this Section and follow guidelines for monitoring and testing to verify and document that the foundation layer materials and construction rnethods are in compliance with the Plans and Technical Specifleatiuns, 1.62 SUBMI'TTALS (Not Used) P'AR'r 2 PRODUCTS 2.01 f,'OUNDATION LAYER MATERIAL A Verify that[be l'brindation layer materials meet the al)r)lic,ablep!n,-oductrcqi,in!re!metits or Section 02240 (Foundation Layer)of theTechnical Specifications, 2,02 CONFORMANCE TESTMY A. Following cleaning and grubbing oflandfill surface but ptiorto fine grading and sewification operations,sample existing interim cover material to beincorponaled iinto the foundation layer and send the sam,plles to,the Soils Testing Laboratory to perforin at least one(1)of each of the following,tests as specifled: 1. Particle,Size Analysis(ASTM D 422)per every 5,000 cubic yards. 1 Unifted Soil Classification.(AS11M D 2487)pier every 5,0100 cubic yards, 1 Moisture-Density Relationship Curve(AS]"'M 11 1557)per every 5,000 cubic yards, & prior to new Foundation layer placemerit operations, sample the actual foundation layer material to be used at tile Work site and send the samples to the SoilsTesting Laboratory to perform at, least one (1) ofeach of the following tests as specified: I, Particle Size Analysis (ASTM Di 422),per every 5,01001 cubic yards, 2. 1 hiffied Soil (".",lassification (ASTM D 2487)per every 51,0100 eubic yards, 3, Moisture-Density Relationship,Curve(ASTM D 1557)Per every 5,0100 cubic yards, C Verify that foundation layer material is obtained fi-onus the approved on-site borrow Source as, determined ftoni,the aforenientioned coil forniance testing. D. If foundation layer rnatedal appearance or properties are different from those ideriti fled frorn borrow source Characterization or change writhin the sarne location at the on-site bon°ow source,based on visual observation,perform additional borrow source characterization tests in accordwice with the aforerrientioned con l'ormance testing prograirl. E Norif�,the Desig�n 1"'Jigineer ofa change in materials and receive approval from the Design Engineer for use of the material for foundation layer construction prior to excavating additional material ftom that location within the on-site borrow source, fllwuCQA02240 Fonlaflon A ayer d�rw FuW Clowure Con�gracnon('QA Man EVA EpqOm ping Aup 2013 02240-1 Page 3546 of 4165 PART 3 EXECUTION 3,01 PREPARATION A. Prior to foundation layer placement operations,hold a preparatory ineeting it accordance with Part 1.04 of Section 01039 (Project Meetings)of this CQA P'la,rl,. B. Convey to the Contractor Chat the nuclem,testing g,1LlgC shall be calibrated on a daily basis using the rnethods and materials recornmended by thejMLIge manufacturer.The nucleargauge serial nurnber and the naine of the oill technician performing the soil density testing shall be note(] to demonstrate that both the technician and the nuclear gauge are certified. 102 P ll EPARXHON OF EXI S,r LNG FNTERlM COVER SOIL"f"t": BE INCORPORATED INTO TH E FOUNDATION LAYER, A. Perronn visual soil classification of the interim cover soils per tire Riflowirig testinethod and frequency: 1. Jltsual Soot Class icalion (AST.&I D 2488);at least one (1) test per every acre. B. Verify that existing interim cover souls are scarified to a rnirlitnurn depth of']2 inches, C, Following scarification,verif y that existing interim cover soils are moisture conditioned and thoroughly l7iixed to ensure a unifbmily distributed moisture content to� within I to 3 percentage points of(lie OptiMUM moisture conteT t, D, Perform the fiollowing field tests,at the frequency shown to verft` drat the compacted,interiin cover soils have a minitilurri dry density of 90 percent of the maximuin dry densityand within I to 3 percentage Points ofthe optimum inoistuc content as determined ftoin As,rM D 1557: 1. I 4)�tk and Moisture("ontent--Nucl a LALS-0211 11M.Lmd1LiQ.L_7),Soil shall be sampled and, tested at a Frequency of four sarnples per 1,000 cublic yards, (YAC/lift)of material placed or 17our samples,per day,whichever frequency results in thie greatest nuinber of`tests, 1 Moisture Conlentf j at least one (1) test per every ten (10) nuclear gauge tests. 3.013 PLACEMENTAND(I"OMPACTION OF NEW FOLM)ATION LAYER MATERI[AL A, VerifYthat foundation layer material is moisture conditioned and thoroughly mixed ft'i the orl- site borrow area to ensirre an uniforuily distributed moisture content. At time of placement, perforrn the fbIlowhig field test at the frequency shown to verify that the foundation layer material nicets the soil classification requirernents: I Soil Clayso Lication(AST L4 I �ffl;one(1)sample per three(31)acres per lift(2,400 cubic yards)of material placed or change in iiiaterial,wl-richever results in the gtreater rrumber of tests, B. Record corresponding sloil,classification results on the'Test (Data R')rrn C, Continuously observe all placement operations to veriA�that the foundation layer material is consistent and has no oversized particles,overly wet or dry areas,or organic,deleterious,or other unsuitable matter. PWCQA 02244)Fotualation Laymdoc RW Closure Coosirucuum 00A Plan ETA Engineerine" Auput 2015 022,40-2 Page 3547 of 4165 ' 'Verify that Jouvidatimi layer!niaterjal is,spread in unif."orril loose lifts not exceeding 8 or 12 inches in thickness, * Verify that each logo s,e lift is moisture conditioned and thoroughly mixed to enSUre a Uniformly distributed nioisture content. * Verify that the rinal thickness,of compacted lifts for new foundation layer material does not exceed 6 nnches. Gj Perfonri the fbillowivAg field tests on each.6-inch Iffl,at the frequency shown to veal",that the foundation layer has I)een complacted to 90 percent of the rnlax iinurn(Iry density and is withi,r.i t to 3 percentage points of the optiniurn n1loisture content as detennined from ASTM D 1557: 1. Content-Myc4ear I D,2922 and Q.30Q.Soill shall ............................. be sarripled and tested at a frequency of' four samples, per 1,000 cubic Yards (3/AC/lift)of inaterial,placed or foursarnples per day,whichever fieqUency restilts in the greatest number of tests. 1 Moisture Content S7 Q at least onle (1) test per every ten (10), nuclear gaUgC tC8,18. K Record corresponding dry density and moisture content results on the Nuclear Den sity/Moistnre'rest Data form. 3,04 FINAU, ' URFACT PREPARATION A, Verify that the completed foundation layer swface is,free ofindividual particles,orprotrusions greater than 0.50 inches in,diameter, R Verify that ruts avid ridges on, the completed foundation layer surface are, liniited to a maximum depth or height of 1,01 inch. 3,05 CONFORMANCE VERIFICATIC)N A, Verify by augler or survey that the completed foundation layer has a rnininvam thickness,of 12 inches. Measurements by either method shall be conducted using a grid pattern with 100-fool centers, 3,016 CORREC"TIVI't' AC'110"NS, A, If a,my portion(s) of the fibundation layer does not meet the requirevnents of the Plans and Teefinical Specifications,based on either field test reSUltS,observations,field survey,and/or pirysical measurement,ved fy that that portion(s)is reworked or removed and replaced to 1-neet the requirenients of the Plans and Technical Specificatiana and that the corrective actions implemented by the Contractor are in cotifonnance with inethods appro ed by the Design Engineer and the applicable,Standard Spec ifications, END OF COA SECTION 02240 F'OUNDATION LAYER Man'CQA V,1240 finindmion Uyer dou Fmal Ckwirt Caaaruuflm CQA Man ANA Eng"irinvIng A wgugr 20)5 022401-3 Page 3548 of 4165 CQA SECTION 02310 ACCESS ROADS PARTI, GENERAL 1.01 SUMMARY ® 'rhe GQA Officer shall perrorm, CQA procedures as outlined in this Section and fbilow guidelines for monitoring and testing to verify and document that the access road materials and constiuction methods are in compliance with the Plans and'Technical Spec ifications. 1 M SUBMIT]"ALS (Not'Used) PAIUI' 2 PRODIJCTS 2,01 REfNFORM',"MENT GEOITXTILE A. Verify reinfi.)rcement geotextile confonnance under CIQA Section 02771 (Rein forcement Geotexffle) of this CQA Plam 2,012 M.K."iREGA'M BASE A. Verify aggregate base con-Fonnance'under CQA Section 012207(Aggregate Matictials)of(his CQA Plam 2.03, CONFORMANCT 'I"ES'l'ING A. Review im),isture-densit relationship conform ance test results for the aggregate b regatase as y determined under(.,,QA Section 02207 (Aggregate Materials),of this CQ�A Plan. PART 3 EXECUTION 3,01 SUBGRADE A Verify that subgrade is scarified a mirihmurn of to inches, unifomily moisture conditioned to within I to 3 percentages,points of optimum molisture content, wid compacted to at least 90 percent of the maxinium dry density as,dietennined by AS'TM D 155T 3, 7 ".02 REINFORCEM[�-,'NI'GEOI'EX T'11,E A. Verify that reinforcerrientgeolextileis tau italled,incline dingexamination ofsubgrade sulface,in accordanca;:with the requirements for geotextile as set forth in Section 012771 (Geotextile)of this CQA Plan. 3,013 A(!Cj,RECjrA,rE 13ASE A. Verity the stability of the subgrade by proofrolfing with a roller or loaded water truck. Verify that any areas determined not to be suitable are allowed to air dry until stable or o er- exicavated and backfilled with aggregate base. PWN.'QA OM 0 Acce"Roa&Am FiTIA Oown CMMUCTior CQA Nan E&I EqOmering Opun 2015 02310-1 Page 3549 of 4165 & Verify that trucks do not back-dump aggregate base onto the reinforcement geotextile and that they only drive on previously clurnped aggregate base to progress. Verif that,aggregate base material is,spread in uniform loose lifts not exceeding 8 inebes in thickness. 1), Perfonia the following field tests at 'the freqiiency s,how�n to verify that the coinpacted aggregate base material has a mininium di�-y derisity of 95 percent of the maximuni dry den,sity and is within t to 3 percentage points of the opth-num,moisture content as determined frorn AS]",M D 1557: 1 L�?:j�L)Smsity ty?( -'ontent- Miclear STM'D2922qndQ.30J7);at least_� _kMstyrv,,( one(1)test per 100 linear feet per lift. I Moisttow Content el 11 a..QffTM L at least one test per ev y te, (10) n Lic e r gauge tests,. E Record corresponding dry density and moisture content, results on tine Nuclear Density/Moisture"Test Data form, fa. Verity that access roads are"proof rolled"with a heavy wheel-load vehicle,sijeh,as a loaded water trLick,to identify weak areas,and verify that any weak areas are!reworked to the Design 1�'Irigineer's satisfaction, 3.04 CORRE('71VE ACTIONS A. If' any portion(s) of the access roads does not meet the requirements of the Plans and Technical Specifications,based on either field test results,observations, field survey,and/or physical measurement,verif: that;that portion(s)is,rewor ed or rernoved mid replaced to meet the requirements of the Plans and Technical Specifications and that the corrective actions irnplemented by the Contractor are in confonnance with methods approved by thc,, Design Engineer annul the applicable Standard Specifications. END OF CQ,A SECTION 02310 ACCESS ROADS L"4wojec0W?WWuYc rurfCQA 11J=fCQA 02M0 Aucew Ro"t3thic Fmol CIO$=Cangru6on CQA Man EBA Enginewiny Auqw�,?M, 023101-2 Page 3550 of 4165 CQA SU-rjON 02722 DRAINAGE AND EROSION C',0NTR,01,S PART I GENE11M, 1.01 SUMMARY A. "rhe CQA Officer shall perform CQA procedures as outlined in this Section and follow guidelines for monitoring and testing to verify wild d,Mirnetlt that the drainage and crossion control materials mid construction rnelhods,are in compliance with the Plans arld'I'lechilical Specifications. L02, si n3mrrTALS A. Collect three (3)copies of each submittal required in tine Technical Slpecific�ations, & Veiil compliance with the submiltal schedule and update Submittal Log,, C' Perform SUbirnittal review arid approval procedUrCS in Part 1, of Section 01300(Submittals) of this CQA Plan. PART2 PRODUCTS 2.01 DRAINAGE AND EROSION CONTROL COMPONFINTS Au Verif, that the following drainage an(,] erosion control coinponeilits, tricet the apfificable product requirements of Section 012722 (Drainage and Erosion Controls) or the 'Fechnical Speci fications, I. Cornigated metal pipe(CM11), couplings,and fabricated ratings. 2. 1-figh density polyethylene(HDPE)l pipe,couplings arid fabricated fittings. 1 CMP wichor assembly stakes and hard war 4. Turf rein,forcernent mat (TR,M). 5. TRM anchorage stakes, 61 Erosion control netting, T Erosion, control netting anchors. 2.02 PIPE BF,DDING A, Verify pipe bedding conformance under CQA Section 02207 (Aggregate Materials) ofthis ,CQA Plan. 103 BACKFILL, A. Verify that backfill placed above pipe bedding consists of material excavated frorn the trench/c.xcavation unless specified otherwise by the Design, Engineer. 11, Review moisture-density relationsbip(,oiifomiaiice'test!r(,SLI]t fby the erosion-resistant laver as,determined under CQA Section 012250, Layer)of this CQA Plan. Curd CQA Plax6CQA 02722 Drahigt main Eumixya Mn A("Jonwe Constguoioa(,,'Q,A Plan EHA E"nRovell Aqgat 20)5 02722-1 Page 3551 of 4165 2,04 ROCK RIP'RAP A Verfl"y rock riprap conforrnance under CQA Section 02207 (Aggregate Materials) of this, CQA Plan. 105 CONCRFTE A. Verif Y concrete,conf4rinance under(70A Section 03300 (C,oncrel of this CQA 11 a i, PAR,r 3 EXE CUTION 3.01 PREPARATION A. Prior to beginning construction of any drainage find erosion control stmchire, hold a, preparatorym metro g in accordance with,Part L04 of Section 0 1 039(Project Meetings)of this CQA Plan, 102 S'I'OCK11111,11W.1 A. Verify that the Contractor places all drainage and erosion control materials in an area(s) .ap.proved by,the Design Engineer. 3.03 F,X(",AVATION A, Vetify excavat ion conf"onnance under CQA Section 02222(lExcavation)of this CQA Plan. 3.014 DRAIN INLETS AND DRAIN PIPE A, Verif trenchingconfonnance underCQA. ection 022,25 (TTenchingand Backfillfing)of this CQA Plan. R Verif"y that drain intetsJburied drain pipe and associated bedding and backfill material are placed in confi.n-mance with Sedion 66-1 of tine Standard Specifications and flic'Fechnical Specifications. C' Verify(hat aboveground drain pi es are placed and anchored in conromancewith Section 66 orthe Stan(hard Specifications,and as shown on the Plans. 3.05 SBill IMI-INTATION BASIN DRAINAGE RISERS A Verif that vertical slots are cut in the sedinientation basin drainage risers to the dirnensions, orientation and frequency as shown on the Plans. B, Verify trenching conformance under CQA Section 02225(Y'renching and Backfiffin )of this CQA I'll an, Verify that minor concrete installed for the drainage riser fbundations is, as shown on the Plans. 'ruri'a.M PlanWQA 02722 Drsnhjgc ad Famic'm Cowxols,doc, Fimd Chnum.Comtmakm CQA Han EBA Aup mr 2015 02722-2 Page 3552 of 4165 D' Veri Fy concrete pliacernent conformance wider CQA Section 03300(Concrete)of this CQA Plan. Verily that bedding and backfiflniaterial are placed in conformance with Section,66-1 of tile Standard Spec i fications and the Tccbnical Specifications, 3.06 EARTHEN SWAIA.IS A, Verify excavation conforniance under CQA Section 012222 (IHAcavation)ofthis CQA Plan. 3.07 EROSION AT LINEr) SW ALES A, Verify that the TRA4 is, installed as shown on the Plans and per manufactiurer's recommend,itior-is. & Verify that trenches f6r terininal and the&slots(anchorage)are excavated into the erosion- resistant layer as shown on the Plans. C. Verify trench backfill confonnance under CQA Section 02225 (Trenching and Back.filling) and perfonn the followitig field tests at t1le fi-equency shown to verify that the trencli backfill has a mininium dry density of 90 percent of the MaXiIlMn),dry density and is withill t to 3 Percentage points of the optinnun tnoisturc content as deternlined from AS,TM D 1 7:: 1 L LiT.-D—e-L1,5,4ity.,and Moisture Contew- NgeleqL,(AjS�7�MD 22L2 qLid Q3Q,12).;at least one(1)test per I OO linear feet per I i it I Moishnv Content-fASTM Q at ]cast one (1) test per every ten (10), nUClear gauge tests. D' Record corresponding dry density and moisture content results on the Nuclear Density/Moisture lost:Data forgo. E, Verify that TRM placed at the top of swale(finish surfhce) is at or below the final gIrlide so surface drainage can, flow froely into (lie swale. F, Verify that all sphices are shingled downstrearn. G Verify that anchorage stakes are installed as shown on the Plans and per inanufacturer's reconimendations. 3 M LOOSE ROCK, RIPRAIII UNI'�D SWALES A, Verify that rock riprali is,placed to the average thlickness shown on the Plans with a 111axiniuni thickness deviation of 4 inches at ajay location, B. Verjf�y that rock ripmp is not be placed by diunping. C' Verif"y that individual riprap stones are moved and placed as, necessary to obtain a stable three-point bearing for each stone and as we,11-graded distribution along the entire length of the s,wale. D. Verify that the placed rockriprap is Iiee of pockets of'srnall,stones orclustet-s,ot'hirger stones. LAprr,jm0,90AC3o,wxft"T'craw'CQA ManTQA 02772 Wain4,,e and Tuoskm Corarokdoe FmAl Cknurr ConstnYrfloji(,°QA Mnn EBA L"aginerring August 2015 02,722-3 Page 3553 of 4165 3.09 GROUT]'E"D ROCK, RIPRAP OUFFALLS r Verify that the footprint of the outfiall is excavatedto t1le dimensions as shown ori the Plans, B. Verify that rock riprap is placed within the excavated footpriiitt(,)the avei•atgetliiekiiess shown on the Plans with as maxinuini,thickness deviation of 4 inches at any location, C� Verify that rock:riprap is,not be placed by dumping. D. Verif� that individual riprap stories are moved and placed as necessary to obtain a stable three-point bearing for each storie and a well-graded distribution over the entire lbotprint of the ouffill. * Verify that the placed rock Tiprap is free of pockets of small stories or clusters,of larger stones, * Verify concrete placement conforniance under CQ,A Section,03300(Concrete)of this CQA Plan,. 3.tO EROSION CONTROL A. "ea*that the finish surface leas been track walked prior to placernent of seeding, fertilizer and straw, B, Verify that the straw is placed onto landfill surfitce slopes that are steeper than 10 percent. C, Verify that the blown straw applied to the landfill surflace slopes has a ininilnunithickness of 1.5 inches in place. D Verify that erosion control netting is placed over tile applied straw and that the netting is sectired with ancliors at a,frequency of I foot on center along the edges,and one(I)every 33 square feet fix-interior areas. 'Verify that butt joints are spaced I foot apart, 3.11 CONFORMANCE VERIFICA"I"10N A, After construction of any portion of ckainage and erosion control measures,verify all grades and diniensions ofconipleted work by either field survey or physical rileasurctnent, 3,12 CORRECTI V E ACI"IONS A. If any portion(s)of the drainage arid erosion control provisions do not meet tile requirements ofthe'Plans and'I"echnical Specifications,based on either field test results,observations,field survey,and/or physical measurement, verify that that portion(s)is,reworked or rernovetl and replaced to incet the requirements of the Technical Specifications and, that the corrective actions ii!Tuplerriented by the Contractor,are in conformance with methods,approved by the Design Engineer and the applicable Standard Specifications. END OF CQA SECTION 027'22 DRAINAGE AND E� CONTROL T1WdCQA 02722 Dra; mgc md Em'mon rmntroh,doc FkW Clongo Coinawlion CQA Man AUM E`qinevring A ugum 2015 012722-4 Page 3554 of 4165 CQnA SECTION 02771 1 1 REINFORCEMENT GE01 EXTILE PNRT I GENERAL LOI, SUMMARY A. The CQA Olficer shall perform CQA procedures as outfinted in this Section andl-Ifflow guidelines for monitoring and tesling to verify and document that reinforcement geotextile materials and installation are in compliance with the Plans and'Technical Specifications, 1.02 SUBMITTALS A. Collect three,(3)copies ofeaclisubnaittal fisted in the Technical Specifications. l3, Verify compliance with t�he submilUd scliedUle and update Subinittal Log. C llerfonri submittal review and approval procedures in Part 1.03 of Section 01300(Submittals) of fl-iis CQA Plan, 1,03 TRANSPORT AND STORAGE A Upon delivery of'the reinfiorceme ant:geotextile rolls to the Work site,Verify that the rolls have been transported with opaque protective coverings and within a closed trailer, & During unloading of the rein forcenie tit geotextile rolls at the Work site,performthe following procedure: I, Obtain a copy of the packing list, I Cornplete the Geotextile Del,ivej!y and Control Log for each shipnient and attach a copy of true pa&king list. "I'lie Geotextile Delivery and Control Log documeDt.q,the following: ,a. Delivery date. b. Roll numbers. C, Batch/lot numbers or production dates, d Roll dimensions. e. Receipt of,MQ(.-' test reports. f, CQA conformance test ,',anipling, 9. Receipt c)f'('QA comformance test results. h. Mamifixturer and Product Narne or Designation. i. Naime of CQA monitor observing deliveTy and stowage. j, "Dotal quantity delivered with eaeb shipment and the cumulative total quantity delivered l�o,date. k. Additional notes including r(jection of materials, condition of delivered materials, and other materials,included with the shipments, 3. Obtain written certification from the Supplier that unloading and storage of the reinforcement geotextile rolls has been done in accor(hince with the Manufacturer's recommended procedures. 4, Verify that reinforcement geotextile rolls are transpotted, unloaded, handled, and stored in a inanner that does,not damage the reinforcement geotextile rolls or their CQA PtRmCQA(1277 p Rchiforvenw7m: FinM Oosun:Omaruoion CQA Man 4"BA 1"nRinew-Mg, Agial M15 02771-I Page 3555 of 4165 protective coverings in accor&uice with,the Manufacturer's recornmended proWdUres and the fbilowing requirements: a. Nylon or other cloth straps were used to unload and handle the reinforcement byeotextile rolls to protect the rolls and dwir protective coverings from damage, b. 'Fhe reinforcernent gootextile rolls were stacked no niore than nve Polls high and with a 3-foot wide access p.)alh between the stacked rows, 5m Verif that darnkigcd protective,coverings are, repaired or replaced. 6, Identify and separate damaged or rejected reinforcement geotextile rolls. PiiLRII 2 PRODUCTS 2.011 RE'INFO,,[((",EM,EN'I'Gp"o,i,i x,rl],E,(70MPONENTS A. Verify that the following reitiforcernent geotextile cornponenis mect the applicable product requirenients of Section 012771 (Reiril'orcernent Geotex tile)of the Technical Specifications: 1, Rein forcernent geotextile, I Sewing thread. PART'3 EXECUTION 3,0 1 PREPARATION AN D EXAMINATION A. Prior to relinfiorcement geotextile installation,hold a preparatory ineeling in accordance with Part 1.04 of Section 0 1039(Prq�ect Meetings)ofthis CQA lllan, B. prior to reinforcement geotextile installation, verify that all underlying material installation and,construction has been completed in accordance,with the'Fechnical Specifications. 3.102 INSTALLATION A, Verify that the reinforcement geotextile is installed in, accordance with Manufacturer's insft'Uclions for deploynient, sea,ming, and exposure. B. Verify that the reinibreernent geolextile is, installed with sufficient tension to preverit excessive overlapping, insufficient overlapping, wrinkles, and folds, D, Verify that the reinforcernent geotextile patiels are overkipped with sufficient rnaterial to create a prayer fold finer sewing operations, Vern that the reinforeement geotextile is adequately ballasted during installation and, until geotextile is covered with the overlyirig niaterial, F. Verify that the Pei nforeenient geotextile is permaliently anchored as shown on the Planswlien installation is complete, ('11 Verify that reinforcennent geotextile,daniaged dUring installation is removed and/or repaired with a sewn patch. H. Verify that ter final ends ofreinf6rcerrient g,eotextile, where the type and purpose of`the geotextile cbanges as shown on the Plans,are overlapped a nfininiurn,of 4 feet. 0'urf(',QA KnOEQ A 02771 Rehirfarvomm 0explem ile dov, Fnd flogurp Commotion CQA Nui FRA Engineming A Ikevo 2015 O2771-2 Page 3556 of 4165 L Verity that when ciating any rein lbreement geotextileabove othergeosynthefics,the histaller rases a knife with a hooked hlade, J Verity that the -underlying soil subgrade or installed geosyntbefics are not darnaged by reinfiorcement, geotextile installation equipment or methods and that any damaged soil subgrade, or installed geos.ynthctics, are coinpletely repaired in accor&nce with the requirements of the applicable parts of Section 02771 (],tehrrorcvment Geotextile) of the Technic,al Specifications., K, Verif tliatrocks,excessivewasp,excessivernoi store orother inatter that could cause damag,',c, hamper sewing operations, or clog,the reinforcement geolextile are not trapped under the reinforcement geolextile:or with in the overlap. 3.03 SEAMING AND R!".',.PAIR X Verif�that al,l searns are sewn unless an alternate sewning method is allowed b'y the Design Engineer based on the Insudler's demonstration offfic aftemative acceptability, K Verifythat overlaps are clean and flee of soil n!iaterials which could adversely affect sewing operations. C' Verify that a prayer fold,is made within the overlap prior to sewing. D 'erii fy that as continuous,401. tivo-thread chain stitch is used to,sew the prayer fold, El Verify that dainagpd reinforcement gedextile is removed entirely and replaced or repaired ir�[ accordance with the follawing guidelines: I. Repair(patching) material shall be of the sa,me type as the damaged reinforcement geotextile, 1 Patches shall extend a minitnurn of 12 inches in hall directions beyond the damaqyed area with the machine diMdjon of the patch a ligned with the machine direction oftbe damaged reinforcement geotextile, 3. patches shall be slearned using the saine niethod used for seaming the (Jarnaged rein forcenient geotextile. 3,04 CORRECTIVIi M"ITIONS A. Lfany poftion(s),ofthe reinforcement geotextile provisions,do not meet the rcqiiirements of the Phans, and Technical Specifications, based on either observations and/or physical measurement, verify that that portion(s) is repaired or rernoved and replaced to rneet the requirements offfile"I'echnical Spec J fications and that the corrective actions finplenilented by the Contractor are in confonnance witli rnetbods approved by ttic Desigm Engineer and the applicable Standard Specifications. END OF CQA SECTION O 71 REINFORCEMENT GEOTEXTILE HnaMogum Comsuvoian OQ A[Ilan ERA Engixireoing Auglar 2015 012771-3 Page 3557 of 4165 CQiA SECETION 02772 GEOMMBRANE PART I G'ENERAL 1.01 SUMMARY A 'I'he (,-,QA Officer sliall Perfbffn CQA pr-ocedujvs as outlined in this Section and follow guidelines for monitoring and testing to verify and docurnent that geornembrane liner materials and installation are in compliance with the Plans and TeThnical Specifications, 1.012 SUBMITTAI-S A, Collect three copies of each submittal lusted in the Specifications, M Verify comphance with the SUbinittal schedule and update Submittal Log, C. Perf"brm subinittal review aInd approval procedures in Pail,1.03 ol'Section 0 1300(Submittals) of this CQA Plan. 1 03 "FRANSPORT AND STORAGEi" A, During-unloading of the genioernbrane roll's at this sate,perform tlw following procedure., I. Obtain a copy of the packling list. I Complete the Goornenibrane,Delivery and(ontrol Log for each slfiprnent and attach acol,)yofthepackinglist. 'Fhe Geomerribrane Die livery and Control Log documents the following: a, Delivery date; 'b. Roll nun-6ers; c. Batch/lot numbers or production dates; cl, Roll dimensions; e. Receipt of MQC test reports; r, Manufacturer and Product Name or Designation; & Name of('.QA monitor observing delivery and storage, 11. Total quantity delivered with each shipment and [he a camulAtive total rjuantity delivered,to date; and i. Additional 11OWS ffiClUding rejection of materials, condition of idelivered inaterials, and other ier materials included with the shipmen Is, 3, Obtain ma-itten certification frorn, the Supplier that unloading and storage of the geornernbrane roll's luaus been done in accorchance, with the Manufacturer's recommended procedUreS. 4, Verify that geoinernbrane rolls,are, transported, affloaded, handled, and stored in a mani-wr that, does riot dainage the geornernbrane rolls in accordance with the Manufacturer's reconunended procedures,and the following requirenients: a, Stinger or straps(n[ylon or other cloth)shall lie usM to unload and handle die geornenibrane rolls to protect the rolls From dainage. K The geoniembrane rolls,shall be stacked no more than three rolls high and with a 346ot wide access path between the stacked rows, 5 Identify and sepanate damaged or re ected geornembrane rolls, L,!'�prqiiecfO,)07'oClor;L�rL'I'LLH'('QA P1,@n\(`,QA 01-1772 Geo men ihranc.doe fin,,fl Closure Construction CO,A Plan EBA Engineefing 02�772 - I Augum 2015 Page 3558 of 4165 PART 2 PR(')DUCTS 10 1 GEOME",MBRANE A. Verify that geornernbrane niateiial consists, of a conipourideJ Linear Low-density pollye.thylene(LILDPE) meeting the roduct reqLlif'emen s of the'rechnical Specilications. 102 EXTRUDATE ROD A, Verify that extrudate rod is made frorn the same resin as the geornernbrane, 103 FIELD"rEs-rlNG EQLTIPMI-,"N'I' A. Verify that the Installer provides and uses a field tensiorneter lbr searn testing that has been calibrated within the last year and is=Urate to,within, 2 pounds. B, Verify that the Installer provides and uses a I-inch (width)by 0-incli (lengtk)eu.tting die l'or cutting seani test specimens. 2,04 CON FORMANCE—FESIING A, ((.'induct sampling for C QA conformance testing at the site u,pon delivery or at the rnanu factu ring plant prior to,shipment and delivery to the site. B. For every 1001,0100, square Feet of inaterial delivered to the site, select at least one: georneinbrane roll to saniple:for C`rQA conformance testing. C' Sarnple the selected geornernbrane rolls for CQA conf6ri-nancle testing using the following procedure: 1, Cut and diseturd the first three feet of geomernbrane material Roan across the entire width,ofthe roll. 2. Cut the next 12 inches of material from across the entire width of die roll;this section of naterial is the CQA confon-nance testing sample, 3. Assign as(.,QA test nuniber to the sample and rriark,the f6flowing int"bmiation directly on the sample with as paint rnaxker: a. Machine direction of the sample.bi, Manufficturer's roll Runiber. C. CQA test number. 4, Complete the geornernbrane'Fest Request and Sample Custody'IA)g and ship samples, to the GeosyntheticsTesting Laboratory via overnight delivery. 11 'I'he following CQA confbrrnance tests will be performed by the Gicosynthietics Testing Laboratory to verify conipliance with the product requirernents of the Specifica(ions I I 71'ensile Properties (ASI'M D638). 2, Density(AS TM. 1) 1505),, 3. Carbon Black Content(ASI'M D 160 3)1 4. Carbon Black D,ispersion (ASTM D . 5. Sheet Thickness(ASTM D 5994). E. Upon conipletion of CQA conforinance testing and receipt of the results,,review all results for compliance with the Specifications and report any test results'whicb are not in cornplimice 1,,�'�prqje,c,tl907' Co,sure"f era CQA HaMCQA 02772('3eomeInbrWw,doc Fatal Closure Comaruction CQ,A,Han FBA Engincefing 012772 - 2 A ugyuM 206 5 Page 3559 of 4165 with the Specifications to the Engineer. F Additional CQA confortnaryce testing or corrective action to be performed in the eventoftesi restilts which are not in compliance with the Specifications, will be dietennined by the E.ngineer, PART 3, EXECUTION 3,01 PR l"PARATION AND EXAMINA"I"ION A Prior to geomerribrarie installation, hold a preparatory meeting in accordance with Section 0103 (Progj'-ess Meetings)of this CQA Plan. * Prior to geomenibrane installation, verify that all underlying material installation and construction has been completed in accordance with aie'rechnical Specifi cations. * Ven'l"y that prior to and at the milddle of each geornerribrane welding work shiftandwbeniever adjustments are made to the welding rnacbinesl the Inst4fler prepares and tests trial welds for each welding triachine that is being used or will be used during that work shit. D, Verif that trial welds are prepared for both fusion and extrusion welding machines and sampled usi!ng the fbillowing guidelines: I Trial weld samplez; for fusion welding machines should be as niininlUni of 6 fbef in length. 1 1,rial weld samples f-brextrUsion welding machines should,be a minitnurnof 3 Beet in length. 3. The trial weld,should be centered along and run the entire length of the sample. E. Verify that trial welds are tested as follows: I Trial welds,should be allowled to cool to arnbient conditions prior to tesfing. 2, After cooling,excessive material should be cut from the beginning and the end ofthe trial weld saniple (approxirnately 4-inches from each end'), 3. Using the cutting die, four I--inch specimens should be cut at an even spacing along the length ofthe trial wi1d. 4. Using the field tenisometer with a rate of separation of 2 inches per minute,two non- adjacent specimen'sshall be'tested for peel adhesion(peel)and two, for borided seajn strength (shear); both sides,of Fusion welds small be tested for preel. F. Record peel,and shear test results for trial welds on the Geomernbrane Deployrnent/Welding Log using the following criteria- I Peel Lest specimens: ,a. The break is either a film tear bond (FTB-passing)or a non-film tear bond (NFIB-Chifing), b. Percent of peel perietration into the weld (maximum of 10%). C. Quantitative value for PeCl strength(iniilirnurrt of 75 ppi). 2. Shear test specimens., a, The break is either a film tear lurid (FrB-passing),or a nori-filrn tear bond (N'Fl"13-railing). b Ellorigation of shear specinierr (inininium of 2 ffiches) C. Quantitative value for bonded sean'i strength (mininium of 120 ppi). Plan CQA O2772 Geomeinbrane.doc nmal Cimure cootnxHon cvo�,Plark ERA Engineering 012772 - 3 August 2015 Page 3560 of 4165 ("'i. If any of the four test specimens do riot meet the peel or shear criteria, repeat the entire trial weld and verify that the weld ing inachine is r),ot used R)r installation of the geomernbrane until passing as retest consisting of repeating the entire trial weld sampling and testingproicedure on a new weld performed with the flailing niachine. K If-die retested trial weld fails, verify that the welding rmichine is not used for installation of die geornernbrane until proper adjustments or repairs are inade and passing as retest; if the welding machine continually fails keld trial weld testing,verify that the welding rnachitie is tagged and completely removed fram work area. 102 INSTALLATION A Verify that geornembrane parilels, are deployed parallel to, the slope by Unrolling down, the entire length of the slope and that corrections or a(ljustments, are made to panels which became askew to the parallel line of the slope. B. Verify that adJacent geomernbrane panel edpfes are overlapped a inininiurn of 4-inches for flusion welding and alignment of'the overlap is kept consistent by marking overlap indicator points. C. 'VeriN that gleomembrane damaged during handling, transport,or deployrnent is renioved or repaired. R Verify that the underlying flue soil subgrade or installed geosynthetics art,, not darnaged by geornernbrane installation equipinent or methods and that any damaged soil subgrade or installed p-gosyntlieties are completely repaired in accordance with the requimnients of the applicable section of the Spec i fications. Vefif y that the Installer only depiloys the quantity of geon'ternbrane which can be colinpletely welded and anchored by the end of the work shift or day. F Verify that the Installer p,repares an adequate number of sandbags to ballast the'geornernbiname during deployment in accordance with the fiollowing guidelines: I, Only plastic ties shoodd be used to close sandbags; no metal or wire ties are allowled. 1 Sandbags should be removed prior to deploying overlyfiig niaterials and after compleflon of pennanent gconiernbratre anchorage. 3, Sandbag fill sbould not be disposed of within the firnits of work unless the fill consists of'inaterial which ineets the Specification for the material it is disposed upon. 4. Cieomenibrane rolls rnay also be used for ballast provided that no damage, to, the deployed geomembrane occurs. G Verify that the Installer deploys and searns the geornembrane in a rrianner which rnini'mizes wrin-kles, and provides the proper aniount of slack irl the installed geornenibrarre to cornpensate for contraction clue to local temperature extremes prior to covering; no stress- bridging or"fishmouths"are allowed, 11, Verif" oes y that immiediately after gleomenibrane panels ranning through ditch flow lines or at k of slopes are welded,sandbags are placed end-to-end along the entire length of the flom((,)T toe line to prevent stress-bfidging at those locations; alternatively, to reduce the number of sandbags, required and to ffirther prevent stress-bridging, the Installer may anchor the Turf(,QA Plan'T,'QA 02772 Gee mmnbranexloc Finifl Clog ure Constnxtion CQA Plan EBA 1,nghxN^ring 02772 -4. August 2013 Page 3561 of 4165 geon-Warnnbrane near the toes of slopes, within a backfilled anchor trench constructed in accordance with the Specifications. 1, Verify that geoinernbrane panels a enot overlapped or searned perpendicular to the slope on slopes with as gradient of nriore than: 10 percent, within 20 feet of the top of any slope, and unless the geornenibrane is, anchored within as backfilled anchor trench constructed in accaulance with the Specifications, Ja Verif" y that when cutting any geonwinbrane ablove another geornerribrane,the Installer uses as kii ,gin with a hooked Made. K, Record the f'ollowing infonnadon on the Greomernbrane DeplOyftierit/Welding Log: nrr� The abbreviations in each verffleation proeeditre are used on the Geomenn5rane DeployinentlWe4ding Log, I TernpCraftlre (T), Ambient and geornembrane surface temperatures with a descripl�ioi'-iolftliecLirreiitwe,itliercoi,ndition.s,, Record every two hours,and document draniatic changes in terriperature and weather conditions. 2. Triat Welds (TW)m 1"Irne of trial weld, type of welding eqUipment, welding equipment number, welding operator, and results of field peel and shear testing of trial welds, 1 Panel (P). Assigned panel nurriber, geornernbranle, roll number, panel dimensions, and area of panel. 1". Using a graph computation sheet, Field sketch a panel layout drawing of the geornerribraric pariels deployed during the day and attach,this field sketch to the cornpleted Geotnerribrane Deployment/Welding Log; the daily field sketches will be transposed to ffic master partel layout drawing. 3.03 FUS[ON WELDING A, Verify that fusion welding operations only take place when the aniblient tcraperature is between40T and I IOT unless the special weatherweldingplans have been submitted lady tine In,staller and approved by Engineer to weld outside t1iis,range,-nleastrre anabient temperature 6-inches above the in place geornernbranc and record readings every two hours, on the Geonienibnane DeploymenblWelding boll. B. Verify that all geornerribrane searns,are fusion welded by tine double-track method leaving an air gap for leak testing;extrusion welding caarn only be used for repairs,patches, fabrications, and inaccessible areas. C Prior to welding, verify that all fusion, welding machines have perfortned trial welds, and passed field trial weld, testing. D, Verify that the Installer's power source is capable of producing su flicieritand constant voltage Under the cornblined line load of multiple welders and otber equipment. E. 'Verify that surfaces,to be welded are thoroughly cleaned. 1�', Verify that scanis are welded at the sarne speed, temperature, roller pressure, and gauge settin gs used to prepare the trial weld and that the welding operators record welding inachine nun,ibers,operators,machine settings, tirries,and dates on each seam welded. Turf'(,'QA P1,uACQA 02772 GconnenibrarwAoc Final Closure Conuliuction CQA Plan EBA Enginexring My 027'72 - 5 pw 2015 Page 3562 of 4165 G, Closely observe each fusion welding inachine to verify that the machine is, not adversely affiecting or damaging the parent geomenibrane material on the welding arc-a, III, Record the following in rorniation on tile Cieontembrane Deployment/Weldirig Log: Notc,,'�: The abbre via,tions in parenthastyjbllo iving each ver�fication In-ocedurn are,used on Me Geomembrane Dept qy)nent(M?1d7ng Log. I Searn(S), Assigned seani nu.niber,welding equipment number that welded,the searn, welding operator,and length of the welded seam. 2. Erid of Searn Test. (F"S,T), If the Installer's qIuality control progpin requires that speci incris be taken ftoin the end of each welded seam and tested fi)r peel adhesion, record these results using the same criteria as for trial welds. Ifthe'InstaHer records these resu Its, request a copy of the results and this int"orriiation,can be omitted ftom the Geomembrane Deployment/Welding l,x)g, 1 Searn'111'est San ipile(S'T'S). Assigned sarriple nurnber,seam numbersample is located a',)%location of sample within the searn,welding machine nUmber,welding operator, and results of field searn testing,, 3 N EXTRUSION WELDING A. Verify that extrusion welding is used,only for repairs,patches, fiabrications,and inaccessible areas. B. Prior to welding, verify that all extrusion welding machines have,performed trial welds mid passed field trial weld testing. C Ver4 that geomembrane:patches,overlap the underlying geolinembrane I?anel a iiiinfi-num,oF4 inches, D. Vieri that geomenitirane patches are cut square with rounded comers and are lar le enough to extend as ritirrimurn of 4 inebes in all directions over the repair area. E, Veril r that geomembrane patches are tack-welded to the underlyin eomembrane planel to prevent movement during grinding,and extrusion welding op,erations. K Verify that the outer edge of repair patches and the adjacent underlyin eomembrane are disc-ground to reinove surface debris and oxidation an(]that grinding is not parallel to searn, G. Verify that the nozzles of extrusion guns are purged before each use to remove solidified extrudate. 11, Verify that the extrusion weld completely covers the entire widdi of the fnind area and that extrusion safety welds extend 4 inches tip arny hitersecting fusion weld, L Verify Chat a car) strip patch is extrUSjon welded at all l"Usion welded seani intersections of three or more geornernbrane panels. J11an\CQA 02772 Geomembrane-doc Final Closure("onstivefion CQA Plan EBA Enginee6rig 02772 - 6 Akq,,,um 2015 Page 3563 of 4165 105 QUALITYCONTROL, A. Verity that,quality control Focedures are perfoianed by the Installer in accordance with the Installer's Geornembrane Installation Quality Control Manual except where amended or rnodified by the Engineer or the Specifications. 13. Verity that the Installer maintains the following quality control documentation during the geornembrane installation in accordance with the Spec ificatiol is: I An accurate geoinernbrane panel layout drawing which includes; 1),roll and panel numbers;2)scam numbers;3)geonierribraine limits'-4)anchor trench locations; and 5) scam test sample locations. 2, Daily deployment logs and panel layout drawings to be subrnitted to the CQA Officer daily which include; 1.) pariel and searn numbers; 2), panel dimensions; and 3) deployment quantities,, I Daily welding logs to be submitted to the CQA (.)fficer daily which include; 1) wielding inacliine numbers;21,operators;3)inachine seffings;wul 4)times and dates for each seam,welded. C Verif'y that the entire length of each ftlsion welded scam is air-pressure tested try the Installer, with an air purrip,capable of generating and maultaining 4,01 psi of pressure and equiippedwith a regu lator and pressure gauge and pressure feed needles having,pressure gauges accurate to t psi, in acclorclance with the 'fol lol proced irare; I Seal bloth ends of the fusion weldeld seam witli vise-grip plate clamps or an extrusion weld;beat inay be applied,to the searn ends to aid in,sealin�g the seam in,conj uniction with, the clarnpis but due to the potential hazard of igniting, landfill gas, propane torches or any other flarne producing device are not allowed, 2, At one end of the seam, insert air pressure !needle into the fusion weld channel. I pressurize the channel to 30-35 psi and maintain pressuref"br 5 ininutes. 4. Release air frorn the opposite end of the seam, to verity that the entire length of the fusion weld channel was pressurized. 5. Ifebannel pressure is not maintained with a inaxi'murii allowable pressure loss,of 2 Iasi over the 5-niinute test period or doers not stabilize at all,locate the defective area, isolate it,and repeat air preSSUre test procedures in each direction from the defiective area. 1). Verify that the Iristaller niaintains air-pressure test logs,on which are recorded scam liurnbers,, begirining and ending air pressures,beginning and ending test dines,lengths of tested,warn, defective areas found, and confinTiation of'repair. Record the following air-pressure testing, information on the Geornernbrane Dep'loyment/Welding Log,- Note: Theabhreviations tile Geomembimne I fir-Pressure Test (AP). Seam number t�est�ed, start time of the air pressure test and initial air pressure (psi), termination time of the air pressure test: and ending air pressure(psi), and length of sealn or portion of seam successfully tested. ]z Verify that the entire length of each extrusion welded seam and repair is vacuum tested by the Installer in accordance with the 'following procedures, will), a vaCUUM ptunpi capable of' generating and maintaining 30 inches of riwrcury arld equipped with a clean view window, regulator, a,nd vacuum gauge accurate to 'I psi: I Saturate the extnlsion weld with a soap and water solution. PIan\C0.A 012772 Geornembrane.doc Final Oosiarc CQA Plan EBA Enginecting 02772 - 7 Augusl 2015 Page 3564 of 4165 1 Place view box over the saturated weld,create art air tight seal,and apply vacuUffl in the box. 3. Maintain the vacuum for 10 seconds and exa,Lrdne weld for forming bubbles which indicate leaks; niark detected leaks for follow-up extrusion weld repair and retest detected leaks,after repair to verify that the leaks were successfully repaired. G Verify that the Installer maintaftis VaCLIUM test logs on which are: recorded repair numbers, vactnim test dates, and vacuum test results. 11, Record the following vacuu-ni testing infonnation on the Geomenibrane Repair Log. I Assigned repairnurnber, location and description of repair,vacuran test dates,and vacuum test results. 3,06 SEAM TI-I'STSAMPLING A. Deterarne sears analysis sample ]'locations by the stradjh.,d random sampling niethod.The stratified randorn sampling method allows random selection ofa single sewn analysis sample location anywhere within tile required 500-lineal Let sampling interval requirLd in the technical specifications. Have the Installer perfonn the following searr-i analysis sarnpling procechires, 1. Seams analysis samples will be 12-inches, wide by 36-inclics long with the weld centered down the length of the saniple, Sarriples sizes, may be modified at the request of the Installer or CQA Officer, Cut one I-inch specimen froin each end of the sample, and field test specilnens for peel adhesion in accordance with the 'recl-mical specifications.If these specililens pass the field peel test,submit sample fbr, laboratory searn analysis. If either of the speekliens, fail the field peel test, perforin Faded Searn Analysis Procedures in accordance with Section 3.08 oftbis Section. 2. Di vide the sarilple into ecitia I two sections,submit one Section for warn analysis and arcfiive storage the second section, 3. Installer ri-my obtain and test any warn analysis sample at its option. 4. Repair sample holes and vacuum test repair in accordance with Section 3.O4 of itis Section. Based on the seam analysis saonpling inethod qj'attfibutes,the CQA Officer may decrease or increase the 500-foot sampling interval based on the following ,ntro chart of passing percentages,of'searn analysis,results. Percent Of Passing Searn Sa mp ling Modific�a tion s 100 Decrease sampli!l :raterwral to lff�tfff lf': 90— 100 1)ecrease sampling interval to 750 If. 60-90 Maintain sampling interval at 500 If 30 -60 Iricrease asanr fli ,interval to 250 1 f, Lott Sampling modVicationswillbe considered oody offer 20 percent 4,,�fseain anal L ysls is cornpleted. CQA PlaMCQA 0127'72 Geomembn.meAv Final("Josure Construlion CQA Phin F'BA Etqginee6ng 02772 - 8 August 2015 Page 3565 of 4165 107 LABORA"VORY TESUNG A. Laboratory seani analysis will be perfornied at the Geosynihetics Testing Labonatory,which is independent of the geoniernbrane Manufheturer and Installer, and, will be perfbimed in accordance with the following procedures. L Seam analysis will include peel adhesion and bonded seauras strength(ASTM 1)6392). Five specimens will be tested for each method. 1 Both sides of Rision welded seams,will be tested for peel' adhesion, 1 All five of the specimens rnast meet the Fail Criteria specified in, the technical specifications. f . Acceptance of the welded geomembrane sciun. s will be based on the resailts oflaboratory sewil analysis, 3,08 FN[LED Sf�,AM ANALYSIS PROC I","DUR]"IS A In coordiriation with the Installer, perforn.) the following quality assurance verificatiol"I procedures in the event of a seani analysis saniple failure determined by either field testing or laboratory seam analysis. I Track the welded seam 10 feet in both directions away from Lbefiailed searn analysis sample location, Cut as sinall 12-inch wide by 12-6111ch long sample frorn each location. Cut one 1-inch specimen from each end of the minple, and field test specimens for peel adhesion in accordance with Part 3.0 1, ofthis Section, If these SI)eCiMens pass the field peel test, submit a 12-mch wide by 18-inch long re-test sample ftom both 1='itions for laboratory sean-i analysis. If either of the spe6r-nens Fail the field peel Lest at either location,continue tracking the welded seani at, 10-foot intervals until specimens successfully pass the field peel tests and as saniple can 'be submitted for laboratory sears analysis, If speciiiiens continually fail field peel tests at I 0-foot intervals,the entire seam or portion of the welded scarn will be repaired at the discretion of dic CQA Officer. 2,. Verify that the failed lengtli, of seam is repaired with an 18-inch wide extrusion welded cap stdp. Tack and extrusion welding the leading flap of the fision welded seam is,not pen nitted. Verify that the extrusion welded cap strip,is vacuum tested in accordimce with the teclinical specifications. 3. If there-test sainple Fails laboratory searn analysis,repeat the above procedures. B, Sarnple extrusion welded cap strips exceeding 10O feet;in length for seani analysis. END OF CQA SECTIDN'02772 GEOMEMBRANE V1k0k,QA 02772 Geormnibnane,doc F'inal CAMIre COIISLMIC60"(,QA PW EBA Emginee6ng 02772 - 9 Augwa 2015 Page 3566 of 4165 CQ'A SECTION 02773 ENGINEERED TURF PART 1 GENERAL 1,01 SUMMARY A. The (.QA 01:17icer shall perforni CQA procedures as outlined in this Sectic)n and follow guidelines for monitoring and testing to verify and docurnent that geonet camposite material and,installation are in compliance with the Plans and 'Fecmeal Specifications, 1,02 SUBMITTALS X Collect three(3)copies ofcacb submittal fisted in the Technical Specifications, 13. Verily compliance with the submittal schedule and update SubrniMal Log. C �Perf'()rm submitUil review and approval procedures in Part 1.03 of Section01300 of thisCQA Plan, 1.03 TRANSPOR'r ANT) STORAGE A, Upon delivery of the engineered turf rolls to flw: Work site, veffy that the rolls,have been transported with opaque protective coverings and within a closed trailer or covered open trailer. K During unloading of the geonct composite rolls at the Work site, perform the 'following procedure: 1. Obtain a copy of the packing list., I (.,oniplete the Engineered 'Turf Delivery and Control Log for each shipment and attach a copy of"time packing list. The Engineered 'fsurf`Delivery and Control Log documents the following: a,. Delivery dat�e, b R.(.)Il numbers. C' Batch/lot numbers or production dates, cl, Roll dimensions, e. Manufacturer and Product Narne or Desigmation. f Narne of C'QA monitor observing delivery and storage. 91 Total quantity delivered,with each shipment. It. Additional notes including rqjection of materials, condition of delivered materials,and otber materials included with the shipments. I Verify unloading and storage!of the engineered turf rolls has been done in accordance with the Manuflicturer's,recon-�rnended procedures. 4. Verify that engineered turf rolls arc transported, unloaded, bandled,and stored in a manner that does not dainage flie engineered turf rolls or their protective coverings in accordance with the Manufacturer's reconimended procedures and the following requirements: a. Nylon or other cloth straps are used to unload and handle the geonet composite rolls to protect the rolls and their protective coverings ftorn dainage. A VhdCQA0277,;[Inginemed Tuff:dov FM Oimurc CQA Man 4WA Enginvering Aoguxt 20�5 02773-1 Page 3567 of 4165 b, the engineered turf rolls arc stacked no more. than five (5) rolls high and with a 3-foot wide access path between dw stacked rows. 5. Identify and separate darriaged or rejected engineered,turfrolls, 6 Verify that daniaged Protective coverings are repaired or replaced. T ffCQA confonnance test sampling,in accordance with Part 2.03C of this Section,is to be Performed during delivery to the Work site,deterntine wh ich geonet composite rolls will be sampled by either individual roll numbers, batch/lot numbers, or production dates,and position the rolls for convenient sampling. PART2 PRODUCTS 2.01 ENGINEEREDTURF COMPONEN'rs, A, 'Verity that tire fbilowing engineered turf components meet the applicable product 'requirements,of Section 02773 (Engineered'Furf)of the I I echnical Specifications: I. 1,^'ngincered ,turl'geotextiles. 2, Engineered turf polyethylene yarns(grass blades). 3, Sewing thread. 4, and ballasia infill. 5, I-lydrobinder. 2,02 CONFORMANCE TESTING A. Canduct sampling for CQA confamrance testing at the Work, site upon delivery or at the manufacturing plan[prior to shipment and delivery to the Work site. B, For every I O0,000 square feet of material delivered to the Work site, select at least one(1) engineered turf roll to sample Bor Ct conformance testing, C". Sample the selected engineered turry-olls for COA confoniucuice testing using the following Procedure: I Cut and diseard the first 3 feet ocf engincered turf material from across the entire width of the roll. 2. Cut the next 18 inches of material from across the ei'itire width of the roll;this section of material is the CQA confbrrnatice testing sample, I Mark the sarnple with the 111)[lowing information directly on the sample with a paint rnarker: a, Machine direction ofthe sample, b. Manufacturer's roll number. C. CQA test number. 4. hnmediately re-wrap the sampled engineered turf roll with its protective covering; use additional opaque plastic sheeting, if needed', to completely cover the:roll, 5. Complete the Engineered Turf Test Request and Sarnple Custody Log and ship saniples to the Gcosynthetics"Festing Labonatory. D "he following CQA conformance tests will be perfortned by the Geosyntheties Testing Laboratory to, verify corn Pliance with the product requirements of the Technical Specifications at the following frequencies, TiA'CIQA Ph&nW,'QA 02773 Es4�KwTed'riur,&w Frmd(Inure ConAlueflou CQA NWR EBA E"Agineering Aubpat 20�5 02773-2 Page 3568 of 4165 ne M per every 100.000 sauare ket, ot'EngineereLl 'Tur -) nent'�y tp IX'rnate'rial emn't±) installed: 1, CB R Runcitire(AST' D624 1). 2. 'rensiie Properties(ASTM, D4595). I Rainfall Induced Erosion(ASTM D96459). 4. Fiber U V Stability(ASTM,G 147), 5, Backing System UV Stability,Exp�osed(AS"I'M G 1,545 Modified Cycle I,INA340), 6. SteadyStale f,lydt,,,iiilicOverto pia,u,g,Turf with Hydroffinder(ASI''M D7277/D7276), T .1 ransrnissivity with underlying stmeture geomembrane (ASTM D4716). 8. Internal Friction of combined components( TM D5�321)). 9 Sand Infill Gradation and Ballast (AS"I'M D6913). 10, Yarn Weight(ASTM D5261)1. IL Tensile Strength of'Yarn (ASTM D2256). E Upon completion,of CQA conformance testing and receipt of the results,review all results for compliance with the 'rechnical Specifications and report any test results, which are not in compliance with the'],I lechnical Specifications to the Design Engineer. F. Additional CQA confortnance testing or corrective action to be:performed in the event of test results which are not in compliance with the Technical Specifications will be determincA by the Design Engineer. PART 3 EXECUTION 3,0 1 PREPARATION AND EXAMINA'noN A. Prior to engineered turf insufflation,hold a preparatory meeting in accordance with Part 1,04 of Section:01,039 of this CQA Plan. B. Prior to angineered turf installation, verify that all underlying material installation and construction has been completed in accordance with the Tech nicaal Specifications, 102 WSTALLATION A, Verity that engineered turf is histalled in accordance with the klamthctt.rrer's instructions. B. Verif that engineered turf is installed with the machine (lengiliwise) direction of the roll oriented down the slope . C Verify that the engineered turf panels are deployed from the top ofthe shape in a way that the engineered turf is laid substantially, smooth and filaments are pointing upslope after deployment is complete. 11 Verif that the first engineered turf panel deployed has the turf filaments, facing upwat'd, Verify that subsequent pancls are deplo, ed. turf side down, and on top of the previously installed panel, Verify that after seaming each panel, tile panel is flipped onto the ge,mnembrane component with care to,avoid pulling of tufts in the drainage studs. E, Verify that end-to-end panel overlaps, only occur on benches, unless the length of a slope PlaxOCOA 02773 EnghoacmA I urf.duc Rud Cbsure Conmnjokm CQA Mai 621A Enginve-fing August 2015 02773-3 Page 3569 of 4165 bet�ween benclies exceeds,the total length ofat ftdl enginecred turf roll, F. Varity that tine engineered turf' is installed with sufficient tension to prevent execssive overlapping, insufficient overlapping,wrinMes, and folds. G. Veril'ythat a single stitch prayer type seams is,constructed LISing a Nulong sewing machine or equivalent, Verify that sewing throad is 207 polyester or equivalent and that sewing occurs between the I st and 2nd row of engineered turf stitches. if. Verif r that the engineered turf is ballasted during installation and until the engineered turf covered with the sand ballast infill material, 1, Verflly that on slopes exceeding 15%, no equipment is allowed on the partially constructed turf cap system until afler the completed installation of the sand ballast infill, Verify that orl slopes,less than 15%,ATV type vehicles are allowed pr,iorto infill placement if tile lore/track pressure is less than 5 psi. 1 Verify that following full specified sand ballast infill thickness installation,traffic be limited to light duty vehicles with drivability tire/track pressures of less than 35 psi. K. Verify that engineered turf darnaged during installation is removed and/or repaired with a sewn or fastened patch at the directi oil of the Design Engineer. L, Verify that portions of the engineered turf wasted by the Installer,and rendered unusable,as deterrnined by the Design,Engineer,are transported by the Contractor and disposed of off-site at a perniitted transfer station or solid waste disposal facility, 3,0 ND BALLASTIN1711.1,PLACEMENT A "erify that sand ballast infill is placed between the tufts of tine engineered turf and-, I Is per plan either 5/8 inch thick or 2 1/8 inch thick,with a thickness tolerance of I,/- 1/8 inch. 2, Consists wholly of sand meeting ASTM C-33-03 for fine aggregates. 1 Turf areas that are, to receive sand ballast infill are accepted by"the CQA Officer before placernent of'sand ballast infill takes place B, Verify that sand ballast infifl is worked into the engineered tijrf between the synthetic yarn blades. C. Verify that conveyor systerns and/or Express Blowers are used to spread and place the sand ballast infill. 11 Ved that the Contractor has,explained with detai,l in the Preparatory Meeting,thernediod of sand infill deployment lc) be used. E VeTif y that previously installed components are not displaced or darnaged as a result of the sand ballast infifl component installation., F. Verify that a standard washer is Utilized as a plate for the point of entry into the sand ballast infill fk)r consistent depth control, I tnfCQA Plan,CQA02773 Enginceled Turrdm Final Climurt,Conmroction CQA Phm 02773-4 Page 3570 of 4165 3.04 INFILI....... HYDROBLNDE,Al, PLACEMEM' k Verify that the HydroffiDdeM infifl, layer is placed Using appropriate,equipment cap�able of completing the work. B. Verify that the Contractor has explained in detail during the Preparatory Meeting the method of HydroBiriderS infill deployment. C. Verify that iDstallatioa of Hydroffind&A) infill is only be perfornied by a Manufacture's approved installer using tecliniques,and equipmeiitapproved by the ManufactUrc. 1), Verify that the I droBinderg is installed into the turf while it is in a dry state and that the Hydrc')Binderl-Dis worked into the tulls so the tufts are in an upright position, J_ Verify that the llydroffindevg)infill is placed di),to a thickress of'7/8 inch with a tolerance of 1/- 1/8 inch, F, Verify that the hydration process occurs on the satin day as the HydroBinderTIRD infill placernient arid that the required Rydroffindei<R) infill thickness is achieved prior to the hydration process. G, Verify that tlic cemented infill is bydratect thoroughly arid that cam is taken to avoid displace'Ment of the non-hydrated infill. 11, Verify that:once,hydration is completed as ckscribed,backfffl,and compaction of the'vertical anchor trenches (if applicable)lake place. L Verify that the HydroBinde0k) is at minimurii perfonnance'levels within 24 hours, 105 DOCUMEN"FAI"10N k Docurnent daily,observations of the deployment and searning operations. 106 REPAIRS A, Verify that all darnaged areas,or holes are repaired with a patch that extends 2 feet beyond the edge of the damaged area or hole. 107 COR RECTIVE M"HONS A, I rany portion(s)ofthe engineered turf components do not meet the requirements ofthe Plans- mid 1'echnical Specifications, based on either observations and/or Physical measurernent, verify that that portion(s)is repaired or rernc)ved and replaced to meet the requirements of the Technical Specifications arid that the corrective actions implemanted by the Contractor are iri conforniance with !methods approved by the Design Engineer and the applicable Standard Specifications, END OF("wQA SECTION 02773 ENGMEEIZEDTURF Llprq mq'M X'knum I'kufCQA ftn"CQA 02773 Engineemd Turfdov FhW Clomurt,Consiruefion CQA P'lan EWA AJgual 2015 02773-5 Page 3571 of 4165 CQA SEC11ON 02900 SEEDING AND FER,rn,[ZING PART I GENERAL 1,04 SUMMAI�Y A. The CQA Officer s4all perform CQA procedures as oudined in this Section and Follow guidelines for monitoring and testing to verify and doctunent t1lat revegetation materials and pal acernent methods are in,cornpliance with the Plans ,md'lechnical Sp ecification& 1.02 SUBMITTAL,S k Collect t1irce (3)copies of each submitial required in tbeTceltnical Specifications, & Verify compliance with thesubmiltal schedule and, update Subrnittal L,og. Perform sulirnittal review and approval procedures in Pan 1.03 of Section 01.300(Sub"littals) I of thus CQA Man, PART 2 PRODUCTS 2,01 REVEGETATION MAT17RIALS A Verify that the following revegetation materials meet the applicable product requirements of Section 029010 (Seeding and Fenifizing)ofthe Technical Specifications: I, Seed, I Fertilizer. 3, Tack.ifier. 4. Fiber, B. Ved rythat&rtili7er conforms to Section 20-2,02 of the Standard Specificat ions, C erify that seed confornisto Sect ion 201-2,1,0 of the Standard Specifications,, Dm eri Fy that fiber andJor stabilizing ernu Ision, if used,conffinns,to,Sections 201-2.017 and 20- 2,11, respectively, ofthe Standard Specifications. PART 3 EXECIAJON 3.01 PRI PARATION A, Prior to beginning of revegetation activities,, hold a preparatory meeting in accordance with Part 1.04 of'Section 0 t 039 (Project Meetings) of this CQA Plan, B edfy that the niethod and equipment to be used to spread the seed,fertilizer and mulch has 'been approved by the Design Engineer. C, Verify that the access roads,drainage structures,,gar d eros ion-resistom layer have been placed 9'1wACQA 079W)SwAmg and FhW Closury Cansip actim CQA Kin EWA A uywl 20 15 02900'-1 Page 3572 of 4165 to gnide before seed, fertilizer and mulch is applied and verif + with the Cuntractor that revegetation shall not occur on the access roads, lined drainage swales, and sedirrientation bas i n s. 3.02 APPLICATION A Verify?that seed and feTtilizer(including fiber anid/or stabilizing emulsion, if applicable)are applied to,the areas designated on the Plans. R Verify that all products are sp,read unil"brimly over all areas sub ect to revegetation. J 103 ("ONFORMANCE VERIFICATION Aa Verify application rates on as daily basis for the respective materials by comparingthe:amount used(as deleirnined from weight tags,) to the toW acreage covered. 3,04 CORREC'FIVE ACTIONS A, I:f°aaiiyportuoaa(;,f of~tlae seealira. ,aauu¢f fv rtifizing provisions do not meet flue'requirements,of the Plans and Tectmical Specifications, based on either observations nand/or physical measurement, verify diat that portion(s) is reworked or removed and replaced to inect t�he requirements,of the'rechnical Spec i fication s and that the corrective actions implemented by the Contractor are in conformance with nwthods,approved by the Design Engineer and the applicable ftan&ard Specifications. END OF CQA SEC,nON 02900 SEEDINGAND FERTILIZINGY PWICQA 02900 SuAffigand FaWizuRgADC, N-IW(3usum Ccmmanokyti C,QA�Man FRA E'np,Mvering Auguv 2M 0:2 001-2 Page 3573 of 4165 (,',',QA SEC'110N 02960, TEMPORARY EROSIONAND SEDIMENTCONTROLS PART I GENERAL 1.01 SUMMARY A The CQA Officer shall perform CQA procedures as outlined in, this Section and f6flow gui(feline f(,)rtnonitoringan itestii-igioverify,i,uiddoctin,icrnl!th,,i:ttlietempu!)rwwcrosiona!nd sedin-tent controltnaterials and installation methods are in compliance with the Mans and Technical Specificatio!iis. 1,02 S1<.iBMI71"TALS USED) PART 2 PROD(Wrs 101 EROSION AN'D SE11IMENTCONTRO1.C.OMPONENTS A, 'Verify that the following erosion and sedirnent control corripoiients meet the applicable prodijct requirernents of Section.02960(Temporary Ero ion and Sediment CornTols)of the 'reclinicA Specifications: L Straw bales, 2. Straw wattles. 1 Silit,fencing. 102 ROCK FOR.CONS TRUC11 ION ENTRANCE k Verify rock conforinance unider CQA Section 02207(Agg rep ate Materials)of this CQA'Plan. PART 3 EXECUTION 3.01 PREPARAT'JON AND SCHEDUL11' A. prior to beginning installation of any temporary erosion and sedirnent eorntrolll components, hold a preparatory jocieting in accordance Nvitb Pail t.04 olf Section 010 (Project Meetings) of this CQA Plan, B,, Verity' that the Storm Water PollLIG011 Prevention Plan (SWPI)11) has, been prepared by a Qualified WPPP Developer('QSD), been submitted to the State Water Resources Control Board,and that a WDID number has beevi received f.or the prqjecl. C Verify that, temporary erosion and sediinent,control meamires are implemented year rowid during the cotirse of the Project,and that teniporary erosion coritrol features are installed and 'maintained between OcUker 15 and May 15, of each year. 102 PROTECTION k Veiify that temporary erosion and seditrient control measures are iiinplemented in all areas of exposed earth created by the Contractor beym)d wbat is shown on the Plans and refern,,d,to in CQA MvmT,QA 02WTcmpomry FmOon Comrokk% Mum Cor0ruction C'QA Man EPA EngiryeevMg Auppiq 2015 02960-1 Page 3574 of 4165 the Technical Specifications and areas cleared and gn,ibbed prior to excavation or embankment operations'which are sulaject to wind erosion and runoff. 3 03 TEMPORARY EROSMN CONTROL FACILITIES A. Verify that the Contractor conducts his operations,in such a rnanner that stort'n water ninoffis contained within the Work site or channeled into the storm drain system which servies the runoff"area. B Verify that storn'i water runoff from one area is not diverted to another runoff area, C Verif that temponary down druins, drainage structures, and other devices are: provided to channel storm, water runoff water into the respective perniarient storm drain systerns during construction, Also verify that penrianient drainage stniclures, not fiffly completed, are modified as reqUired to accept de-silted runoff. D "erify that fill areas, wfifle being brought to grade and during periods oficornpletion prior to final construction,are j,')rotected by various measures to elinainate erosion and the siKati()n,()f downstrearn facilities and adjacent areas. F" Verif that contour graded areas art-,protected against erosion and the resulting siltatiull of downstrearn facilities and ad.jacenfa:rt-as during gtrading operations. F. Ver ifs that incorporation ofcuNert piipe used in corkjunction with temp orary crosion control measures for Flu I construction fixtprovementslias been apiproved by the Design En girlect, 104. CORRECT]"VE ACTIC)N'S A, 11' any portion(s) oil' the ternporary erosion and sediment controds does not meet the requirements of"thaw Plans and 'rectinical Specificalions, based on either f"Wid test results, observations, field survey, and/or physical rneasurennent, verify that tliat pioftion(s) is reworked or rernoved and replaced to meet the requirements, of the Plans and Technical Specifications and Jun the corrective actions implernented by the Contractor are in cont'onnance with nietborls approved by the Design Euigincer and the applicable Standard Specifications, END OF CQA SECTION 02960 TEMPORARY EROSION AND SEDIMENT CONTROLS Plani,02A 02960'rempoviry Eroum Umiirol doc Fad Ckysure Con.9inwakm CQM Man EHA Lngfuping Aupw 2015 02960-2 Page 3575 of 4165 CQ'A SECTION 0; �O ("ONCRETE PART 1, GENERAL 1-01 SJJMMARY' A. The (".QA Officer shall perfibirm CQA procedures as outlined in this Slection and follow guidelines for monitiming and testing to vernal"°and document that the concrete materials and construction methods are in compliance with the Plans and 'I'echnical Specifications. 1 M SUBMITTALS A Collect three(3)copies of each subminal required in the'Fechnical Spec iticati on s. B, Verify compliance with the sulbinittal s,iche(.fule arid, update Submittal Log. C. Perform submittat a"Cview and approval procedures fii Part 1.03 of Seuion 013010(Sohmittals) of this(,,QA Plan. PART2 PRODUCTS 101 (.',,ONCRETE COMPONENIS A "erify that the following concrete components meet the applicable pro luct requireiilents of Section 03300(Concrete)of the Technical Specificationi: L Concretc. 1 Rein forcienient. 31. Forms. 4. Epoxy. 2.012 A(.3GUGATE BASE A Veri aggregate base confonilance under,CQA Section 012207(Aggregate Materials)of this C'0 A Phan. 103 ENCHNEERID FILL A. Verilyeriginecred fill coriforinance under(.'QA Section 02224(Engh'ice red Fill)of this CQA Plan. 2.04 (40N'FORMANCE TES'I'ING k Review moisture-derisity relationship conformance test results for the ag gre ate phase g se as, detet-mined under(QA Section 02,207 (Aggregate Materials)of this CQA Plan. Fmf C'QA P1aT0CQA033M CWWOt&C Nnal Myom Cmurnainn CQA Plan E8,4 Augmt 2015 0,3300-1 Page 3576 of 4165 B, Vierify that concrete arid aggregate base Materials are, obtained from the approved sources throughlaut the Work. PART 3 EXECUIION 3.01 11RETARA'm I.)N A Prior to beginning construction of any drainage arid arosion control structure, hold a preparatoryinecting in accordance with Part 1,04 of'Section 01039(Project Meetings)of this CQA Plan. 13, Verify that than 1ocations and dinlensions of the concrete pads are as shown on the Plans or as staked by the Design Engineer. Cr!" Verif r that the footprint arenas fear the flare station concrete pads as,shown on the Plans are properly cleared alid gnibbled and that the underlying subgrade conforms to the engineered fill re,quirenlenti pier CQA Section 02224(Engineered Fill)of this CQA Plan. D' Verify that aggregate blase for the flare station concrete pad is spread in a uniforril loose lift not exceeding if inches in thickness,. E. Perforrn the t6flowing field tests at the frequency shown to ver,ify that the complacted aggregate base niaterial has an rnininium dry density of 95 percent(if the nlaximun-ldry density and is within I to 3 percentage points ofthe oPtimurn moisture content as determined froin ASTM D, 1557: 1 Lhj?gjtsiap qLw,(j.,A4,,,)ish4re Content- Nucleqr,(&�' 92.........2'and 1 7) 30 ;at least ... . one lest beneath each concrete pad. I MlVstarry Content tAST f 1) 59 luclear at least one (1) test per every ten 0), 1 gauge tests, J�" Record curresponding, dry density and knoisture content results on. the Nuclear DeTlsity/Moisture'Test Data form. 102 REINFORCEMENT' A. Verify that all reinforcernentis insuilled in confbrnlaance widl Concrete Reinforcing Steel Institute's(CRSI's), "MarlUld c,)f Standard Practice". B. Verif that al I reinforceirient is ftee (rorn nist, oil,dirt, or ally other coating. C. Vei-if`y that continuous reinforcing bars are lapped at splices at a mininauall of 32 diatneters. 11 Verify that reinforcenlenthas a minilnUM corweretc coverof'3 inches(unless offierwisenoted), E Verif` that reinfbircernent is, not damaged and is securely supported and anclicired to avoid movement during placement of concrete. C',(,?A Pkw',C'QA WNW Concre'lle,doc Final Chmm Cmlnic'6in CQA Plan E'13A Engineering Mqim 2015 031300-2 Page 3577 of 4165 3,03 FORMWORK A Verif °that the strength of concrete formwork is,sufficient to hold the concrete with mininial or no leak4ge and that shoring and bracnig is provided to,ensum stability of fonn.work,. & Verify that 3/4-inch charn&r strips are used at expo,sed corners. 3.04 CONCRETE SLAB,AND DRAIN INI-ET PLAC,'FIMENT A. Verify that the sub grade and f6niis are moisterled prior to Placing concrete, B,. Verify that care is taken to not darn age or displace the reinforcing steel coitiponents, C11. Verify that concmte is placed in a continuous operation and thoroughly vibrated to ensure consolidation around reinfbrccrrient. D Collect sarnples of the concrete to be used at the Work site and perfonn the f"ollowing tests to verif" that the concrete has the slunip and compressive strength characteristics sl)ecified in the Technical Spccffications: one rest per each concrete pour. i>n,t,11 L C, MIT—almA4 LIO. ...5tr. X zf..... �57'Alf 31 atid ASTU C 39j; one test per each concrete pout" E Verify that the final surfaces of the concrete slabs have a non-slip broom,finish. E Vexit that all significant cracks, smalls and irregularities in for'nied or finished surfaces or other defects are properly repaired or patched. 3.05 MINOR CONCRETE PLACIEMENT A. Verify that rninor concrete for post footings and the sedimentation basin's, drainage riser foundation are installed as shown on the Plans and in confonnance with Sections 51 and 90- 10 of the Standard Specifications,as applicable, K Verify that minor concrete for the grOLIted rock riprap is placed in confomiance with,Section 72,-5.04 of the Standard Specifications, 3,06 L�TOXY SECURED DOWELS OR ANCHORS A Verify that the dianieter and depth of the drill hole is as indicated. If not included,verify that the bole is drilled 1/8-inch larger and ten(10)tiTrtes deeper than the diatneter of the dowel or anchor. K Verify that the hole is thoroughly cleaned by blowing it out with,compressed air and by using a wire bru sh C. Verify that placement of epoxy in the hole is performed Using a dispensing tool provided by, or recominendeld by the manufacturer and that the hole,shall is completely filled with epoxy, 11 Verify that the dowel or anchor is placed in the hole and the epoxy allowed sufficient time to completely cure before disturbing the dowel or anchor. hjPf(:QA?NM(,QA 03100 Conructe&x FhO Cbmuo Cangtrumon CQA Plan UA En gin v,v r in R Augwi 2015 03300-3 Page 3578 of 4165 3,07 (,'ONI'ORMAN'04 VER III CKHON' A- After construction, vcrify by sumey that the flare station concmte pads are completed at the elevations shown on the plans. 108 CORRECTIVE A("l'I'I()NS A. If any portion(s) of the concrete provisions do riot meet die requil.rements of this Plans and 'rechnical Specifications,based on either field test results,observations,field sta-vey,and/or physical measurement,verifythattfiat port ion(s)is reworked or removed and rep kiced to,meet the requirements of the"recfmical Specifications and thalthe corre,,ctive actions implemented by the Contractor are in con f6mance with methods,approved by the Design Enginecrand tine applicable Standard Specifications. END OF CQA SEC710N 03300 CONCRETE TurrC(,M Pfian'COA WMO Concrcmdoc Hna GIDSUM CQA Mmi 'E"Rd A`ngineedn'g Augat 2015 03300-4 Page 3579 of 4165 CQA SECTION 151.00 1,.ANDFII,,L GAS (LFG) EXTRACTION WELLS PART I GENERAL 1,01 SUMMARY A I'lie CQA Officer sludl perform CQA procedures as outlined in this Section and, follow guidelines for nionitoring and testing to verify and document flial the ITG extraction well materials and construction methods are in clompliance with the Plans and I'eclinical Specifications. 1 A)2 SUBMI71"'FALS A, Collect three(3)copies of cacti submittal required in the Technical Steen ications, R Verif corni,?liance,with the subMittill schedule and update SubjuitW L,og. C. PexTonn subn-titfal rev ew and approval procedures in Part 1,03 of Section 01,300(Subinittals) of this CQA P'lan. PART 2 PRODUCTS 2.0 1, UG EXI"RACTION WELL COMPONEN't-s, A. Verify that the following IXG extraction %veli cornponents, rneet the applicable product requirement's of Section 15100 (1,andflill Gjas [LFG] Extraction Wells,) of the Technical Specifications: 1„ PVC well casing and fittings, 2. Bentonite 'deal. 3 PVC well bore sea]. 4, Prefabricated well head assemblies, 2.02 GRAVEI. PACK A^ erify gravel plack confionilance under ("QA Section 022017 (Aggregate Materials) of this CQA Plan. 2,03 SOII-, BACKFAIA, A. Veriry soil backfill confbmiance under CQA Section 0122510(Erosion-Resistant L,ayer)ofthis (,,'QA Plan. PART 3 EXECUTION 1011 PREPARAIION X Prior to 1J`G extraction well dirdling and installalion, hold a preparatory meeting in accordance with Part 1.04 of Section 010,39 (Project Meetings)of this CQA Plan, PJaRkCQA MOO 1 F0 Extrxoion Wefls,doc Finotf,30sure,ConMrudum CQA Man ERA fi!Vq#PWdC4"R Aijjpist 2015 151001-1 Page 3580 of 4165 R Verify that the 1-1.`G extraction well locations conform to the locations staked by the 11 1)esign Engineer. cl erify that a driffing pennit(s), if required, has been obtained by the Contractor, 11 Verify that drflling contractor is licensed(CBass C-57) in the State of California. E Ver4 that the Contractor understands that individual L.FG extraction wells inua be drilled and installed in a single day so as to tninit-nize tine potential fbr LFG emissions ftorn the borehole, In the event of equipment breakdown or other uniloreseen circunistance that-, prohibits complete installation of the ITG extniction well wiffiin the sarne workingday,verify that provisions are made to cover and sea]the exposed borehole at the sud"ace to prevent L,F'G emissions. 3,02 DRILLING A, Verify that the boreholes for the LF(3,cxtraction wells are drilled using a,bucket auger drill rig capable of drilling 24-inch diameter borcholes. B. Verify that a safety screen is placed over the top of the Iborehole as soon as drilling is completed and that the screen is kept in place until backfilling,is within 4feet of the surface. Verify that the safety screen size is large enough to acconiniodate all backfiJ I l mate�Hals,and activities yet not large enough for any human to accidentally fall through, C� Verify that: the borehole is straight and the well casing is installed in the center of the burchole, Verify that tine Contractor takes all tension,off of the pipe by mechanical means and centers the well easing in,the middle of the borehole before starting to backfill, D, Verify that PVC well casing joints are solvent centented and securedwith 3/8-inch longType 316 stainless steel lag screws. * 'Verify that, the completion height of the well casing above ground sutfaze is such that the finall height of the installed prefabricated well head assembly is 5 feet above firial grade, * Verify that the top of the casing is,capped Until bistallation of the prefablicated well head assernbly. G. Verif;y that spoils generated as pan of the drilling process are handle and rnanaged in conformance with CQ,A Section 02222 (Excavation)of this CQA Plan. H. In the event obst.nxtions,and/or saturated conditions are encountered during drilling, verif r that the Contractor makes a reasonable effort to drill through obstructions and saturated conditions and that abandonment of the borehole is not perfbrined without writterl approval obtained from the Design Engineer, 103 BACKFILLING A Verify that`the strength of concrete ficxnnrwork is sufficient to hold the concrete with minirnal or no leakage and that shoring and bracing is provided to ensure stability of forrnwork. R Verify that 34-inch charnf*er strips are Used at exposed corners. LAProjeCO11907"Clonwt T urrCQA PlanTQA'EMOO LFG Extruqbn Wdkdoe: Raal ansum Conurkm On OQA Plan EWA EfigoweHAq A uhpw 20 15 15100-2 Page 3581 of 4165 3.04 (.'ONCRE'1'1,-,"SI,ABANI-)DRAtN]Nl-,EI I PLACT,"MENT A Veri fy that back fij I ling operations cornmence irnmed iate ly after wel I dri l I i ng is,completed and the well casing has been instal led in the borehole. Veiif that backfill materials are installed as shomm on the Plans and as,directed by the Design Engineer. 13. Verify that the gravel pack is,poured or scooped through the safbty screen at a rate that wil I not endanger the integrity ofthe well casing. (11 Verify that the, per and lower beritonite seals are rorrned byevenly distributing the bentonitc material around the annu]US Ofthe well casing anid that fresh water is added in amanner that will allow f6r a thorough saturation of the bentonite. Verify that the proportion ofwater added versus bentonite material is in accordance with the bentonite manuflactur&s, recorntnendations. D Verify that soil backfill is Placed fiom the top of the lower bentonite seal to the bottorn of the upper bantonite sea] in a manner that wil I prornote self compaction and avoid bridging of tite soil back-fill rmerial, E VerifY that the PVC well bore seal is installed in accordance with the manufacturer's reconimendations around the well casing and placed at the location shown on the Pla,DS. F. Verify that the boot portion of"the well bore seal as seCUred around the well casing with stainless steel straps, to provide an air-tight connection, Following placement of erosion- resistant layer tnaterial,verif w(I'mt the boot is installed in a collapsed position above the final grade to icconimodate potential settlernent, G. Verify that the PV' well bore seal is covered with the overlying GC11. material or soil (tern porary)if the PVC well bo,re seal is going to be exposed for,naore that'i three )working days, 105 INSTALLATION OF PRI-''FABJRICATED W1,LL HEAD ASSEMBLY X Verify that the prefiabricated well head assemblies are handled and installed in accordance with the manuflacturer's reconiniendations and as shown on the P'lan.s. K Verify that the well head is installed such that the interior extension tube assembly is concerftric within the well casing. C, Veffythatthe final completion height of thewell headassemblyis 5 feet above final grade xs shown on the 1"llans. D, Verify that the PVC flexible hose conncction between the well head and LFG collection system piping is installed with sufficient slack(ti to 8 inches)to accorrunodate expansion and contraction. Verify fl-tat "IPS Weld-On 795"plastic pipe cement,or approved equivalent,is used for flexible hose connections tcu the Nvell head and LFG collection system pipling. 106 ABANDONMENTOF LFG EXTRACTION WELL,BOREHOLE(IF'REQ1 J I R f"D) A Verif'y that borcholes approved by the r)esign Engineer forabandonmentare backfilleldwith refuse and/or soil to the final grade and corripacted. If refuse is used, verify that the refuse is l'u.rl'CQA PhnKQA MOO LFG Kmraaba WuHsAm, hna�Gosm,0marmikin 47QA Phm EHA rmgmmeHng A urust 2015 ,15 100-3 Page 3582 of 4165 mechanically cornpacted within the borebole using the bucket auger to elfinimate pMentia] voids, B,. Upon conipletion of borehole abandonnicn(activities,verifythat the a rear.around the borehole is restored to meet the surrounding graxles as shown on the Plans. M7 PER FOR fail Aloll CETESTING A Veffy that perforniance testing of the prefabricated wc11 head assernblies is perfornicd in confiorniance with Section 15100 (1,andfill Gas [LFG] Extraction Wells) of the Technical Specifications. 3.08 CORRECTIVE A(I I IONS A If any portiOTI(S) of the LFG extnactiori well provisions do riot ineet tfie requirements of the Plans and Technical Specificatioris, based on either field test results, observations, field survey,and/or physical nicasurernent, verify that that p,ortion(s),is reworked or removed and, replaced to meet the requirements of"die: Technical Specifications and that the corrective actions implernented by the Cont�rac:tor are in conformance with methods, appr(nred by the Desigii Engineer and,the applicable Standard Speci rications. END OF CQA SECTION 15100 LANDFILL GAS (LFG) EXTRACTION WELLS Man"EQ2k p5100 LFG J'Nwaown wtkdoc rhA(lasurr Ganwu(IW CQA PUA LBA JEngineeriop August 20 5 15 1 O0-4 Page 3583 of 4165 CQA SEC-FION15200 LXG,cot,LEchON SYS'rEM COMPONEN,rs PARIA G'ENERAL 1,01 SUMMARY A, The CQA Officer shall peribmi CQA Procedures as, outlined in this Section and R.Alow guidelines for rymnitoring and testing toverif and doemnent that,the LFG collection system coniponent materials and construction methods are in conaphance with the Plans and Technical Specifications. 1.O2 SUBMIT"'FALS A. Collect three (3)copies of each submittal required in tine']'echnmeal Specifications. R Verify compliance with the submiUal schedule and. update Submittal Log. C Perfiorm submittal review and approval procedures,in P,,,ml 1.013 of Section 01300(Submittals) of this CQA Plan. PA 111' 2 PRODUCIN 10 1 1,R] COLLEC710N SYSTEM COMPONE.NTS A Verify that the Nlowitig UG collection systern components meet the applicable product requirements of Section 15200 (LFCXI Collection S stem Components) of the Technical Specificatiom L PVC pipe and, fittings, I PVC butterfly valves(isolation valves). I PVC ball valves, 4. PVC,"cement. 5 Vacuum test ports. HDPE pipe and fittings. 7, PVC-IIDPE transition coupling, K Flexible couplings. 9. St,tked pipe supports and anchors. 10 etal frarne pipe supports. 1l. Block type pipe support& 11 Cmp. 2.02 CONCRETE k Verify concrete conBortuance Under Ct A Section, 013300(Concrete)of this CQA I'llam 2,03 PIPE BEDDING A. Vr erif pipe bedding conformance Under "CAA Section 02207 (Aggregate:Matei4ials) ocf this CQA Plain, L mPfOj=V'907a 009=Turf'CQA PhiTK,Q A d5100 HG Colloclivin System Coffqwmrmmdou RnfaJ Cbmure ConankWon CQA Nn ERA August 2015 15�2010-1 Page 3584 of 4165 2,04 ENGINEERED FILL A Verify engineered fill conforniance under CQA Section 02224(Engineered Fill)of th (.;QUA. P la"I'l 2.015 CONFORMANCETESTING A, Review moisture-density relationship conforniance test residts for the pipe bedding and engineered fill as determined tinder, CQA Section 02207 (Aggregate Materials) and CQA Section 02224 (Engineered F'i 11),respectively, of thi s CQA Plan. PART3 EXECUTION 101 PI ERARATION' A. Prior to LFG collection system construction,hold a preparatory meeting in accordance with Part L04 of Section 0 1039(ProJect Meetings)of this CQA Plan. 3,0!2 LF(.3 COLLECTION SYSTEM PIPING A, Verify that the LFG collection systena piping, inchiding flexible couplings, isolation va�ves and condensate drop-out points are insualled as show]] on the Plans. if. Verif'y that alll PVC pipe, fittings, and valves are inspected for cuts, scratches, or other dainages prior to painting and installation. C erify that Prior to insufflation,all PV(."pipe and fittings to be left,ex posed care steam cleaned and allowed Io dry,then painted in conforniance with Section 15200(IT(I'Collection Syst in Coinponents)of the'rechnical Specifications, D; ''erifythat PVC pipe, fittings and valves are joined wil'h socket and solvent cement welding in accordance with ASIN D 2855 and that thejoining ofPVC pipe, fittings,and valves are 41 accordance with the pipe manu fileturer"s recommendations and the"recturical Speci fications, Venfy that PVC pipe cutsarre square and perpendicular to the centerthie ofthe pipe and that PVC pipe ends Eire beveled prior to applying ptinier and solvent cernent so that the primer or cement are not wiped off during iliserlion irito the fitting socket. F. Verify that all burrs,chips,etc, generated as a res'ult of cutting operations are rennoved from the pipe interior and exterior and that the inside of the piping is kept cleari of dirt and debris. Alsoveril that any piping left(,wenfight is capped., G, Verify that as coating of CPS I'ninier as recorntnended by the PVC pipe supplier is applied to the entire interior surflace ofthe fiti inn socket,and to an equiva,lentarea on the exterior of the pipe prior to applying solvent cement. U 'serif" that the solvent cement used coniplies witli the requirements of ASTM D 2564 and is, applied in str�iel accordance with rnanufacturces specifications. Man'CQM 1520 LFO 4 ollcv6on Sym=Compimaimdoc FuW Clusare Cw tructina(X: A Plan rBA EngMeerMg, Augum 20( 5 15200-2 Page 3585 of 4165 L Verif'y that PVC pipe,fiffings and valves are not pi-irned or solvent welded when it is raining or when arribilent temperature is below 40T or above I 00"T, 31. Verify that after solvent welding, the PVC piple, fittings and valves are allowed to rentain undisturbed unfil cenient has thoroughly set. K Verify that flexible couplings, are installed at the locations shown on the Plans and that the flexible coup lint gscare installed per the pipe separ-ation criteria s;pecilled in the Plans based on the arriblient temperature at the time of iristallation. Also verify that stainless steel band clanips are,secured around the ends of the flexible coupling in such as manner asto.provide an air-tightjoint. 11. Verity that vacuum test ports,are,installed at the locations and orientations show on the Plans and in accordance with the procedures described in Section 15200(UG Collection System CorriP anents)of the Technical Specifications. A Verify that staked pipe supports areinstaHed under I,he selected pipe seginerits as specifiecl on thile Plans, and that they are, spaced at 10 :feet on-center along the full lengh, of the pipe sleginents. A]so verify that the freight of tbe pipe supports are adjusted as appropriate tc) ensure positive slope of LFG collection system piping and that the stakes are driven no less than 12 inches and no more than 18 inches below final surface grades,. K Verify that blocl,< tyupe pipe anchors are installled at the intervals indicated on the Plans, as well as at the locations of all tee, elbow and wye fittings (both, ends, but not on the fiffings themselves)and at flexible,couplings located on slopes as shown an the Plans and that the pipe clamps are secured around the LFG headersystern,pipe t(�)ensure, that the pipe does not MONIC. 0 Verify that metal Crarne,pipe supports are, installed at tfie locations shown on the Plans and that the height of cross-barpipe supports are adjusted as appropriate to ensure,pnositive slople of LFG collection system piping. Verify concrete placement conformance under (,( A Section 03300 (Cl oncrete) of this CQAT)lan. 3,03 BURfED HEADER CROSSINGS A, Verify that trenching across bench sections care to the depth and dimensions shown orn tile Plans. B. Verify that LFG coilection systern pipinig is sloped at a, ni,it')finurn or3 percent to mairitain proper condensate drainage capabilities, ('11. Vetify backfill conformance tinder CQA Section 02225 (Trenching and Backfilling) and perf'oni'l,the Following field tests, at the frequency shown to verify that the compacted pipe bedding arld engineered fill have a nifilArnurn dry density of 90 percent of the maxiiiiiini dry density and is within I to 3 percentage points ofthe optimurn inoisture content as detennined fi-orn ASIM D 1.557: 1 'Dr,i,,De,ti star ao�idAlloivtureCot�tep,it-Nu,c..I..e..ar, ISTA/f D 2922 and D 30171, at least one(I) test per- 100 finear feet per I ift. I Moisture ConLuLt L k jj at least one (1) test per every teri (10) nuclear - gauge tests. D. Record corresponding dry density and moisture content results on the NLI,clear ManTQA MI(W LFG Collecom Syge.mCompnows,doc, Thal ClIosura ConsRrudian COA Man ETA Envincering Aujpwa 2015 152010-3 Page 3586 of 4165 Density/Moisture Test Data- form. 104 R(.)AD CROSSYNGS A, Verify that CMP pipe SUpports and protective sleeves are installediri the orientations shown on 'the Plans and that the CMP pipe supports, allgned with the: center line of the drainage swale, B. Verify that reinforcement geotextile is Wrapped,arOLInd the CM P protective sleeve where it will be in,direct contact with the underlying CM P pipe support. Verify that LXG collection system Piping is inserted through the CMP protective sleeves in a manner that does not darnage or compromise the LYG collection system piping. D. Verify engineered fill placement confbrmanice tinder CQA Section 02224 (Engineered Fill) and perflorni the following field tests at the frequency sbownto verify that the corripacted engineered fill has a rrdnirnurn dry density of 90 percent orthe rriaxiinurn dry density and is with in, I to 3 percentage pt.)ints of the optirnurn moisture content as deterniined from ASTM D 1557: 1, Da Density a d Miistui e Content- Nu, I& .&LS�7]IL I at least -q,nd,Alloistur f M Q 2922.and-D-101a; one(1l)test per 100 linear feet per lift. 2, MWvture ntent 64STAI D 49591; at least one (1) test per every ten ('10) nuclear gauge tests, E Record corresponding dry density and moisture content resnIts on, the Nuclear Density/Moisture,Test Data form. 3,05 CONDENSATE DRAIN PIPE AND FITTINGS A. Prior to installation,verify that a HIMP,pipe and fittings are inspected for cuts,scratches,or other darnages andfliat pipe and/or fittings with irnperfections are not u sed, B. Verify that trench excavation and backH for buried HDPE pipe and fittings are as shown on, the Plans. C. Verify that HDPE pipe connection ends and fittings are joineat by butt fusion Procedures in accordance with the HI)PE pipe and fiffing rnanufacturer's,recorriniended procedures. D, Verify during construction that the IIDPE pipe is not bent to a degree greater than the minimurn radius recomr-nended by the manufacturerand that the 1IDPE pipe is not SuLupectcd to straiDS that will overstress or Inicklie Piping or impose excessive stress on joints, L Verif that operi ends offitsed III PE pipe are covered or cap peal at the end ofeach working day to prevent entry by anirnals or olebris. R Verify that suflicient slack is provided for segments completed above ground to allow for thermal explansion and contraction san as to not promote excessive stress on the piping following installation. UtiVmjor,090T,Xloauye TurfCQA PtmWQA 1520 LFG CollecGon &w Fhml Chisam CoWmclion COA III= AXA Rag0eering ARASim 2W5 15200-4 Page 3587 of 4165 (31 Veri ry that allowance is provided for thernial expansion or cons naction olburied RDPE pipe Within trenches and is coordinated with thiu pipe backfifl operations to avoid NdIdup of thermal stresses. III Verify that sufficient titne ;per manufacturces recorrinlendations), is provided following placement of'111RE pipe to allow the pipe to,adjust to trench ternperattire prior to testing, segment tie-ins, or backfilling activities. 3,06 CONDENSATE DROP-OUTS A. Verify that the condensate drop-outs,including-ti-trap assemblies,are installed at the locations and to the diniensions,shown on the Plans. B. Verify that',excavations are not deeper than necessary to maintain adequate buMr above the underlying GCL. (11, Veri y that the transition Crmn PVC to HDP,E is conducted at the flange connection as shown on the Plans. D, Verify PVC,and HDP[�',Inpe, fittings and valvesinstalladon confimnanceunider flails,3,01 6Ivild! 3.05 of"this Section. E Verify instAlation o"I'staked pipe anchors at various points on the u-trapi piping as S.1-jown on the Plans. F Verif"y that the u-trap,asseniblies are filledwifli clean water f6flowing construction and prior to start;of LFG collection system operations. 3 07 CONDENSATE DISCHARGE POINTS A. Verify that the Condensate discharge points are installed at the locations and to the dimensions shown on the Plans, R Veri,wy soap anct/or relbse excavation and handling conforrilance under CQA Section 02222 (Exczivation) of this CQA Plan, C% Vcrify PVC and FIDPEpipe and fittings installation.conformance tinder Parts 3.01 and 105 of this Section. 11 for condcrisate discharge points located within the hinits of the firma] cover systern, verify placement conforTnarice of the engineered fill and respective final cover system components ablove the condensate discharge points per the applicable sections of this CQA Plan. E 1aor condensate discharp,e points l.ocated outside the limits of the final cover system, verify engineered fill, placement contbi-mance under CQA Section 02224 (Engineered. Fill) and perforiii the following field tests at the frequency shown to, verify that the conipacted engineered fill has a minimi,=dry,density of O percent of the maximurn city density and is within f to 3 pereentage points of the optirrium moisture content as detennined from ASTM D, 1-5-5 7: Da 2eji,m Moisture (,ontent - Nueletir�ASTU 0 2 9-72 itz L)jf I t least ............................ a one(1)test pier 100 linear feet;per H. Uqxon=E'X'ACkk�e TuITQA PW0,CQA 6 5200 LFG CoUbation SyMem CAmnponena ,dou Fmal Ckwun Cananxilon C,QA Plan E&A Aupsu 2015 15200-5 Page 3588 of 4165 2. Moistiov Content MYTill L) 4959j" at least one (1) t A per eveiy ten (10) nuclear gauge tests, 1"7" Record corresponding dry density and moisture content results, on the Nuclear Density/Moisture,Test Data fonm 108 111-HRIFORMANCA.,."TESTING A Verify that perforrnatice testing of the PVC ,I,,,I,'G collection systein pipe,HDPE,condensate drabi f)ipe,and condensate discharge points is performed in conforrnance with Sectiorl 15200 (LFG Collection System Components)of the'fecbnical Specifications. 3,09 CORRECTIVE ACTION'S A. If any portion(s) of the LFG collection system components, provisions, do not meet the requirements ofthe Plans and Technical Specificatioris, based on either field test results, obsetwations, field SUrvey, and/or physical measurenient, vedf that that portion(s) is reworked oir renioved and replaced to,nicet the requirements orthe Technical Specifications an(] that the corrtxfive actions imp leniented by the Contractor are in conformance with methods approved by the Design Engineer and the applicable Suvidard Specifications. ENI) OF CQA SEcriON 15200, LFG("OLLECTION SYSTEM COMPON ENTS Tgrf CQA P1&nTQJ%B2,00 LFOCd"-don SymcnRCmqwnmm%(k)c Fitud Uomac Com'drucGon CQA PLaa h"BA fi"'ngeaveryng Mguo 20�5 15200-6 Page 3589 of 4165 CQA SECTIONA5300 FLARE STATION PART I GENERAL 1,01 SUMMARY A 'Fhe CQA O,fficer shall perform CQA procedures as OUtlined in this Section arid follow guidelines for monitoting arid testing Co verifyand domirl'ient that the flare siziltion materials and construction methods are in compliance with,the Plans and 'I'echnical Spceifications, 11.02 SU-13MI'ITALS A Collect fliree (3)copies of each submittal required in the'Fechnical Specifications. B. Vcrif compliance witb the subniittal schedule and Update Snbraittal Log, C. Perfomasitbrnittal revilew and approval procedures in ['art l.03,of Section 101300(Submittals) of this C'QA Plam PAR1T 2 PRODUCTS 2.01 FLARE S'1A'1'ION COMPONENTS A Verify that the l'ollowing flare station components mact the applicable prod'uct requirements of Section 153,00(Flare St�ation)oftlieTechnical Specifications: I. Skid-niounted packaged combustion systern. 1 Electrical conduit, wire and fittings. 3. Chani link fence. 102 PVC PIPE, FITTINGS NND, BALL VALVE A Verify PVC pipe, Fitthigs and ball valve confomiance under CQA Section 152010 (LFG, Collection Sysumi Components)of this CQA Plan. 103 PIPE BEDDING A,., Verify Pipe bedding conforrnmice under C',QA Se:ction 0220,7 (Aggregate Materials)of this (.,'QA Plam 2.04 ENGINEERED FILL A, Veflf °engineered fill conl"Onliance under C.`QA Section 02224(Engineered Fill)of this CQA Plan. PWnWQA TMUK)Flare Swkm,dov rhW Clown,OomMud km CQA Nun ERA Lngineving August 2015 15300�-t Page 3590 of 4165 2.0 CONCRI`�"TE A Verify concrete conf6rniance under CQA Section 033010 ((,oncrete)of this CQA Plan 106 AGGRECTATE BASE A, Verif aggregate base conforn'tallee under CQA Section 02207(Aggregale Materials,)of this CQ�A Plam 107 (',ONFOR MANCE J`ESFING A, Review moisture-density relationship conformance test results fbi, the aggregate base as determined under CQ,A " ection 02207 (Aggregate Materials)of this CQA Plan. PART 3 EXECUTION 3,01 FLARE STATION ASSEMBLY A. Igrior to flare station assernbly activities,hold a preparato me:eting in accordance with Part L04 of Section 0103 (Prqject Meetings) of Marra CQA Plan, 13, Verify that Contractor has obtained all required building permits. (1, Vejffy that Contractor's iaborers are skilled and experiericed in, the installation of sirrular equipment. D "erify that the skid-mounted packaged combustion systern is installed in strict accordance with the specifications. 3 M CON DENSATE DRAINAGE LINE A. Verify that the condensate drain line between the flare station and leachate wet well is ii-istalled, as shown on the Plans. & Verify trenching and pipe bedding conformance under CQA Section 012225 (Trenching and Backfilling)of this CQA Plan., ' Verify PVC pipe,fittings and ball valve installation conformance under CQA Section 15200 (LFG Collection System Cornponents)of this COA Plam 1). Verify that the condensate drainage line is installed at a niii'vitnum slope of ] percent in the direction of the leachate wet well. E erify that the condensate drainage line Penetrates the wal I of the leachate wet wel l at the appropriate depth and that the antrular space between the condensate drainage line and the wall of the leachate wet well is,sealedusing non-shfink grout. R Verify engineered fill placenient contbrinance underCQA Section O 4(Engineered Fill)of this CQA Plan, I udCQA Plan'14JQA MOO Flare Stawmd,Dc Pima Clowe Conmucam CQk Man EBA Enginektriar ,August 2015 153010-2 Page 3591 of 4165 3,03 SECURJ'l'Y'FE'N('7E A, Verify that the chain link fence and gates are histalled as shown on the Plans and in accordance wiIIIII the requirements of'Section 804.02, of the Standard Sp,eci ficat ions. K Verif that all line, corner, and gate post assemblies are constructed with concrete post rootings, C. VeiiCy that soil between fence posts, is leveled to create a 2-inch, clearance Under the fence fabric. 104 RARE,, STATION AGGREGAII BASE A. Vefil; that the aggregate basewithin and around the flare station is placed to the dirriensions shown on the Plans. 13, Verity that the aggregate base is spread in, uniform loose lifts not exceeding 8 itiches in thickness, C Ilerfim-rn the ffillowing field tests at the frecluency shown to verif that the conipacted aggregate base inaterial has a minimmil dry density of 95 pereent of the maximum dry density and is within, 1, to 3 percentage points oftbe optirnum moisture content as deterniined from ASTM D 1557: 1 Dr,,Deo'tsitv andVoisfure Content - Nticlear(AST M D 2922 and D 301 a; at one test per eviery 1,200 square reet, I Molsho-c ("oil S711 Q 49 L ; at least one (1) be st per every ten (10) nuiclear — , gauge tests. 1), Record corresponding dry density and moisture content results on the Nuclear Density/Moisture Test Data fonn. E. Verify that the final complacted thickness is a minimurn of 6 inches, M5 PERFORMANCE Tl.�"STJNG A VeTif)a that performance testing of the skid-mounted packaged corribustion system and condensate drainage line isperfonned in conformance with Section 15300(Flare Station)of the Technical Specifications. 3.06 CORREc"rIvEACTIONS A. I fany pottion(s)of the flare station provisions do nat rneet the requirements orthe plans and Technical Specifications,based on either field test results,obsmations,field survey,ancl/or pbysical meastirement,verify that that portion(s)is,reworked or removed and replaced to meet the requirements,ol"the'I"echnical Specifications and that the corrective actions implemented by the Contractor,are in conformance with niethods approved by the Design EIngincerand the applicable Standard Specifications, ENl � CQA SEcriON 15300 FLARE SIATION cQi�P Wi,CQA WsOO 11are S1a&4{w4joc Final Oasure(.,4,mm"qkjn�CQA Man VM Eng0mmIng A qum 2015 153010-3 Page 3592 of 4165 CQA SECTION 15400 FLARE S]11 ArIONELECTRICAI, AND 'FELEPHONE FEED PART 1, GENERAL i_0 1 S U'NIMA R Y A. 'I"he CQA Officer shall Parformi CQA procedures as outlined in this Section and tbIlow guidelines for n-ionitoring and testing to verify and docutnent,that the flare sultion electrical and telephone f`eed malerials and installation methods arc in compliance with the ]-%ns and I I echnical, Specifications, 1,02 SUBMa"i'ALS, A. Collect three(3)copies of each sub�imittal required in the Technical Specifications. B. Verify comphance with the submittal schedule arid update Submittal Log. Cl. Perform submittal review and approval procedures in Rart 1,03 of Section 0 1300(Submittals) of this CQ�A Plan, PA R'"r 2, PRODUCTS 2,01 E.LECTRICAL ANIYIT'�LEPTIONT," FEED COMPONENTS A Verify that the fifflowing electi1cal and telephone fced components meet the applicable product requiretnents of Section 15400(Flare Station Electrical and'Yelephone Feed)oft,he "recimical Spec i fications: 1'. Wire, 2, Conduit and fittings. 1 Meter socket. 4. Jumfion and outlet l�.noxes. 5. Waming tape. 2.02 PIPE BEDDING A, Verify pipe bedding confbi-mance under CQA Section 02207 (Aggregate Materials)of flans CQ�A Plan, 2,03 ENGHNEEREI)FILL A. Verify engineered fill conformance under CQA Section O 4(Xmgineered Fill)of this CQA Plan, 2,04 C',ONCRETE A. Verify concrete conformance under C ection 03�3,00 (Concrete)ofthis CQA Plan. NaMCQA 15400 Ram Stj:laury klm,,�6W Fvm%R doe Hnd Clown:OmOvuAlAian CQA Plan Auhust 200 l 5400-1 Page 3593 of 4165 2,05 CONFORMA'NCE TESTIN'(5 A Review m6sture-density relationship conformance test results for pipe bediding and the engineered fill rased for backfilling the tawnier leachate pond as, determined under CQ,A Section 022,017(Aggregate Base)and CQA Section 0222'4(Engineered Fill),respectively,of this CQA Plan. PART3 E WECUTION 3,01 GENERAL, A, Prior to electrical and telephone fleed installation,bold a preparatory meeting in accordance with, Part 1.04 of Section 0 1.039(Project Meethrgs)of this CQA Plan. R Vedly that Cantractor has obtained all reqtfired electrical permits, CI ' 'ern fy that Contractor has furnished and installed al I ternporary power and lighting systems needed for construction and their subseqtient removal after constniction is completed. D, Verjf r that,Contractor has verified that the wire and conduft sizes for the main power supply and automatic telephone dialer systeM are,appropriate for the intended iise, E. 'Verify that all electrical coniponents are in accordance with the National Electric Co�de (114EC'), National Fire Protection Association, (NFPA) and local codes and regulations for installation in a Class 1, Division I or Class, 1, Division 2,classified locations, 1", Verify that electrical and telephone feed instaHations are perfix-ined in accordance with the local electrical and telephone company Tales and regailations, G Verifr y that the electrical and telephone feed from the existing service points to the flare, station control panel is completed below grade as showir on the Plans, 1-11, Verify that Contractor has confin-ned service and Panel locations and alll other service requirements,pTiOr.to Starting WOtk, 3.02 PREPARATION A, Verify that all materials are inspected for darnage and irriperfecdons prior to installation and that daniaged materials,or materials wilh irriperfections are riot used. 103 'FRI,'�N("'l IING AND BACKFILLING A. Verify trenching and pipe bedding placernent conformance tinder CQA Section 012225 (Trenchilig and Back.filling')of this CQA Plan. B, Perfori'n the following field test�s,at the l"requ,ency show ir to verify that the cornpacted,pipe bedding and crigineered fill have a mininium dry density,of'9O percent of the ma imam dry density and is at as moist-nre content within I to 3 percentage points of the optirrium moisture: content as deternriined front ASTM D 1557: PUnW,QA 154M)11fre Swim Ukdrical and I'deplione Feadhot 17hal CWum Constmutian OQA Plan I'Ad Enginee'ring Aupa 20�5 154001-2 Page 3594 of 4165 one (l) test per 100 linear feet per Lift or at a change in material. a Moisture ontent a at least one (1) test per every tern. (10 nuclear gauge tests. ti:`. Record corresponding dny density and moisture content results on the Nuclear euasi y/ oisteure Test Data pones, w Verify (hat all equipment, motors„ eas°�duit and outlets, as applicable, are pa rraaanently and effectively grounded in accordance with N'Et , California Adininistrative Code(CAC)-Title 4 and local codes. l:';f. Verifythat all conduits are sloped towards pull boxes and run in straight lines,except.where a change in direction is necessary. Also ver•it`y that couplings are staggered firr oaanairrnuurra d:rret line stren lr.. C Verify th.,,at, the ends cal"tauuried eoruduuit are kept closed with approved conduit seals during construction and tlunat."n:rrunnediately prior to pulling wire o;rcable,a swwraln is drawn tlurc.Ugh all. conduits to fanree out water and foreign materials. R Verify that junction boxes, are irnstafled in an accessible loeartionu as required for splicing, connections and pulling of"wire. E. Verify that all above ground conduit is properly secured on pipe supports or,concrete slabs, F Verify that the meter socket instal led at,the existing service pole eou is lies withthe hei tnt arrurd. fastening specifications outlined in the local electric eornpaany rules and regulations, 3.05 CUAN-UP eaafy that all exposed pnorfiouns of elleetrieal installation are thoroughly cleaned,i:a'rch'idirag the removal of all truces of soli.l, labels„grease,oil„ and other foreign matter. 3,06 CORRECTIVE ACTIONS l:farny portion(s)of the flare station electrical and telephone feed provisions do not meet tine requirements of flue Plans arid Technical Specifications, based an either Field test results, observations, field suu veayA, and/or physical al measurement, verify that that partionn(s) is reworked or removed and replaced to anaeet the recpnnirenane nts of"tine Technical Specifications and that the corrective actions irrnpaleaunernt;ed by the Contractor are in eounforanaarnee wwnitln n:nnethods approved by the Design Engineer and the applicable Standard Specificdtions. END OF CQA SECTION 15400 FLARE STATION ELECTRICAL AND TELEPHONE "gip A".,c,•i`A17 k:bco-un�uva FuTI C'OAe P1arxa C',1 A%5400 Mom S"VaUCWD B!AATiiCW Arod'1:"ei1rptluMV euCud.¢6 X Flih]4.%urt me t;onstrr,uctia ar(X)A k61bn l 010-3 Page 3595 of 4165 CQA SECTION 1550O [XACHATE OVERFLOW COLLECTION AND STORAGE SYSTEM PARTI GENERAL 1.01 SUMMARY A. The CQA Officer shall perform CQ)A procedures as outlined in this Section and follow guidelines for morfitoring mid testing to verif and docurrient, that the leachate overflow collection and sLora ge systern niaterials and construction methods are in compliance with[lie Plans and'I'echnical Specifications. 1 02 SUBM111"I"Al',S A Collect three(3)copies of each submittal required in the Technical Specifications. & Verify compliance with [lie submittal scheidule and update Submittal Log. C Pertimn m.rbrnjttal review and approva,l proccdares un Part 1.03 of Section 011300(Submittals) of this CQA Plan. PARS' 2 PRODUCTS 101 C OLLECTION AND STORAGE, SYSTEM C.'ON11110NENTS ,A. Verify,that the fol km(ing leacbatc overflow collection and storage system corriponents meet the applicable, product requirements of Section 155010 (Leachate Overflow Collection and Storage System)of the Technical Specifications: 1. P'ipe:niaterials. 1 Pipe accessories, 3, Concrete junction b�oxes. 4, Uning material for leachate sediment chamber/wet well, 5 Leachate I JST'and accessories,. 102 1 [PE7 BEDDING A Verify pipe bedding conformance under CQA Section 022017 (Aggregate Materials)of this ,CQA Plan, 103 TANK BEDD1`N(3AND BACK11111. A 'Verify tank bedding and backfill confbimance under CQA Section 012207 (Aggregzfte Materials)of this CQA Plan. 104 ENGINF�TRED FILL A, Verify engineeral fill confionnalree under CQA Section 012,224,(Engincered Fill)of this C,QA Plan. PI COC k MOO Lzarkme0yeTflow(k&cflom and Slomp symcni[Aw HnM(bumv Consinic6on("QA Plan Eftyf Emgigreerimg Auj,,um 2 0�5 15500-1 Page 3596 of 4165 105 (",'ONFORM.ANC',I�,� 'I'ES"l'ING k Review moisture-density relationship coi-O"orniance test results for the pipe bedding and tank biciddingand backfill as determined under(,.,,QA Section 02207(Aggregate Materials)of this ('(',)A Plan, (: . Review moisture-derisity relationship conformance test results for the engineered fill as I deterIllined Linder CQA Section 02224 (Engincered Fill)of this CQA Plan, PART 3 EXECUTION 3,01 BRACINCI AND S11ORING k Verify that Bracing and shoring complies with Section 5-1.02A and 7-1.01E of the Standard Speci 1,icat ions, 3.02 GFMRAL PHIE INSTALLATION k Vietify that Coritractor confinns the locaflon of point oficonnection (POC)i at the existing leachate collection piping as shown the Plans by potbohng to deterinine the location and depth (elevation). 13, Verify that the trench surf grade for the gravity drain pipe provides unifbrr'n support at a Unift)rm slope along lbil length of pipe. 103 PIPE INSTALLATION A, Verify trench conformance Lindier CQA Section 0122225 arenching and Backfilling), of,"tliis CQA Plan. B. Verify that the biottom of the trench is graded and prepared to provide a ftrrn and nnit"orni bearing througliout the entire 1crigth of[fie Pipe barrel, C. Verify that pipe, fittings, and accessones are installed in accordance witli 'manufacturer's instructions and that,the scalcidjointsarc %vaticitight, D Verify that pipe is placed to the lines and grades as shown on the Plans. 1- Verify that the pipe is Wd without break upgrade from structure to str,ucture, with bell end upgrade for bell and spigot pipe. F. Veiffy that thehori7ontal alignment of the pipe is laid such that no points vary more than 0,1,01 feet 1.rom the design aligninent established and shown on the Plans, G, Verify backfill conformance 'urider CQA Section 02225 (Treaching and Backfilling) and perform the following field tests at the freqyency shown to, verify that the compacted pipe bedding and engineered fill have as mininium dry density of 90 pie rcent of the rnaxiniurn dry. (tensity and is at a moisfin-e content within I t(,,w 3 percentage po�ints of the optinium moisture content as determined from AS,TM D 1 7: PbTACQ A B500 Lach'Me(haflow COB&tkm and Sioriage R'ySiermidoc AnA(liniffic Comonkclwon 0,1A Plan T"Rd Engincering A agm 20�3 1,55010-2 Page 3597 of 4165 I 12a DgLyUjLiL� ivhwe Content Muclear(4,j O�L12 at Icast one(1) test per 100 linear feet per lift or at a change in niatcriaL 2, Moisfure Conten(AS AI D 4959 at least one (1) test per every ten (10) nuclear gauge tests. if. Record corresponding dry, density and moisture content results on the Nuclear Den sit y/Moisture Test. Data florm. 3,04 CIO NCR I In JUN('TION BOXEIS A, Verilyexcavation conformance under C,QA Section 012222 (Excavation)of this CQA Man. 13 erify that concrete junction boxes are installed in accordance with inanufacturer's instructions and that their placement into the excavation is pleribi-mural in as rrmni3er that will not induce darnage or cornp.rornise future stability. C Verif y that backfilling operations conform to the provisions in Section 19-3 of the Stanctard Specifications, 3,05 LEACH ATE SEDIMENT .lot fill ERME'l WELL LINING C, Prior to start of Work, verify that provisions have been made to divert leachale from the existing leachate drain frorn discharging into the leachate sediment charnber and document how the leachate is being diverted and rminaged- 11 Verify that all leachate is purnped from the leachate sediment chamber and wet well and document where the It-achate is purnped and managed. E, Verify that any sediment present at the base of the Ileachate sedi-riieaitclia,n'i.iblerai'ld/or wet well is removed and document how the sediment is removed and managed. 1". Verify that existing pturips and any other equipmentQatures that niay inhibit applicition product are'rernoved and stored in a cityand secure location. G. ji Verify that the interior walls, and base of the sediment chaniber and wet well are steam cleaned to remove residual griine and residues. Also verify that residual rinseaie p,rcnerated by ,the stean-i cleaning operations is rernoved and docuinent how the rernoved rinseate is managed. I L Veril'y that sufficient thne is provided to al ow the surfaces of the interior walls,and base to dry and docurnent the nature of any mechanical means employed to expedite,the drying time, as,applicable. 1, Verif y that the lining product is app lied to provide full and sufficient coverage of all interior walls and base and that the application.is perfori3led in strict accordance with recon-mierkded manufacturer's procedures. L Verify that,,punips and any other equipment/features that were renioveld are re-installed and verify that normal operation of the: leachate sediment chan-iber/wet well, is restored per pre- existing conditions. 'ruxf(,"QA P1adX,QA 15500 L whale0vallow CcjkTkim and Sluragc Syacnmkiv Fnal Clomite Caminirl6n CQA Mon FIRA EovgWering kugw�2015 15500-3 Page 3598 of 4165 3.06 TANKHOLMN(i A. Verify that the tank,is riot drop ed,rolled or inipacled during unloaded and that the tank is set on smooth ground, Free of rocks and foreign ol�jeets, and chock tanks to prevent movement. 3,07 TANK INSTAI-LAJION ,X Verif y excawation conformance under CO ection O Excavation)of this CQA P'lan, K Vedf-y that!the(ank excavation,is large enough to provide 2 feet of clearance between the tailk, sides and ends and the excavation walls in stable soil and 12 inches of bedding under the tarik. C Verify that the tank and all related piping and accessories are:installed as per manufiacturer's printed.instructions. D, Verif that the tank bedding and backfill is placed in accordance with the Sequence ,Ind procedures outlined in Section 15500(Leachate Overflow Collection and Stomge System)of the"Fechnical Specifications. L Following placement of the tank bedding and backH, verify backfill conformance for tile reniainder of the excavation under CQA Section 02225 (Trenching and Bach filling) and perffirni the following field 'tests at the J.'requency shown to vefify that the compacted engincercd fill has a nifirimum dry density of 90 percent ot-the nuiximurn.dry density and is, with in I to 3 percentage points of the optitinuin moisture content as detemlined t1roin As,rm i.) 1557: 1 !?Aty ond MokstureIT (-Content-- Aly lear- 7 2 jSM'D 92 2 and D 30 1 a: at one .................. test per every 1,200 square feet, 1 Moisture Content , 15TA/f 1) 495() at least one (1) test per every ten (10) nuelear gauge tests. F. Record corresponding dry density and moisture content results on tile Nuclear Density/Moisture Test Data form. -1 1 3.08 P E RIFORMA NC F� '11'F"IS"IFING A. Verify that performance testing of flie teachate sedinierit charriber/wet well and,leachate UST is plerfOTMed in conformance with Section 15500,(Leactiate Overflow Co]lection and Storage stern)of tine Specifications. 3,09 (",'ORRECHNE ACTIONS A. If any l)ortion(s) of the Neachate overflow connection and storage system provisions,do riot meet the reqUirernents of the Plans,and Technical Specifications,based on either fiehitest resufts, observations,field survey,and/or physical measurement, verify that that portion(s)is reworked or reinoved and replace:d to Yneet the requirements ofthe Technical Specifications and that the coTrective actions implernented by the Contractor are in conforniance with methods ap roved by the Design Engineer and the applicable Standard Specifications. END OF, CQA SECTION 15500, I"Aprojec,090TC10sum I klrfCQA M='lCQA M)0 I CaChMeOvenfl®rW01*01on Ind$Wriqr SyVealdm E.6W Ooswr Owstruchan C10A flbn EHA Fqpmeering Augum 2015 15500-4 Page 3599 of 4165 Page 3600 of 4165 DA.ILYSUMMARYREPORT Project: Date: Day: Owner: Document Control No.: Contractor: Weather: AM Pm Construction Adivitv Construction UnWAreq: flicluj4pill t, Personnel: Subcontractors, CO�A Monitoring/Tetin SumMM (Amich h7spection I)ataSheelv or I)ai�v,Fieldb�,,,�) Non-Co n forma nee/Co rrective Action (Altach Non,-co,;Ili)i,inciticeIC(,)rrec,,,tive Action Form) Materials Received/Submittal Status ws L,t hir I 9—S Olther Information Signature: Page 3601 of 4165 Project: ate: Day:. Owner: Document Co drol No.: on-eonfor iance SqMmar ST)ecification or T rgwi l eferoraoe: Corrective Action. log.i1 . efieafion Variance or Drawing Revision: (Record any Drawing!Revision on the Site, s- malt Record Drawings) Signature: Page 3602 of 4165 ,A CCEP TA NCEREPOR T Project: Date: Day: Owner: Document Control No.: Contractor: All materials and construction processes l'br the Construction Unit stated below comply with the De sip, Plans and Sped fi cations. Const�rucLion UnitlSection No.1 DjLH � 'SuVim aELReRorts Referenced (Liv Doeume nt C'ontrol Nos) No.n-Cojifori,nance/Co�rrective!Aet Forms Refer enced (List Docunient Control Nos) Signature: .......................... Page 3603 of 4165 MEETINGIDISCUSSION SUMMARY REPORT Project: Date: Time: Owner: Docunie'ut Control No.: Contractor: Location: Attendees MLinutes, 'if scheduled meefingLor Sya2L)sis Items for Resolution Signature: Page 3604 of 4165 PHOTOGRAPHLOG' Pn ect: Date(s): Ro�ll No.: Owner: Contractor: DATE TIME PICTURE NO. SUBJEC"T MATTER Signature: Page 3605 of 4165 SUBGRADE SOIL SURFA CE A CCEPTA NCE ilroj-elc Date: Day: Owner: CQA Monitor: Document Control No.,; Contractor: Material Desc!i Nnnnn;, Cell No.: DLL Alion SOU Of I S'Ourfucc to be Lined:SMAL- I hereby certify that the above surface area is, suitable f r the il'istallation of geosynthefics, and that .....................fContractor and Ins tale y)...__ shall e rcspo.nsiblefor its integrity and suitability in accordance with ffie Specifications from this clate to the completion of tine installation Installer Representative. Signature: ..................... .............................................................................. Name: Date: 1"itle: R,epresenting. ............. .............. Subgrade Contractor: SignatUre: Name: Date: Title: R,ep�res,enting: ........................................................................... ............. witn"m CQ,A Monitor: Signature: Narne., Date: Title: RtT, resenti nag: ............. ................. ............................................ ................. Owner Representative: Signature: Name. Date: Title: R,epresenting: 7urfCQA MaMCQA FormsAppendix A4Mwl%muk,dcc Page 3606 of 4165 APPENDIX SOILS 'MONITORING FORMS Page 3607 of 4165 0 00 0 co M a) dUp I LU Lu I ' K A ' , '., rq� 5 lop o ' ., , �* 2 C a s Laja u a I0 J —L LO 0 rn 0 m M �ro o� CL sty LUfn a i I ',CL p� u� m, cs 41 QL dFA r� Piµ A 7 Rib ,..... ..... '..�+�rvrrrv.«. � gym....... A y � LLLL0 In W3 rip C '�w iL &., z, CL APPENDIX C FORMS Page 3610 of 4165 LO 0 M II I to LU iw LLm i of z o GEC E EP IS I (Attach field sketch of d Hy pane�l layout Project: Project No.: I 1,Abbiirevi iiu nis: Pan l(P), oll(i)„ eam(S), ro a rrm( ),Air Prey rare( )$Vacuum Test( Seam Analysis Sarnp$e(',S ) End of Seam'T' f S „Trial Meld TAW ,; u bgrade fare e l ,T°erru :eir tuure'T), Note( , Date: CAA Monitor:. Sheef' .. of Page 3612 of 4165 LO 0 M M tb I uj G+A LU WO 06 U i y M1V5 I 4YN air W CL o, Page 3614 of 4165 LO o T' m ............... m.. . .. ._.._. .e...._,. .-.----.-. a� i I I �nw St Ym^ C C 7-v d tir' �Y � q 9, wr ^u a ' a „n a nt � r a "r" r . c tz av S. CL ct c ry+ f Y„b B 9"h; GS 'L'' rP ±. 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I 1 Y,I i A I I 9' _ I I ea , Appendix C Examples of Artificial Synthetic Turf Used at Landfills Page 3624 of 4165 uuuuuuuuuuuuuuuuuuiiipuuuuuuuuuuuuuuuuuuuuuuuuuuuuugiipuuuuuuuuuuiiii IIIIIII@k Ill�i uum � III IIIIVIUIu Jli ®i / / ar, rrlf f o �� illfff, / ji j j Geosynthetic Solutions for Final Closure : A Decade of Performance By Mike Ayers ChA oal ash is the second-largest industrial waste stream in turf system spans approximately 1,500 acres of closure, safely the United States,with approximately 130 million tons and effectively reducing environmental and operational impacts produced annually. Over the last several years,new of landfills,including ash impoundments, across the United technologies for final ash storage have been success- States.It has also provided an innovative and stable solution fully implemented and are outperforming traditional vegetated for solar generation. closures in numerous categories.This year,Watershed Geo celebrates the 10-year anniversary of its first ClosureTurf"land- CCR Regulations and Challenges fill installation and reflects on a decade of progress,noting the In 2015,the U.S.Environmental Protection Agency(EPA) value of geosynthetics as a viable final closure solution for coal published its final rule governing disposal of CCRs produced combustion residuals (CCRs). by electric utilities.The rule requires facilities to meet detailed location,design,operation,closure,and 30-year post-closure ClosureTurf"is a final landfill closure system designed to care requirements,including the maintenance of and repairs to address the environmental and performance failures of tradi- final covers and other unit components,as well as the semiannual tional soil/vegetated caps.To date,the engineered synthetic detection and assessment monitoring of groundwater. „<, vlpp!Illllllllppllllllllllllllllllllllllpp IIIIIIIIIIIIIII I ➢.ali d I I ,., � ,%� 1��ie�..,,r �� IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII //'il,;� Vn��!((IIII���/, r,r rHrl�, ���� � �I �� / / l f / J 1 r/ r J / 1 1� c I I1 II I III / p, I IIII I I � I I illl ,/ I r r / a The federal CCR rule and individual state efforts to regulate this Because of challenges associated with prescriptive designs,and non-hazardous solid waste are furthering interest in new and specifically the unique requirements for CCR surface impound- emerging technologies.Industrywide,approximately 10%of the ments and landfills,an engineered synthetic turf system was created coal burned to make electricity makes its way into a CCR waste as an alternative Subtitle D capping option and now has a decade stream. Beneficial reuse is part of the solution,but the industry of installed performance.In addition to eliminating the need for needs a long-term answer for CCR that is both cost effective the intermediate soil cover and vegetative layer,these turf systems and environmentally responsible. Final landfill closure solutions have mane advantages over their traditional counterparts,mclud- that include state-of-the-art engineered turf systems require less ing faster installation times,safer construction methods,improved operation and maintenance expense over the life of the project storm water quality,and significantly reduced maintenance and and are environmentally friendly options that offer utilities more post-closure costs.For surface impoundments,using an alternative flexibility to meet the growing regulatory framework faced by capping design can also greatly reduce the amount of disturbance utilities.Additionally,utilities are facing renewable energy man- of the existing CCR material within the impoundment. dates issued by individual states that vary widely,prompting the consideration of geosynthetic turf closures as an ideal surface on An engineered synthetic turf system is a three-component which to deploy and maximize the use of solar panels. system comprising a structured geomembrane,an engineered turf,and a specified infill.The structured geomembrane provides Designed to address the stringent requirements of CCR closure both drainage and high interface friction for stability.It serves regulations,the synthetic turf system is proving to be an effec- as the barrier layer to minimize infiltration through the cover tive solution for utilities and industrial sites facing aggressive system into the CCR.The engineered turf is made of synthetic mandates. Currently being used on multiple large-scale CCR grass blades tufted into two layers of geotextile backing.It is the disposal projects,this innovative solution is fully compliant with protective layer that covers and protects the underlying geomem- the requirements of Subtitle D of the Resource Conservation brane from ultraviolet(UV) degradation and wind uplift The and Recovery Act and offers meaningful advantages specific to specified infill provides additional UV protection and allows the CCR disposal challenges. system to withstand traffic loads. Traditional Closure Design vs. Geosynthetic Soil Construction Factors Closure Eliminating the need for a two-foot soil and vegetative cover Prescriptive final cover designs for landfills have historically layer improves safety while reducing the carbon footprint of included a compacted soil liner,geomembrane liner,a drain- the closure,as there is no need to transport soil to the site(see age layer,and a vegetative soil cover.These traditional capping Figure 1).This means the removal of thousands of trucks from options involve large volumes of soil that mane coal-fueled local roads,as geosynthetic turf closures eliminate the need plants may not have available. for approximately 550 truck trips (275 round trips) per acre that would otherwise be needed to transport soil to and from a borrow site.Less equipment also means reducing the carbon footprint of the closure by approximately 80%compared to traditional soil/vegetative covers.The reduction in size,number, and duration of equipment ment further contributes to an overall increase in safety on both the project site and local roads,as well as the reduction of dust at the site,mud on the roads,and noise impacts to the surroundin community. Most traditional closures also require destruction of land for project soil sources,resulting in additional environmental impact and loss of future land use. A geosynthetic turf system installs two to three times faster than a traditional soil cover and uses fewer and lighter pieces of equipment.The increase in project-completion efficiency means / that owners,operators,and their design and construction teams can effectively cover more acreage per day.Additionally,the standardization of engineering and construction details associ- ated with engineered turf systems reduces the burden on the regulatory review and approval process.The use of this system also makes it easy to install in smaller,incremental closures.The sooner full cells can be capped,the sooner leachate is reduced, providing significant savings for the owner. Geosynthetics are lighter and improve the stability of CCR closures by eliminating the weight of the traditional soil and vegetative cover.This reduces the static load surcharge on the impoundment or landfill and the dewatering needed to stabilize Issue 1 2019 Ash at V1PS* 36271&4165 y Aqw,Sta uctu. ed W � w w fJ I &.dt��:A�k^'a'M.�'�Id r+ "-r,.,. �MIVVie�,4l �'1W �I� � ,' fig9@�1A0� r. rwl➢M`I�'A"..!. "vmiuctuWett MEN" Ttaidi1tional VegetatedCap,,Application ClowreTiwVApplication Figure 1.A comparison of a traditional vegetated system and geosynthetic turf system demonstrates the two-foot elimination of soil. a CCR impoundment for final closure,which in turn can shorten the construction schedule.In the event that future access to the ash is needed,the geosynthetic system can be easily cut and resealed back together.Asoil cap, this instanc e, would require excavation,management of sediment runoff,and then complete reconstruction. Shear Strength and Slope Stability Traditional soil covers are subject to veneer-type slope failure due to insufficient interface shear strength and the possibility of excess B h draulic head in the soil cover. T g y y removing the burden of the heavy soil layers,final cover slope stability is significantly improved due to the highly durable interfaces of engineered turf. In fact,there are two interfaces in ClosureTurf"—the interface between the engineered turf and the structured geomembrane, { and the interface between the structured geomembrane and the subgrade soil or waste. rr Landfills settle as a result of CCR compression and the consoli- dation of foundation soils.The dewatering and consolidation of sludge,as well as differential settlement,can create depressions " in the final cover,causing traditional soil covers to crack and ponding to occur on the cover surface.Engineered turf systems will tolerate a much larger differential settlement than soil covers due to the elongation of the geomembrane.The flexibility of the system conforms to the surface depressions without damaging the cover. With the low load-bearing capacity of saturated ash,there are concerns that the additional geotechnical loading of a soil or clay cap and vegetated soil cover could produce excessive surcharge stresses,creating the geotechnical instability(i.e.,sloughing) con- ditions often associated with very low California Bearing Ratio test value subgrades.What we have found through the successful deployment of geosynthetics is that it eliminates the possibility that these settlements will result in reversing the final grades of " the cover due to the additional surcharge-type loading after the geomembrane installation. 12 Ash at Work Issue 1 2019 Page 3628 of 4165 Design If properly maintained,the engineered synthetic turf layer will have a 100+-year functional longevity.The results of 10 years of independent weathering data for the synthetic turf yarns tell us that the projected half-life of the engineered turf layer far exceeds 176 years.This longevity has been independently evaluated by multiple organizations that are experienced in the longevity performance of geosynthetics.The underlying geomembrane will last much longer because the engineered synthetic turf layer provides protection of the structured geo- membrane so that it is not exposed to the environment In fact, studies by the Geosynthetic Institute show that the geomem- brave can last more than 400 years under covered conditions. Wind tunnel testing was conducted at Georgia Tech Research Institute to evaluate the wind uplift of engineered turf.Wind actually created a downward force on the turf,and it resisted a hurricane-force wind of 120 mph without being lifted.Several project installations have experienced significant,if not historic, o �„ weather events,including hurricane-force winds and record- setting rainfall.A closure project in South Carolina endured a 1,000-year rain event when a hurricane swept through the '���� y, �'119gy i� 6ir area,and a Florida Panhandle protect experienced a historic ��i m , 500-year storm event in which 5.68 inches fell in a single hour lJll%i, I fl / , 26 inches total in a 24-hour period).No damage to the system /t i� was incurred.Additionally,northern installations with an engi- veered turf system have provided opportunities to evaluate itsj "` performance in areas that encounter cold,high wind,and snowy conditions. Geosynthetics perform exceptionally well in each of these extreme-weather scenarios. Reduced Environmental Impacts When considering a final cover system for a landfill or impound- ment,it is important not only to keep water out of the waste, but also to ensure that nothing detrimental comes off the , surface and lands in the water carried offsite. Considering the average size of CCR impoundments and landfills,opportunity exists for significant sediment pollution through erosion that is � often an inherent part of traditional soil covers. Geosynthetic � i turf systems provide clean runoff with very low turbidity because they do not have a soil layer,except for the thin '' 1 VVII iW uuum y (0.5-inch thick)layer of sand infill.The sand acts as a natural filter as the water moves down the slope and channeling areas. As a result,sites have experienced a 90%reduction in turbidity, resulting in cleaner water.These systems also significantly reduce sediment loading to surrounding channels and sedimentation ' detention basins either onsite or offsite.This produces a positive impact on overall storm water quality,allowing effluent levels to meet(or be well below)the regulatory turbidity limits.Most importantly,they consistently provide repeatable water-quality results for every design storm event In areas of channelized flow (bench drains,down chutes, and perimeter channels), the geosynthetic turf system can be �r infilled with a fiber-reinforced,high-strength concrete matrix instead of sand. This specialized pozzolanic infill created specifically for storm water applications will flex and move !� P Y PP with typical differential settlements that occur on permanent covers.It provides superior hydraulic performance capable of M" i ii @ONNNUNiVWOV ouuuouJ m- � 0 f rl'%'1�� "1rf � NuSV handling high shear stress and large flows,resulting in very high This new slope panel technology system increases the power velocities. output by as much as three times per unit area compared to traditional arrays. Geosynthetic systems also require very low post-closure maintenance compared to alternative soil systems.The cost of Looking Ahead maintenance is estimated to be as much as 90%less as a result An engineered synthetic turf system is a proven technology of reduction in maintenance activities,including the vegetation, that solves problems that have been plaguing the industry for mowing,fertilization,irrigation,re-vegetation,erosion repairs, decades. It addresses landfill stability and erosion problems by and storm water pond cleaning associated with traditional soil providing a long-lasting,geotechnically stable,and environ- covers. Common erosion,storm water,and siltation problems mentally friendly final cover system that significantly reduces are prevented—even during severe weather events such as construction time and maintenance costs while providing an intense rainfall,hurricane force winds,and earthquakes.Further, ideal foundation for solar panel deployment. they protect against driving forces and severe weather conditions such as drought and heat The volume of existing CCRs,in both landfills and impoundments, represents a staggering volume that will need to be closed,in some cases on very aggressive schedules.According to the EPA, Post-Closure Beneficial Use: Renewable Energy there are over 310 active CCR landfills,with an average size of With recent federal regulations likely forcing the closure of mane approximately 120 acres,and 735 active CCR surface impoundments, power plants'coal ash impoundments,an engineered synthetic with an average size of roughly 50 acres. system provides an ideal foundation for utilities to deploy solar generation alongside active or retired coal-fueled plants. One The amount of coal ash likely destined for future disposal is of the biggest hurdles to utility-scale solar is finding suitable expected to remain significant for years to come,leaving an sites with grid infrastructure for interconnection.By nature,this ongoing disposal challenge that can greatly benefit from the use problem is alleviated when solar is sited at an existing or retired of new and emerging technologies such as geosynthetics. power plant and the impoundments have been capped with engineered synthetic turf systems. Challenges to deploying solar panels on vegetated caps include fugitive dust,grass clippings, Mike Ayers is Chief Executive Officer of Watershed Geosynthetics and potential damage from mowing equipment Additionally, LLC.He has over 25 years of professional experience in the Panel systems might move or break due to settling caused by design and development of heavy civil engineering projects, erosion impacts to a vegetated cap. including the execution of all phases of land development, geotechnical evaluation,hydrology assessments,site selection, Upright solar panels have been successfully deployed on and management of the permitting process with state and federal numerous synthetic cap closure sites across the U.S.Recently, agencies.A licensed professional engineer and general contractor Watershed Geo demonstrated a unique approach to maximizing in multiple states,Ayers has over 20 hears of design experience solar collection at landfills and impoundments.The solar system using a variety of geosynthetics for stability,erosion control,and combines the most advanced,proven panel technology with a containment He is actively involved in the Industrial Fabrics rackless,direct surface attachment system that can be used on Association,Solid Waste Association of North America,and the the top decks and side slopes of a geosynthetic turf foundation. International Geosynthetics Association. 14 0 Ash at Work Issue 1 2019 Page 3630 of 4165 �1 u1V� eeneier co�ory': ��ami :now�a:e: me mwroie CloSureTulf� ce^era� oroo.�,en�rro, erm��an�e .o�� �arers =m �ea�a�y oo:rno:��e �a wrcn:rn�amy eame, e�e�o:, aid �mP,o�me :m,m wage, m���c�e�, sc Quality overavaditional5ubcitle D�egetative cnp. Ber N unN n5(eCN am r Muni pal solid Wane zoi3 ,. rr � �� .— Watershed�eo Overcoming Capacity Issues Officials at the landfill had to address significant challenges with the closing of the site explained Mark Schlievert, Director of Solid Waste at BCWS. "The waste had been built too far out to the edge,leaving little room to place a two-foot traditional � soil capping system. It would have required us to excavate excess waste and "'In the event of transport it to another location. In addition,the landfill is located in an earthquake seismic activity or zone and an area susceptible to hurricanes and high rainfall events. In the event of seismic activity or significant rainfall, the soil used in a traditional capping system sign ifica n t ra in fa A, would present a significant slide hazard." the soil used in a Schlievert and the BCWS had a previous relationship with AGRU America, a traditional capping manufacturer of geomembranes used as final caps on landfills.After discussing the site's issues,AGRU introduced a new Subtitle D method,called ClosureTurf . Mike system would Ayers,CEO/President of Watershed Geo"and inventor of ClosureTurf,describes the system as a patented, three component system comprised of a structured present geomembrane, an engineered synthetic turf, and a specialized sand infill. "The significants/ide foundation of the system is an impermeable, highly transmissive structured geomembrane manufactured by AGRU. It provides for the highest interface hazard friction values available in the market.The engineered turf component gives the system its natural look and feel of grass while protecting the geomembrane from extreme weather conditions for the long term. The specialized sand infill component is placed between the blades of the engineered turf and allows the system to be trafficked while also providing additional protection from weathering.When required,ClosureTurf's patented surficial gas system is included with the system to collect landfill gas emissions.,, Addressing Permitting Concerns To gain approval to implement ClosureTurf, which is considered an alternative long-term cover landfill system, Berkeley County landfill officials worked closely with the South Carolina Department of Health and Environmental Control (SCDHEC). Final cover design for the closure of Berkeley County Landfill went ............................"'I through a three-year approval with the SCDHEC prior to the start of construction. Since ClosureTurf was a new technology to the state, the SCDHEC had several A 'soiless technology', Closure- factors to consider for permitting; some of which included the longevity of the Turf' eliminates the risk of slope product, the cost benefit over a traditional system, water runoff conditions and erosion. accessibility to the areas of the cap. Schlievert, Watershed Geo and SCS Engineering, the consulting engineer, together made several presentations to members of the SCDHEC over the decision period to address the proposed concerns. Ayers addressed the ultimate goal of ClosureTurf, "As a response to numerous failures and poor performance of environmental closures at landfills, engineers and landfill owners have studied new approaches to establish a more physically stable and environmentally sound solution.Traditional landfills require large amounts of soil throughout their lifespan and are often lacking adequate soil to complete closure construction. Many of these landfills experience on- going erosion and sedimentation issues.Traditional covers are highly reliant on trucking soils, heavy civil construction equipment, on-going maintenance and repairs in order to maintain their integrity. ClosureTurf takes the soil out of the equation all together, therefore solving 90% of the ClosureTurf° applied in a tradi- issues with that alone." tional bench design. Page 3632 of 4165 ClosureTurf" Benefits Specific to Berkeley The sliding of a soil cover along the steep slopes was a primary concern with the Berkeley landfill, particularly with the risk of a major weather event. With this 1 �, concern in mind, Ayers addressed ClosureTurf's stability attributes. "During a rain event,the rainfall will penetrate quickly through the sand infill and drain directly in the geocomposite integrated drainage layer below, avoiding sand erosion and maintainingstability of the sand infill.The infill is also held in lace b the unique Y p Y „<. structure of the synthetic grass that traps the sand to anchor and ballast the synthetic turf layer to the surface it covers. The resulting high interface friction serves to provide a resistance to sliding or veneer failures due to weather, steepness of final slopes and seismic conditions.In fact,the ClosureTurf system has an interface friction of 39 degrees between the engineered turf and geomembrane ClosureTurf° can be used for which equates to a safety factor greater than 2.0 for typical landfill slopes." incremental closures as seen above in Berkeley's first four cells Ayers went on to explain, "There are other advantages that ClosureTurf provided that met capacity. to the site both during and after construction;one of which being accessibility for ease of construction and ongoing site inspection. The sand infill used in the ClosureTurf system not only acts as a ballast but also allows for access of a 60 psi tire pressure vehicle on the slopes and higher ground pressure vehicles in flatter areas without being susceptible to damage. This proves to be especially beneficial when gas system monitoring locations or wells in the landfill will have to be "The reduction in accessed by persons on foot or in vehicles.Typical soil closures would likely require all-weather roads for construction access and to get to monitoring locations." maintenance is our ClosureTurf also provided a natural water filter for Berkeley. The engineered turf biggestgain. and sand aid in filtering runoff that is free of sediment, fertilizer and other We're saving contaminants. "This ensured that runoff from the site flowing into local water sources was clean and safe,"explained Ayers. around$24,000 a ClosureTurf Receives Approval year in Even with all of the obvious advantages, one of the looming questions of state maintenance... We officials focused on is the longevity of the ClosureTurf system. While the oldest real-world application of ClosureTurf was installed at the Lasalle-Grant Landfill in have absolutely Jena,Louisana in 2009,independent,real-world weathering test performed at Atlas Material Testing Laboratories in New River,AZ,has shown ClosureTurf s engineered zero eroded slopes turf component to have a design life of 100+years,certainly exceeding the typical to repair and we 30-year Subtitle D requirement. With these confirmed results,the SCDHEC granted BCWS approval to use ClosureTurf as an alternative long-term cover system in early have eliminated 2013.The countywas assured that If ClosureTurf could pass inspection for two years and all requirements were met,the SCDHEC would approve the product as a final mowing andgrass cover. uokeep." Construction on the site began in April and was completed in January 2014. The county saved an initial cost of$50,000 in construction and expects to save at least $720,000 over a 30-year period in future typical maintenance costs while reducing the environmental impact and improving safety and performance. The project marked the first large-scale implementation of this type of cover system in South Carolina. While ClosureTurf solved several challenges for the county, Schlievert has been most excited about the economic advantages that Berkeley has benefited from in relation to post-closure care since completion. "The reduction in maintenance is our biggest gain.We're saving around $24,000 a year in maintenance. On average, Page 3633 of 4165 total overall maintenance costs are typically reduced by approximately 90%with '"" °""°" '%!%9///E ClosureTurf compared with the traditional soil cover system.A Subtitle D prescribed cap typically requires ongoing vegetation and soil maintenance for the entire system to perform as designed consisting of frequent mowing,water, fertilizer,top soil replacement,erosion control,and sedimentation basin IVi i Ad J) Ne I. maintenance. We have absolutely zero eroded slopes to repair and we have eliminated mowing and grass upkeep. In addition,we are significantly reducing water contamination,dust and heavy equipment noise and pollution." Putting ClosureTurf to the Test Rubber tired vehicles can be Schlievert and the SCDHEC were particularly impressed with ClosureTurf's driven on ClosureTurf° without performance during a recent flash flooding event in the South Carolina coastal risk of damage. area."During the epic rain event,we received 26 inches of rain over a couple day period. Many areas in our community experienced severe flooding and many of the county's traditional soil-capped landfills were left with significant and costly erosion. With ClosureTurf,we experienced a small amount of sand migration to the bottom of the slope but there was enough coverage of sand that it did not have to be redistributed or replaced. It did its job and what it was designed to do." Recently,the final inspection of the two-year period that SCDHEC required was completed. Field Operations Manager for Watershed, Bob Buzzell, reported that, "Other than a few small synthetic turf repairs,the site has withstood environmental and weather conditions extremely well." Because ClosureTurf's top layer consists of a synthetic turf material and is not covered with a thick soil 0......... ......... profile, it is easily inspected for damage,and if identified, may be easily and ClosureTurf° was easily im- inexpensively repaired. Since the infilled turf serves as protection for the liner, plemented into Berkeley's there is no risk to the integrity of the overall system and its performance. conventional gas system. "When we designed ClosureTurf,we were very technical and practical in our approach to solving all landfill closure issues,"said Ayers. "Today, it has been designed, permitted and installed all around the United States due to its superior performance. I think at this time we have over 33 projects completed with 25 million square feet of ClosureTurf installed. It's been thoroughly vetted and proven in many applications. We look forward to watching ClosureTurf exceed expectations at Berkeley. Our next step is to receive final approval from the state." CLOSURETURF'is a U.S.registered trademark which designates a product from Watershed Geosynthetics,LLC. This product is the subject of issued U.S.and foreign patents and/or pending U.S.and foreign patent applications. Page 3634 of 4165 J Y, , r u�q l i 1 i i ,,:::................ /�/ / / , , i i i III A III Ill::;; W II"1 II°N Watershed Geo- LcOrr Uu Unearthing Solutions °111 14u °111 U1111° g IW IE 110 11314 A 114770.777.0386 www.watershedgeo.com Page 3635 of 4165 After a thorough process of approval from the City Council and public, ClosureTurf was submitted to the State of California for permit modification and approved. The scope of work included removing the interim cover, making drainage improvements,and installing the ��'J� f % f�{/,✓' ClosureTurf system. "From a quality construction assurance perspective, installation of a 'fl/�����f(i��� f�m�� Jo��711wrmmiiufif(�i�Rr � 9//� II� frn,1(fl'i ClosureTurf cover system required less field personnel during construction than a traditional prescriptive cover system. This resulted Clean groundwater post ClosureTurf in cost savings to the city,"stated Jake Russell, P.E., of the City of installation. Portola's CQA consulting firm Geo-Logic Associates. "The installation of the ClosureTurf cover was completed in significantly less time than p g Y � � F other similarly sized perspective Subtitle D vegetative cap landfill cover systems with which I have been involved. By removing the soil components of the cover system, construction issues associated with the variability and availability of soil materials were eliminated." ,i�, /�ti�r111191l➢ar�rall�l�l�I�� flit �r % i With a residential neighborhood 1,500 feet South West of the landfill, contaminated water was also a concern. Many of the residents receive water through individual domestic supply wells. Because the sand and engineered turf act as a natural filter, ClosureTurf provides clean runoff with very low turbidity. In addition, no chemicals,fertilizers,or Sand infill is brushed into the pesticides are required to maintain vegetation. engineered turf. �m I �gN,YY r/ e Located in the Sierra Mountains,the Portola Landfill is often subjected to harsh climates. CLOSURETURF'is a U.S.registered trademark which designates a product from Watershed Geosynthetics,LLC. This product is the subject of issued U.S.and foreign patents and/or pending U.S.and foreign patent applications. Page 3636 of 4165 d` r / r r r / r / / 1 / rrrr„r rrrrrr r , , t , r r r r ,rrrrrr rrrrrrrrr rrrrrrrrr rrrrrrrrr rrrrrrrrr rrrrrrrrr / i, , . „ r ,, ,, , r / r ,r / MADE W II"A IIH Watershed L Geo- rr Uu 'U'nearthing Solutions .I.I11�u .I.u.11 i k 6 I 3 4 A 114770.777.0386 www.watershedgeo.com Page 3637 of 4165 Because of site conditions,the SVSWA's final cover system would have to „N,uiiiii+ r meet five main criteria: 1. The system would have to withstand the environmental conditions uu°u present including wind erosion and uplift, rainfall erosion, concentrated I flow erosion, ultraviolet light degradation,and traffic. 2. The system had to provide a static factor of safety of at least 1.5 and resist j seismic deformation due to the San Andreas Fault zone located about five miles northeast of the site. 3. The final cover system had to provide excellent groundwater protection to halt continued impact to the local groundwater supply. I' 4. Due to an old cross-traffic style highway interchange,risk to motorists had to be avoided during construction. Installation of engineered turf and 5. The new system could not create additional nuisance conditions for geomembrane before sand infill is nearby residents, many of whom had been concerned about the landfill added. site operations and impacts for years. In addition,surface water that could be affected by the landfill would provide groundwater recharge,contact recreation (i.e.swimming),and wildlife habitat. Adjacent land uses near the site included cattle grazing and residences. Homeowners had often registered complaints with the SVSWA regarding dust, windblown litter,odors,and general site appearance. The SVSWA evaluated several closure systems including an evapotranspirative cover system,a prescriptive cover utilizing a textured geomembrane,and a prescriptive cover utilizing a structured geomembrane. However,getting �i vegetative cover soil to the site proved financially prohibitive at an average of $13/cy.The SVSWA was then introduced to the ClosureTurf technology,which was relatively new at the time.The primary regulating agency and design engineer requested some additional testing such as wind erosion and uplift. The engineered turf and sand infill They found surprising results in that the system became a downward force at higher wind speeds (up to 120 mph or Category 3 hurricane wind speeds.This effectively filters surface water, was important because the design wind speed for the Pacific coast was 85 mph providing clean runoff with very low turbidity. in 2010. With rainfall erosion also being a concern,ASTM testing confirmed that no sand loss occurred at 2.63in and 4.65 in of rainfall per hours. For concentrated flow areas,a cement infill called HydroBinder'was used to increase hydraulic shear resistance up to a measured 15psf) equivalent to a 12-in D50 riprap. In addition,tests were conducted on UV resistance and trafficability,all of which ClosureTurf performed well on. Ultimately,the SVSWA chose ClosureTurf due to the fact that it met all five criteria, and the cost fell within their budget of available closure funds.The annual post- closure maintenance was estimated at$46,000 per year.ClosureTurf reduced these �f annual costs by approximately 80%.The total savings over a nominal 30-year post- closure period is projected at $1.4million. `r � Fa�� In addition, ClosureTurf eliminated about 11,000 truck trips to import soil to the site. The project's carbon footprint was reduced by 80% due to the combined the conventsrfl easily integrated into project size reductions of soil import elimination and reduced heavy equipment the conventional gas col-lection system, needs. Most importantly, the closed landfill has had a positive impact on the local neighbors.The site is now barely discernible from the natural hillside,and aesthetic and odor complaints from neighbors have ceased. In fact, many have contacted the SVSWA to compliment the appearance of the site. Page 3638 of 4165 Because some of the side slopes measure 2H:IV,Agru's Super Gripnet'membrane was used to provide a high shear strength. ��ovl gw¢ p w r , N m 1 Nay t �t { I ' 4 r gip, I Confluence of drainage channels with HydroBinder'at the Crazy Horse Landfill outlet. CLOSURETURF'is a U.S.registered trademark which designates a product from Watershed Geosynthetics,LLC. This product is the subject of issued U.S.and foreign patents and/or pending U.S.and foreign patent applications. Page 3639 of 4165 r f nevi" �y- esru III�uurl ��' u 60 rGEOsTRATA NOvcM BER/D EC EMBER 2019 Page 3640 of 4165 / wr /fN! rl r I � Page Iff of 4165 wvv.q ain�rs iikuke.orq CC JIIII 11� IMF� Illiilu �i� "IIIIIIII q�;i ����` 1 F/ I u7rure.1,View of stacked geotextile tubes for containment of dredged sediments showing detail of multiple tube operation stages. (Photo courtesy of TenCate Geosynthetics.) Ill recent years,however,there's been increaasi:ng,confidence: and consolidation(Figure ure 1). 1°loccarlants are usually added. within the:g;eotechaaical profession regarding,geosynthetics' to fine-grained slurries to facilitate agglutination of solid paerforirr all c:,e and long-term durability.Why?It's because poly- particles.After dewatering is complete,g,eotextile tubes call be mer formulations have continued to advance,phenomenal either transported for off-site disposal or capped ill palace for research has been(and continues to be)co lid to caanti fy perraarcnt disposal. Unlike traditional cewateriag techniques, the:longevity of geosynthetics,and field evidence of good such as settling;basins,g,eotextile tubes offer high cfewatering perforinance has been documented for gAeosynthetic structures efficiency and provide effective odor control by]uniting; that are more than a half-ceiatury old. exposure of waste to air. This particle is not intended to document the important A recent trend in g eotextile tube:applications involves results of recent research on durability or add to all already stacking them in raaultiple layers to reduce the disposal area healthy record of field performaance of early,gxeosynthetic. footprint ill large environmental reniediation projects.For stractaics.Instead,its objective is to illustrate]low overcoming exarnple,as part of the Onondaga Lake Cleanup Project near early concerns about durability has enabled innovative geo- Syracuse,NY,about 1.6 million na''of contaminated sediments synthetic solutions in landfill design.C',eosynthetics have been dredged from the:lake were dewatered and contained using used in modern landfills in the U.S.for over four decades since approximately 1,000 g;eotextile tribes that were,Lila to 91 in ill the passage of"the Resource Conservation and.Recovery cyst in length and 2.4-27 rn in circumference.°I he g;eotextile tubes 1976.13eyond the well-established use of g;eosynthelics in base were.stacked in six layers approximately 11 ill high within. liner systems,three relatively new applications are featured ill the 22-hectare landfill footprint and permanently capped i.n. this article that involve the use of g e.osynthetics as part of tlae place with a soil-g,eosyntlaetic final cover in 2017. Figure 1 waste disposal,slope:stabilization,and final closure of landfills. shows all aerial photo of the stacked g;eotexti:le tribes during; These applications illustrate recent advances in g,eosynthetic construction."I he key design considerations when stacking; solutions to overcome enduring;challenges previously man- g;eotextile tubes include internal stability of individual tribes„ aged using traditional approaches. slope stability of stacked tubes,and settlement and bearing capacity of the foundation that supports stacked tubes. Stacked Geotextilae Tubes for Waste Disposal Another trend is to utilize the waste encapsulated in the The use of g7eotexti:le tubes combines dewateri.ng and disposal g;eotextile tubes as fill material to reduce the quantity of ofindustrial wastes,such as sludges,dredged sediments„and imported construction materials.A g;eotextile tube wall was sluiced coal combustion residuals(C:C R),into one large operation, closure of all ash pond at as g,ee¢�aticara, constructed in 2C11Ci durira significantly reducing,the;handling,of saturated wastes. Mid-Atlantic utility site.The wall separated the ash pond into Geotextile tubes involve high-streng7th„permeable woven a pool section that continued to serve as an operations area g;eotextiles sewn into a tube.When wised for dewatering,the to receive sluiced C:C;II,and as construction section where geotextile acts as a filter that allows water flow while retaining, preparation work for final closure grading was to be started. the:solids in the tube.]"Ire dewatering;process includes The g,eotextile tribes were stacked i:it two layers and formed all three main stages:hydraulic:filling,,free water drainage, approximately 111-to 24-na-wide.,3.4-nr-high,and 730-m-long 62 GEOSTRATA NOVE BER/ ECEMBER 2019 Page 3642 of 4165 wall.Approximately 61,000 m3 of in-situ fly ash were dredged structures.Geotechnical properties of municipal solid waste and pumped into the geotextile tubes and used as the fill are inhomogeneous and highly depend on the composition material to construct the wall.Figure 2 shows a section of the of the waste itself—in particular,the percentage of organic installed geotextile tube wall. components that decompose over time.Furthermore,waste degradation involves complex fermentation phenomena, Durable Geosynthetic Reinforcements for Waste chemical alteration, creep,oxidation,and cementation that Containment Stabilization results in mineralization of the waste.The resulting waste often While many design solutions have been adopted to maximize has an average temperature of 40'C,with peaks over 60'C the available waste capacity within p the defined footprint of landfills(e.g., dynamic compaction,bioreactor technology,and landfill mining),the use of geosynthetic-reinforced structures, such as mechanically stabilized earth berms,has been incorporated into landfill designs over approximately the last two decades.While the design of reinforced-soil structures generally fd requires granular backfill material, landfill owners have started using actual landfill waste as backfill material to optimize the site geometry and reduce / construction costs. The use of waste as backfill material r' introduces several challenges into ref „ the design of the reinforced-soil ligu.uu°°e 2.View of geotextile tube wall filled with re-used fly ash in an ash pond at a Mid-Atlantic utility site.(Photo courtesy of TenCate Geosynthetics.) i �f f � Geogrid rtf Ura.wilur t(odl ;i w rat f W "rv f ligu.uu°°e I View of a geog rid-reinforced soil cover system on the North Slope of the Oil Superfund Landfill. Note the detail of the geogrid reinforcements anchored into solid waste. Paq?U43 of 4�65 www.geoins u e.org v J uuf�ffuu(����I�III��I�I��IIIIIIIIIIIIIIIII��Illlll��llll��l/lllll�i��tl�ll���llll IIIIIIIIIII�I� I�IIII�I(II�IIII�I�III1011111111���P i aWi i III .mw�us�sv,��r'Ji�W�a��,rc5�r�i�m�cu�r��rcsanh*ressty Este Vegetative Soil C 66 .o ✓,Wa d i7 pd rpy p a—.,......... _ P Nonwoven Geotex"tile �� Geo9rid Reinforcement drarc?�,r4� Igu�lr��r4.Viewof 11 4 : „ „ .. capping cross section at � � Niccioletta Landfill.NoteDrainage 9 9 � � IIPbf�ilP�� the detail of the eo rid c iii iP � reinforcements in direct Y y � eos nt etic a finer contact with waste backfill. ., �''„ due to anaerobic digestion,and is often chemically aggressive. Engineered Turf Cover for Final Closure Key aspects to be considered when selecting geosynthetic Closure of a landfill is required after reaching final grades reinforcements,such as geogrids,include their resistance to to isolate the underlying waste and manage long-term chemical degradation under a wide range of pH,creep perfor- environmental risks.Traditionally,landfills have been closed mance,performance at high temperatures,and resistance to using soil covers with geosynthetic components.A traditional mechanical damage during waste compaction. landfill cover,for example,consists of(from bottom to top) a The final closure of the Operating Industries,Inc. (OII) geomembrane barrier layer,a geocomposite drainage layer, Superfund Landfill located near Los Angeles,CA,is an early and a protective/vegetative soil layer that is at least 0.6 m thick. design example involving geosynthetic reinforcements in Two persistent,long-standing challenges associated with many direct contact with solid waste.One of the most challenging traditional soil covers are soil erosion and cover slope failures. design and construction features of that project is related to The engineered turf cover is a relatively new landfill closure the stability of the landfill's North Slope.The North Slope is solution that uses engineered turf and a specified infill to located immediately adjacent to the busy Pomona Freeway. replace the protective/vegetative soil layers used in traditional It rises up to 65 m above the freeway and consists of slope soil covers.The elimination of these soil layers removes soil segments separated by narrow benches that are as steep as erosion as a driving force behind cover slope failures.Because 1.5H:1V and up to 30 m high.As illustrated in Figure 3,hori- engineering turf is not susceptible to erosion,it's less affected zontally placed uniaxial geogrids anchored in the actual solid by factors such as changing weather conditions and varying waste were selected as the most appropriate and cost-effective soil properties compared to traditional soil covers.Moreover, method for stabilizing the engineered soil cover constructed engineered turf covers require less post-closure maintenance over the North Slope.The cover has performed well since its because soil-erosion repairs,re-vegetation,fertilization, construction over 20 years ago,which demonstrates that the mowing,and stormwater pond cleaning are not needed. geosynthetic reinforcement solution has been both durable The engineered turf component is made of high-density and successful. polyethylene(HDPE) synthetic grass blades tufted into a In 2011,a landfill cell was constructed in Niccioleta, double-layer polypropylene,woven geotextile backing,which Tuscany,Italy,using waste as fill material for the reinforced is placed directly on top of a HDPE or linear low-density poly- side slope(Figure 4).A geogrid material was used to reinforce ethylene-structured geomembrane(Figure 5).The specified each layer of waste material,providing the tensile strength infill,either bonded or unbonded clean sand with a minimum required to achieve internal stability.Additionally,two layers layer thickness of 13 mm,is placed inside the synthetic grass of drainage geocomposites and one layer of geosynthetic blades.The engineered turf and infill function primarily to clay liner were wrapped around each layer of waste to form protect the geomembrane from ultraviolet(LTV)exposure, the landfill's final capping system.A layer of vegetative soil, wind uplift,and puncture by external forces,such as vehicular retained by a turf-reinforcement mat,was subsequently placed traffic,hail,and animals. in the slope face to provide a vegetated facia and an extra layer The first engineered turf cover was installed in 2009 at of protection for the capping system.As designed,the system a four-hectare MSW landfill in Louisiana to solve recurrent allowed the construction of landfill cells having side slopes at soil-erosion problems.In 2013,installation of a 28-hectare angles much steeper than the typical 3H:1V slope,significantly engineered turf cover was completed at the Crazy Horse increasing the overall landfill cell capacity. MSW Landfill in California;it was selected to meet the design 64 GEOSTRATA NOVEMBER/DECEMBER 2019 Page 3644 of 4165 requirements of final cover stability for both static and seismic long will they last?" is being addressed through extensive conditions for steep side slopes up to approximately 211:1V'1"o research,sound engineering design,and innovative applica- date,engineered turf covers have been or are being installed at lions"This contributes to sustainable landfills by incorporating more than 40 sites in over 201 states in the U.S.,covering as total geosynthetics in the design of landfill components related to area of triore than Wo hectares,These sites include MSW land,- disposal operations,stabilization approaches,and final closure fills,industrial waste landfills,and CCR landfills and surface systerns,as illustrated in the three applications presented in impoundments.Figure 5 shows the aerial photo of a 14-hectare this article, engineered turf cover installed in 2014 at (lie Hartford Landfill Innovative geosynthetic materials, products,and designs in Connecticm, are expected to continue to emerge with the pursuit of Sustainability for landfill closures entails long-term perfor- sustainable designs.For example,according to data provided inance and minimal environmental and social imp acts.The by the U.S. E'nvironmental Protection Agency,there are more design life of the engineered turf cover is projected to be over than 1,000 active CCR landfills and surface impoundments in 100 years as as result of the enhanced UV stabilization of the the U.S,that require closures,creating opportunities for imple- synthetic turf fibers.'Ilie carbon footprint of engineered turf menting new geosynthetic solutions.Overall,geosynthelics cover is smaller than that of traditional soil covers,due to faster play an important role in geotechnical projects in general and installation,fewer construction materials,fewer construction landfill design in particular because of their versatility,cost- equipment operations,and less post-closure maintenance. Ill effectiveness,ease of installation,,and good characterization of addition,land disturbance is avoided because borrow soils are their mechanical and hydraulic properties.The creative use of not needed,which results in less impact on local communities geosynthetics in geotechnical practice will continue to expand as a result of less truck traffic,on loca_1 roads, as manufacturers continue to develop new and improved Engineered turf covers also facilitate r(A)SC of the large materials,and engineers come up with new design approaches space at the top of landfills after closure,such as converting and field applications. 2 them into a solar farm because maintenance of grass within the array isn't needed. Figure 5 shows the I-megawatt MING ZHU,PhD,PE,M.ASCE, is the director of engineering solar-electricity-generating facility installed atop the Hartford with Watershed Geosynthetics, located in Alpharetta, GA, He has 1.,andfill,which powers approximately 1,000 homes per day more than 10 years of professional experience in geotechnical and at peak capacity.The solar array is supported by a racking geoenvironmentali engineering. He can be contacted at mzhucd system ballasted with concrete blocks that sits directly on the watershedgeo.com. engineered turf cover.This approach reduces maintenance, because the solar panels are not subject to potential damage MARCO ISOLA,Phl), PE,M.ASCE, is a senior engineer with from mowing equipment and the runoff from the drip edge Maccaferri, located in Tarnpa, IFL. He provides geotechnical, of the solar panels does not induce soil erosion that would geoenv�I ronmental, and project management expertise in the undermine the panel foundations.Additionally, the engineered transportation and rnining sectors. Fle can be contacted at rn.isola(p turf cover provides as relatively dust-free environment that maccaferri,c+ m. promotes efficient solar collection. JORGE ZORNBERG,Phl),PE,FASCE, is a professor of Looking Ahead geotechn[cal engineering at The University of Texas at Austin in Advances in geosynthelics have made these materials a Austin, TX He was president of the International Geosynthetics well-established technology within the portfolio of solutions Society 0GS1 and currently chairs the G-1 Technical Committee on available to geotecbnical engineers.The old question,"Flow Geosyntheti1cs. He can be contacted at zornberg otmaitutexas.edu. act Pa 3645 of 4 161-5 www.geom I ute,org 1fr�ff i f , 1 , / / / j VNAV 11:; WV"11 111°11 C1 1 �� Watershed frONUUnea 770.777.0386 www.watershetions dgeo.com ire u.�u .u.u ire ir..ir:) kllllllllllllllllllllllllllllll6� a it uV e ir irr u4 i t . hedgeO.COm Page 3646 of 4165 The relocated landfill behind the bluff measures approximately 19 acres. It uumllli;;;luuuum uumuu 'iiiiiiii6 iiiiiiil was permanently closed in 2016 with the ClosureTurf°system. Slopes are 2.5:1 with the longest slope length at an impressive 285 feet.The Agru Super Gripnet°geomembrane used as the foundation of the system provides greater stability on steeper grades and reduces the need to rebuild slopes. Port Angeles receives 29 inches of rain per year on average and the 25- j year storm event is 3.9 inches of rainfall in 24-hours.The 25-year flow in the perimeter ditches is over 6 cubic feet per second and the flow velocity is over 5 feet per second.The ditches were quarry spall lined to help Slopes are 2.5:1 with the longest increase roughness and attenuate flow velocities.The engineered slope length at an impressive 285 synthetic turf and sand infill effectively filters surface water, providing feet. clean runoff with very low turbidity. In addition,the system significantly reduces sediment loading to the surrounding channel and sedimentation/detention basins. The ClosureTurf system also protects against other weather events such as hurricanes,typhoons and earthquakes.The area can experience high wind / gusts annually from heavy windstorms and pacific typhoons. In 2016, Super Typhoon Songda hit the Pacific area with wind gusts over 60 mph. k The site survived as designed with no erosion or maintenance required. Located in a seismically active area, it is prone to seismic hazards such as amplified seismic response and seismically induced landslide activity.The site lies approximately 4.5 miles north of the recently discovered Little River Fault,a shallow crustal tectonic structure that is considered active Port Angeles was easily able to and is capable of producing earthquakes of magnitude 6.5 or greater. integrate ClosureTurf°into their ClosureTurf protects against erosion that may occur with these events. conventional gas collection system. The system is designed for and proven to have a design life over 100 years of the infilled geosynthetic protective layer (engineered turf) with the of the underlying tiered mbfrane lasting more years beyond the long lifeiii g pThe City's Solid Waste Division now services 7,000 residents and 850commercial businesses and all refuse is collected at the onsite transferstation and transported to nearby landfills.The closed site serves as anatural habitat and is occupied by many different species of insects and animals, including bees, butterflies, bobcats,otters,elk, and deer. Deer play daily on the top deck and side slopes of the landfill. Page 3647 of 4165 f � f ......... ........,, f , / c i i J ✓u✓ ✓ //J// /r,g r/, 1 ✓ aii/, , 1 rldJJ �1✓!ln film � l�/� r i �✓ / '� ✓r n/QD�JJJkf4'�yaKpYA�w✓ ,N4fr rf�� .,�Y1�r��jYlfmr��rrtai✓mwxnplr ✓arrr rG �� � � .�i � '� i�wu�NlNj,IXr�Ur�.rt(wbi�ruerii ry✓i�iiHoi ra, l�'��0��>�UYNY,�yYd�lYalnlbiiurr�rri 1j�1 �1 �arWD�JN�D�iriaai„✓�, � � 1t � i Refuse still remains in one of the slide slopes on the bluff but is stabilized by a large MSE wall embedded with survey targets to track any kind of movement. r rf, t is ClosureTurf`°can be driven on without damage to the system. CLOSURETURF'is a U.S.registered trademark which designates a product from Watershed Geosynthetics,LLC. This product is the subject of issued U.S.and foreign patents and/or pending U.S.and foreign patent applications. Page 3648 of 4165 0 I 0 � p M (D >1cojjj O r /rrr( N lfl N f/) N M CIO O (a ;-rr1 III�� Un -0 ca O N +_n o 0 0 C �II N M 3 Q }� O ��pD11�JJ� W 70 =3 : 70 Vl» (n % M N c-I c-I O O O C /� � CL (� N ca -0 cn a) Na) N CL V � cn _ — `I 1.— (D i = 0) E CU Co E -C a) U cn cn i L �a U) 0 U O CIO L (DU a) to Lij N a) U > cns 0 i N V Na w N U D U t Co U N � Q ' N S O C: C: (n V � O EQ ••• ••• • Co d)tillitillsigJuatisI • O Q ice* ice* 0 LO 0 I 0LO p M (1) 0) f r6 CL III �,mkr r � r r ■� ;tip' r� �; G r 1 O C� o N L Q O >1 Q N � U (n > to CO CO N D to � 0 CO � +r 4-0 � p •� N ca E ■E �J'� O m _ C/) :3 • • a� Q cn cn S a O N N cn N m m U 2O 0 o > J U U Z Q Q LO 0 I LO(1) 0) °°� 911�11�I 9 J O M � Q N CL O cn �q co �i N O O N E O N (� U N N c p � a) a)cn cn -0Q � — � _ +r 4-0 O �O _O � •� U V C a) •� � � � N can 4-0 w � -o QvE Uo � �Co 0 Co Co u) ° E m LO 0 0 LO M 0) Ln O f , = O Q U o I O > F v r r i C: Q O i III I — Lid co � O 0 — N N O V- It s O t� LO _ ' N Appendix D Ukiah Landfill Monitoring Wells and Vichy Springs Resort Page 3653 of 4165 DAVID RAPPORTJ RAT PORT RT state e Bar N +"�38, mm, � MARSTON v. Wit 200 W. HENRY STREETu � P .O Box 488 Attorneys for Defendant OOURTCRERK 5 CITY OF UKIA171 6 7 IN THE SUPERIOR COURT IDS THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF MENDOCINO 10 Q G f::f: 4IE t" ASHOFF and M RJD:RI t D Craw No. 70873 A Sit.DFF, dba V!."C fY SPRINGS and a SPRINGS Mf:I^,TEtwyAL WATER DECLARATION OF DAMON F , B OW1,113 CORPORATION, IN OPPOSITION TO PLAINTIFFS ' APPLICATION FOR PRELIMINARY ff°1'9 NAR 1 Plaintiffs , I U f"4 t:., . ON 1 TIME : 3 : 3 tD a. m. REGIONAL WATER—QUALITY 17 CONTROL BOARD (NORTH COAST R ,(",I()N) , COUNTY OF MENDOCINO, � 18 WEEKS DRILLING & PD'.wMP I COMPANY, DOES 1 TO 20, 19 Defendants . �F 20 21 1 , Damon F. Brown, declare : 22 f am emj)loyed as a Senior Geologist 3 o n.d.: , engineers and enon'"do.n.:o:rnnnen'-nt::al consultants, which has 24 contracted with the City of Ukiah (City) co conduct various 25 geological and engineering studies and prepare various documents µ 26 in connection with the operation of the City' s landfill . I air 27 submitting inng this declaration rant ionv. in opposition to the plaintiffs' fs' jmotion for a preliminary n_nj:.ns.nct,.c.a'an and could competently Page 3654 of 4165 I testify to the contents of this declaration from personal, 2 knowledge or based on my professional opinions, if called as a 3 witness herein , 4 2 . 1 am a Registered Geologist and Certified Engineering 5 Geologist in California and hold a Master of Science degree in 6 Earth Resources from Colorado State University. I have fourteen 7 years, experience in the fields of hydrogealogy, engineering 8 geology and environmental geology. A detailed resume, setting 9 forth my professional experience and qualifications, is attached 10 hereto as Exhibit A. 11 3 . ERA Wastechnologies has been contracting with the City 12 to provide engineering services in connection with operation of 13 its landfill since 1986 . 1 have been assigned to supervise this 14 consulting work for EBA since November 1992 . We have assisted 15 the City in completing Solid Waste Assessment Tests (SWAT) for 16 the landfill in February 1986 and again in 1988 . In connection 17 with preparing that assessment, EBA supervised the drilling of 18 two monitoring wells located at 87-1 and 8V-2 . (A plat map 19 showing the location of the various wells in relation to the 20 landfill , Vichy Springs Road, and the Vichy Springs Resort is 21 attached hereto as Exhibit B and incorporated herein by refer- 22 ence . ) In response to this SWAT, the Regional Water Quality 23 Control Board (RWQCB) ordered the City—to Will additional 24 monitoring wells in connection with supplementing its report of 25 waste discharge pursuant to 23 CCR Section 2205 . In addition, 26 regulations adopted by the State Integrated Waste Management 27 Board (Board) require the City to continually update a Report of 28 Disposal Site Information (RDS& which it files with the Local y.brn D, 9 9,1 2 Page 3655 of 4165 1 Erif orcement Agency (LEA) and the Board. (See 14 Cal.].fornia Code 2 of Regulatiorts [CCR) Section. 18222 . ) 111 11989 , EPA also con- 3 tracted with the CiLy to perform various geotechnical and 4 hydrological services to comply with State regulations governing 5 the operation of solid. waste sites , like the T,.Jkiah landfiI.I .I . 6 'These services included drilling eight additional monitoring 7' wells and six exploratory borings, geologic mapping, preparation 8 of geologic cross sections, performing aquifer permeability 9 analyses, and analysis of groundwater and surface water quali.Ly. 10 EBA has developed several work plans for, the City in connection. 11 with updating its RDSI and responding to requests from the RWQCB 12 to identify discharges of leachaLe from the landfi.11 and its 13 effect on groundwater in the area . 14 4 . In the course of supplementing its report of waste 15 discharge, the City drilled a well, which has been assigned, 16 number 90-8 . Water from well 90-8 was tested and contained 17 relatively high concentrations of benzene , which is classified, 18 as a hazardous or toxic substance , Benzene, at th.i..s level , had 19 not been detected, in any of the other moniLo.r'ing wells that, the 20 City had drilled., including wel-Is at: the toe of the landfill o.r 21 in samples of lan.dfill leachate. 22 5 , The RWQC2 ordered the City to drill an additional, well- 23 to determine whether- benzene had moved further from the landf..L11 24 in, the direction, of the Ci.ty' s property line . As a resul-t of 25 that O-cder, the City drilled monitoring w,.11. 92--4 , which is 26 depicted on Exhibit B . Benzene, with similar concentrations, 27 was detected in the water extracted from well 92 -4 . 281i 6 . The direction. of groundwater flow is along the slop/ing Dec 3 Page 3656 of 4165 1 plane defined by the stirface of the water, table . Asa res�111, t- of, 2 previous Lest s conducted by the Ci'y, the Citzy had determined 3 the flow direction and gradient of the groundwater aq,,Afer on 4 the northwest side of the landfill , where the landfill toe is 5 located. Howe-ver, in comparing the waters extracted from the 6 wells drilleri at, the Loe of t-he landfill with waters extracted 7 from wells 90-8 and 92 -4 , 1 determined that the waters came from 8 different, i.ii,'idergroi.,im.d aquifers , Wells 90-8 and 92-4 -are sepa-- 9 rated trom the wells at the toe of the landfill by a ridge . 10 Well 92 -4 is approximat-lely 980 feet from Vic-,.,hy Spring, 1"n order- 11 to determine the direction of flow (slope of the surface of the 12 water.. table) in the aquifer to the southeast--- of the landfill , 13 where we] Is 90 -8 -arid 93 4 have 1:ten drilled, we require a third 14 well to create a triangular pattern . T'he third well. in, the 15 triangle will.. allow us to identify the plane of the aquifer and 16 its gradient . "11he proposed monitoring well will be approximate- 17 ly 1 , 080 feet frc.-)m Vichy Spring, From this infori,,iation, we wi.11 18 be able to calculate the direction of flow (whet-her it, is "lioving 19 from the landfill or toward the landfill ) and t.he groundwater 20 gradient . This information is vital to developing a plan for 21 cleaning up the contamination before it spreads and cont-arr'linat-es 22 water used by the general, public . Well 92-4 is close to Sulphur 23 Creek. If the cc)ntaryiination effects groundwater on, other 24 property or the water in, Sulphur Creek, the darnages , alLl-ioiagh, 25 difficult to estimate, could be subs t.laint ial , possibly in the 26 hundreds of thousands of dollars . Until we drill the benzene 27 well. we cannot estimate how immediate this threat may be . 28 Consequent-Ly, on November .1.7 , 1903 , the RWQCR directed the City ."': e p 1 A,;a"9'1\vu'hy I I 4 D Page 3657 of 4165 1 to drill this thii.d monitoring well (the benzene we.11 ) to 2 provide information to supplement iLs report of waste discharge. 3 �A true and correct copy of the letter from Ray O' C<:)nnor to Sue 4 Gocdrick is attached hereto as Exhibit C and incorporated 5 herein. 6 7 . In Exhibit C, the RWQCB d.l.rected the City to develop a 7 work. plan, including well construction, specifications, and a 8 site plan showing the proposed location of the benzene well , 9 8 . Tn January 1994 , 1 prepared the requested, work plan 10, and submitted it to the RWQCB on behalf of tlie City. (A true 11 and correct, copy of the work plan is attacherl hereto as Exhibit 12 D and incorporated herein. ) On February 1 , 1994 , the RWQCB 13 approved the plan and autho.rized the City to proceed with the 14 dr i 11 ing (A true and cor.rect copy of Lhe letter from the RWQCPI 15 is attached hereto as Exhibit E and incorporated herein . ) On, 16 Febriaary 1.0, 199,4 , the City signed, an agreement with EBA Wastec- 17 hnologies, authorizing it to install the benz,ene well . (A true 1.8 and correct copy of the agreement. is attached hereto as Exhibit 19 F ,.and Incorporated herein. ) 20 9 . The City instructed me to delay drilling the well , 21 because Lhe owners of the Viclay Springs Resort had expressed 2 2: concerns thLat the wel,1 might adversely affect their springs . 23 10 . In response to concerns expressed by Mrs . Marjorie 24 Ashoff about a reduction in the temperature, but not the produc- 25 tion of the springs, and the possible effect on a separate 26 spring on their property called the Ardeche Irian. , I commis- 7 sioned additional stable isotope analysis at the University of 28 , California at Davis to determine wh,eth,er the water in the test "'0 d y"':' - P sc%,,mber 19'?6 5 Page 3658 of 4165 1 wells (90 -8 and 92-4 ) could possibly have come from an aquifer 2 common with LI-le waters produced by the Vichy and Ardeche 3 Springs . This, additional analysis took, until .1aLe May 1994 . 4 TI ie results of the additional analyses were consistent with r; previous tests, the waters from Vichy anal Ardeche Spr.ings are 6 similar to each other but different from Lire: water in 90 -8 and 7 92 -4 . On May 23 , 1994 , the R.WQCP, notified the City to proceed 8 wit.h drilling additional wells , other than the benzene well . 9 Because of stated concerns by the x-epresentatives of Vichy 10 Springs Resort that the existing and any new monitoring wells 1.1 might affect their water supply, tlie RWQCB requesLed that the 12 City compile a summary of groundwater quality data and hydro) og- 13 ical information in advance of a meeting w-]'-th consultants for 14 Vichy Springs, the Regional Boar�:I and the local Health .De part, - 1,5 ment . (A true and correct copy of the May 23 , 1994 , letter from 16 the R.WQCB to the City is attached heret�o as EXhibit G' and 17 � incorporated herei.n . ) Ora August 1 , 1994 , the Regional Board -18 requested the City to prepare a summary of information support- 19 ing my conclusion that the existing or future groi,,indwater 20 monitoring wells at the landfill would riot adver-sely impact, 21 Vichy Springs . (A true and correct copy of the August 1, 1.994 22 letter is attached hereto, as Exhibit H and incorporated herein. ) 23 , 11 , On Augi.,ist, 31 , 1994 , 1. prepared a summary report, and 24 submitted it, to the R.WQCB . (At.rue and correct copy of the 25 summary report dated August 31 , 1.994 , is attached hereto as 2 6 Exh.ib,'it I and incorporated herein . ) This report summarizes the 27 data 'arid m the basis for my conclusion that the oni in torg wells 23 have not and wi-,'..l not impact the Resort springs , I had reached 6 Page 3659 of 4165 I this conclusion and communicated it to city officials in May 2 1994 . 3 Based on a review of : 4 (1) the site geology, 5 (2) the effects experienced when the monitoring wells 6 were drilled, 7 (3 ) an organic and inorganic hydrochemical analysis 8 of the waters extracted from wells 90- 8 and 94-2 and waters 9 extracted from Vichy Springs, 10 (4) stable isotope analysis of those waters, and 11 (51 my personal experience and the experience of EBA 12 with the geology and hydros Bolo of the area , I concluded that 13 monitoring wells 90-8 and 92-4 are not impacting Vichy Springs, 14 because they are installed in a water-bearing zone significantly 15 different from and not connected to, or intermixing with, the 16 waLer-bearing zone of Vichy Springs . 17 1 also concluded that the monitoring wells are not capable 18 of influencing the hydrology or temperature of Vichy Spring and 19 therefore , are not responsible for the heat loss and flow reduc- 20 tion reported to have occurred at Vichy Springs . Based on the 21 data developed, it was and is my opinion that the likelihood of 22 future landfill site monitoring wells impacting Vichy Springs is 23 extremely improbable , 24 On October 14 , 1994 , 1 met with representatives of the 25 City) Vichy Springs, the RWQCB, and Alisto Engineering in Walnut 26 Creek to review all of the data complied to date and to receive 27 any information that Vichy Springs could produce challenging my Qcon u clsions , Contrary to Mr. Ashoff ' s declaration , we had a SnUVIQKKWiKYAn' December 7 Page 3660 of 4165 1 vigorozis discussion with the engineering firM representing Mr. 2 Ashoff about the hydro geologic data andi its significance , Af ter 3 that meeting, Mr , Ashoff supplied the City and myself with a 4 letter dated OcLober 13 , 1-994 , prepared by Al Sevilla from 5 Alisto engineering . Thi.s is the same letter that i..s attached, t-.o 6 Mi.:- . Sevilla ' s declaration cis Exhibit.. i . 7 13 . After reviewing tlie let-ter arid letters from Stanley 8 Singer, 1 st-IL.I.1 believe my concl i.isions are correct . The RWQCE 9 an(.-I the Califo-rnia State Water Resources Conf-rol BIcard, Divisicri 10 of Clean Water Prograi-tis , a1sc) reviewed these materials and have 11 similarly concluded that the drilling of the mcni...toring wells 12 have not- been the cau,,,-;e of any observed changes in the Vichy 13 Springs and are very unlike'.1y to cause any such changes in t-he 14 futi.,ire , (See October 28 , 1994 , letter from Ben4arnin D. Kor, 15 Executive Officer, Regional Watei." Qi_iality CoriLrol Board, to en-4 amin 16 Charles L. Rough, Ukiah City Manager, and M�.-_-moiandum to B 17 for from Harry M. Scluieller, Chief, Division of Clean Water 18 Programs, State Water Resources Control, Board, dated October 31 , 19 1.994 , attached hereto as Exhibit J and incorporated herein . ) 20 14 � In, the October 1.3 , 1.994 , letter from Alisto Engine er- 21� inch, and in the Declaration of Al Sevilla in si_ipport of plaila- 22 tiffs ' comp'.1aint, and application for irrItinctive relief , Mr . 23 Sevil.la COntends that the drilling of well 92 4 caused the 24 decreased flow and temperature of Vichy Springs , He further 25 beli.eves; that the drilling Of tlie benzene well will catise 26 further degradation of Vichy Springs . 'He bases this opinion on 27 his view that: nc other event in the area other than the drilling 28 cf well.. 92 4 could account. for the sudden. decrease -in the flow i\u\p.Wqn9,1 I,vichy brn Page 3661 of 4165 1 and the temperature of the Vichy and Ardeche Springs . He 2 speculates that well 92-4 punctured a "non-hydrostatic geologic 3 zone" which allowed gases to escape that come from the Vichy 4 Springs through faults and fissures in the ground. He and 5 Stanley Singer contend that this reduced pressure caused the 6 flow from theysprings to decline and the temperature to drop . 7 e also criticizes any investigation in several respects . 8 He maintains that the City did not follow standard well instal - 9 lation practices in drilling well 92 -4 and that the reasons for 10 locating the well are questionable . He claims drilling of the 11 well did not follow standard practices, because I did not 12 backfill and seal the well , when it did not fill with groundwa- 13 ter within twenty-four (24) hours after drilling. He questions 14 the methodology, because he believes that a well should be 15 drilled at the probable source of the benzene contamination, 16 which, in his opinion, is the landfill , and not in the location 17 1 selected. 18 Finally, he contends that the existing wells should be 19 sealed to see if the temperature and flow of the Vichy Springs 20 increases . He believes this should be done before additional 21 wells are drilled. He also believes that we should first 22 prepare geologic cross-sections and mapping of the area before 23 drilling additional wells . 24 15 . 1 disagree with the arguments of Mr. Sevilla and Mr. 25 Singer . I will state their contention followed by my response : 26 a. Ihere is no Justification for drilling well 9,2,-4 the two exisl.inq wells are not in a water bearingzone and a 27 Aird well will not grovide valid data re.9Ard-ina t _gra �ant are flow directi2n. 28 , Contrary to Mr. Sevilla' s assertion, it is not standard industry \u\pldqs,'94\vi ch'y Inn �994 9 Page 3662 of 4165 I I practice to abandon a well if no water exists within a 24 he: 2 period . when drilling monitoring wells in low permeability 3 materials, it is common for wells to remain dry initially for 4 many days or weeks . Regardless, we fully expected well 92 -4 to 5 take considerable time to fill with groundwater . This was based 6 on our previous studies of the site geology and the behavior of 7 the previous monitoring wells that we had drilled in this same 8 geologic formation . In the past , we have had to wait several., 9 days or weeks after drilling a well before concluding whether it 10 would provide useful data or not . 11 Wells 90-8 and 92-4 are installed in Continental Basin 12 Deposits . As pointed out in my August 31 , 1994 , report , this is 13 one of three major geologic units that exists in the vicinity of 14 the landfill . These deposits are estimated to be in excess of 15 2 , 000 feet thick in the Ukiah Valley area and consists princi - 16 pally of highly consolidated silty and clayey soils with minor 17 gravel lenses . Water percolates very slowly through these silty 18 and clayey materials . The boring logs for monitoring wells 90-8 19 and 92-4 indicate that they were both drilled through continuous 20 sections of clayey silt and silty sand of the Continental Basin, 21 deposits . No gravel layers, confining layers of clay, or 22 bedrock from the Franciscan formation was encountered. Under 23 these conditions, it is very difficult to obtain water from a 24 monitoring well . Mr . evilla' s statements about industry 25 standards are simply incorrect . 26 The suggestion that the wells are not constructed in a 27 water-bearing zone is surprising given that groundwater samples 28 � are routinely collected from them. s, \U',PJxJgv,J1 1,vichy.lnrn Wcembof 1h Page 3663 of 4165 b �No 12 af2j�2 is investigation si,lpj2orts, the location of the benzene well . 2 The purpose of the benzene well is to determine the direc- 3 tion in which the groundwater is flowing in, the area southeast 4 of the landfill and the gradient of thc5t flow. Even if we dr,illed a well directly into the landfill , as Mr . Sevilla suggests, and discovered leachate with similar concentrations of 7' benzene, that: would not help us in determining the extent of the 8 benzene contamination in the groundwater, the direction in which 9 the benzeiae contami.nated groundwater is travelling or the 10 gradient of the groundwater . '.she only way to obtain that infor- 11 mation and to further characterize the extent of the benzene 12 contamination in the area is to drill a third well creating a 13 triangle in relation to the existing two wells . 14 Contrary to Mr . evilla' s statement that we have made no 15 effort to assess the impact of waste disposal on the underlyling 16 groundwater, we have performed an extensive assessment of the 17 impact to groundwater from the landfill . Impacts to groundwater 18 have been detected in a nUTnber of wells downgra,dient of the 19 .1.andf ill . While the nature of the groi.,indwater impact at the toe 2 0 of the landfill is consistent with our experience at other 2!1 leaking landfills to wide variety of compounds at relatively low 22 concentrations) , it is significantly different from the contami 23 nation observed in wells 908 and 92 -4: which consists primarily 24 of very high concentrations of berizene along with low levels of 25 toluene, xylene and ethylbenzene periodically detected, While 26 these compounds are common constit.tients of gasoline, the con.- 27 trast in concentration between benzene and the other three 281 compounds is tinu,sual for gasoline impacted groundwater. kil,3994\VI Ch'/,DIM Page 3664 of 4165 1 Moreover, we have collected no objective data to date, 2 suggesting that benzene is escaping from the landfill , No 3 sample of leachate has detect benzene and—only one well at the 4 toe of the landfill has detected benzene , This well (90-5) 5 consistently has concentrations that are orders of magnitude 6 less than the concentrations identified in the test wells 90-8 7 and 92-4 . while the landfill is the most obvious source, there 8 is as much reason to suspect a source outside the landfill, at 9 this point , as there is to suspect the landfill . 10 we have determined the direction of groundwater flow in the 11 western area near the toe of the landfill . The groundwater 12 encountered in the landfill toe wells is chemically different 13 and separate from the benzene impacted groundwater found in 14 wells 90-8 and 92 -4 . Drilling the benzene well will address all, 151 of the questions that the Regional Board has requested us to 16 � investigate . Drilling a well directly into the landfill would, 17 not answer most of the important questions that we need to 18 answer at this point , 19 C . Wells 90 -8 and 92-4 hay.-- rated eith,gr a n n o - hyQzgLLn!ic -IIressure—zo wo clot neferent ecicc xc znit. r a 21� Our previous geologic investigation convinced us that the 22 Vichy Springs water comes from the Franciscan formation, which 23 is a separate and distinct geologic unit from the Continental 24 Basin deposits in which wells 90-8 and 92-4 have been drilled. 25 Rocks from the Franciscan formation are much older and deeper 26 than the Continental Basin Deposits , The Franciscan formation 27 consists of a mixture of various types of rock, including Qsandstone, metavolcanic rock, greenstone , and chert . The stable s;%\0dg"4\wxhy hm 12 Page 3665 of 4165 -s V 4 1 otop o e analysis f the from the water fro the wells arid the 11chy and 2 Ardeche Springs clearly establish that they c,orne from separate, 3 d.isconnecLed a(p,i]..fers . Moreover, the temperature of the water 4 ..n the wells was significantly lower than the temperature in 5 Vichy Spr',Lngs . A review of the boring logs documenting the 6 geologic materials encountered during the drilling Of the wells 7 demonstrates that two distinct geologic units were not penetrat-- 8 ed. 9: Reco� gniz,ing that the waters come from separate aquifers , 10 Mr . Sevilla suggests that the test wells have tapped into the 11 gases which drive Vichy Springs . This theory would explain how 12 wells which have not tapped the same groundwater that supplies 13 Vichy Springs could impact the flow or temperature of the 14 springs . 15 ire calls the zone that the wells penetrated a non.-hydra... 16 static pressure zone . This means that the water pressure ill 17 this zone is created by active tectonic stresses rather than, the 18 pressure created by the water itself . In effect , he contends 19 that the City' s wells popped the balloon which contains the 20 pressure which drives Vichy S-pri.ngs . By releasing the pressure, 2,1 the wells lowered the temperature and. reduced the flow of the 22 springs . He hypothesizes that, the gases could have travelled 23 from the Resort ' s geologic formation to the well sites through 24 faults or cracks aligned between the two zones . 25 The occurrence of tectonic overpressure zones in the 26 Coastal Ranges, such as the geothermal fields near (E-1eyserville, 27 California is well documented. However, I belie-,.re Mr . evilla' s 28 Hypothesis that, the wells are responsible for the release of ,e,,,e'rnbrer 9, �994 13 Page 3666 of 4165 1 gases that have migrated from the springs to the wel.ls through 2 faults and frac-tures is clearly flawed and n,ot worth serious 3 consideration . 4 1 base this op]..r,,.1..on. on the f0ll outing: 5 (1) A review of published fault maps and geolog- 6 ic maps, of the area do not ,::'how any fau.lts or fracLiares sets II 7 through the area of Vichy Springs i:esc,:)rt ancl. the area of we",Lls 8 90-8 and 92-4 . (California Division of Mines and Geology, 1982 , 9 Alqu.ist-Pric,.To Fault, Map, Ukiah Quadranc. le. Clark, M .M. , et -7 10 al . , 1984 , lip-Bute Table. and Map of Late--Quaterna-z-y Faults of 11 Cal.i forma U.S . Geolog.ical Survey, Open, File Report 84 - 106 . 12 Jennings, C, '4 . , 1975 , Fau]. L Map c",)f California wlt-,h Locations of 13 Volcanoes, Thermal Sprin.cfs azid Therma.7. Wells: California 14 Division Mines and Geology, Calif . Geol. . Data Map Series , Map 15 No . 1 . Jennings and Strand, 1960 , Geclog.ic Map of Calif"ornia, 16 Ukiah Sheet.: California Division of Mines and Geology , I-Tart , 17 et al . , 1983 , Sunn7ary Report, Fault Evcil ua Lion Prograzir, 18 1982 Area (North ern (--'oasL Ranges Re.cfion, Califo .z-nja) » Caj ifor', 19 nia Division of mines and Geology, OFR 83 - 10 , SIT11-th, et al . 201 2982 , Fcni.lL Evalr,iation Report- .- Yaacama Fault: (Central ai,'2d 21 Nortlhern segmenLs) FER, Nos . 123 , 124 & 125 , California Divi - 22 sion of mii-tes and Geology . Upp R .R . , 1.982 , Holocene Act-ivity 23 on Lhe Mziacama Fau]. L, Mendocino CoiznLy, California : PhD. 24 'I'hesis, Stanford Un.iversi't.-.y . ) 25 (2) ()n a numbE,rr of occasions , i have reviewed 26 numeroi-is high altitude and low altitude aerial plaot-ographs ar 27 t-he area where the wells were car illed, and I have determined 28 that there are no photo lineaments present in the Continental bn I 2.4 Page 3667 of 4165 I Basin deposits whi(,.-h would indicate the presenns f,,)f faults or 2 f-r-acLures which could i-_)r,cvide a pathway for the migration of 3 these gases . 4 (3) Observations ma-de during geologic field 5 mapping of the area noted no evidence of faults, fr.actures or 6 joint sets within the Continental Basin deposits in the vicinity 7 of wells 90-8 and 92-A , 8 (4) Observations of the geologic material Lhat 91 we extracted fi.cm I[-Aae well while it was being drilled, demon-- 10 strate we never enccuntered Franciscan formation. bedrock or any 11 evidence of a confin:L.ng layer that would have trapped gas or 12 allowed it to pressurize water . 13 (5) If we had enetrated such a confining layer, 14 there would have been some evidence of a, pressur-e release . 15 Nei�...her during the drilling rior after the drilling have we 16 encountered evidence of significant changes in pressure within. 17 the well.. . 18 (6) Our experience with the migration of methane 19 gas from the landfill through the Cont.inental Basin depos.,its 20 suggests that these geologic materials are not capable of 21 holding gases under pressure . 22 23 Mr . Sev.illa' s suggesticri that the water encountered in the wells 24 may, be from a pe-rched aquifer does riot support his conclusion 25, that the wells have impacted Vichy Springs and while this 26 suggestion may have implications for benzene migration, it is 37 riot relevant to the rest of his discussion. 28 , d. Need fur"Cher qeologic- _Lnyt�t q—a ion fre f ore (.Iri,'I,liDcLa �,�,iti(.-)nal wells . Gec(Inr' 1994 15 Page 3668 of 4165 I we have already completed all. of the non- i.ritrusive geologic 2 investigat-ions that would pz.'oduce usefi.,il information in, predict- 3 ing the effect of drilling the monitoring wells on the Vichy and 4 Arrieche Springs . The City could perform some additional geolog- 5 is mapping of fracti-ires wait hi.ri the Franci.sca,n forination in the 6 immed.11.aLe area of V_"I.chy Springs . This data would only supple.,.. 7 rnent the informal obser-vations i have already made during a tour 8 of the resort, given to Tne and RWQCB personnel by Mr . Ashoff . 9 However, , this would riot provide the City with any additional 1 I 0 informanLon that would increase c.,,u:r,- Understanding of the geology 11 between tine wel..'.I.s and V.1ichy Springs . Contrar.y to Mr , Sevilla' s 12 conLention, we have developed cross sections and mapping of the 13 geo1c)g- c zones . The structure and or of the gec.loqic 14 beds (strike and dip of bedding planes) has already been docu- 15 mented and is well known . Without additional subsurface boring 16 data, a cross...section treading toward Vichy Springs would 17 proii.de little benefit , it would simply show a th.ick (minifflUm 18 26,5 feet. deep') zone of Continew-al Basin deposits with the 19 Franciscan bedrock I-ying below at some unknown dept-h. 20 e . We-1—Is 90-8 and 92-4 shoul d be backfi'.[.,led and ................................ e a I ed. to see if the sD,T, ' i n rT c. r e c c,y e.r be f 0 r e- d r,�11 �,_n�...........Uie benzene 21 Ige-1-1 22 There are two reasons why i� is not necessary or advisable 23 to backfil.1 and seal wells 90-8 and 92 -4 . 24 First., it is riot necessary. Both wells can be sealed 25 pressure tight without backfi_'Iling , Above the screened bottoii'i 26 ,-)f the well casing that allows, groundwat-er to enter, tile bore - 27 ho-le is sealed with bentonite and grouted to the surface and the 281 top of the well casing is f.1 e..ttd wit.h an airt. ig ht ca TIp . lie 16 Page 3669 of 4165 1 benzene well will be constructed in the same way. Presently 2 well 90-8 is fitted with water sampling equipment that does not 3 provide an airtight seal , however, this equipment can be moth- 4 fied. Well 92-4 has continuously been equipped with an airtight 5 cap . The well is only allowed to vent to the atmosphere for 6 less than an hour every three months when collecting samples . 7 Second, the two existing wells may be useful. or necessary 8 to futi.ire rernediation of the benzene contamination once a clean- 9 up plan is developed. Backfillii--ig and sealing the wells now may 10 require re—drilling the wells during the implementation of a 11 clean-up plan. 12 16 . We also do not have reliable data on the degree to 13 which the flow and temperature of Vichy Spr-ings varies over 14 time . In his declaration, Mr . Ashoff states that the flow of 15 water from Vichy Springs was reduced from a normal rate of 65 10 gallons per minute �gpm) to below 40 gprn. He also states that 17 :i the temperature when from ninety (90) degrees fahrenheit , wh-ich 18 is the springs ' nor'mal temperature, to a low of around seventy- 19i six (76) degrees . He attaches as ExhilDit 1 to h--i,,s declaration a 20 list of gallon per minute and temperature figures for the Vichy 21 and Ardeche Springs . 22 � For example, Exhibit 2. shows that in 1-979 , Vichy Spriings, 2�3 had a sixty-nine (69) gpm flow . However, according to a hydro 24 logical field test report suppi'i.ed to the City by Gilbert Ashoff 25 Batt.ached hereto as Exhibit K are the excerpts from the 1979 26 , report furnished by Mr. Ashoff) , the Vichy Springs produced a 2 7 natural flow in December." 1979 , of 3 . 4 liters per second. At that same time, the Ardeche Springs (discharged one liter per \Vic!y,hrn Page 3670 of 4165 I second . 3A liters per second converts to S3 . 89 caprn and 1 liter 2 per second converts to 1i-S . 85 rip-n. The combined output of oth, 3 equals approximately 69 gpm. It appears that Mr. Ashoff may, 4 have improperly, combined the two rates to report t..he 69 gprn flow 5 rate thaL Exhibit I shows for Vichy Springs alone . 6 In addition, if the Ardeche Spring was flowinq, at 15 . 85 gprn 7 in 1-979 , accord.ing to Exhib-it 1 , -i-ts flow had already dropped 8 over 3 gprn between 1979 and March 20 , 1993 , which is just. before 9 well, 92-4 was drilled . After the dri.11ing of we,11 92-4 , Mr :L 0 Ashof f reports that. the Ardeche Spring went front 12 . 5 gpm to 9 . 5 11 gpm, which is roughly the same amount of reduction as occurred 12 before Llae well. were dri.11ed. In addition,, if , as Mr. Ashoff' s 13 data suggest , the Vichy Spring was producing 53 . 9 gpm in 1979 ' 14 it, subsequently increased in producti�-)n to 65 . 1 gpin in 1980 ; and 15 then after the drilling of well 92-4 , went down to 40 . 5 gpm. 16 According to a U . S . Geological Survey paper dated 1.915 on 17 f i l e with the RWQCB, and al-so, referred in t1ae October 31. merno- 18 randum tc the RWQCB from the State Water Resources Control 19 Board, the Ardeche Spring discharged 8, gpi'i�i and the Viclay Spring 20 ab out 1-6 gpm, as compared to a vol.ume of 9 . 5 gpm and 39 . 3 gprn, 21 respectively, report.ed by Mr. Ashoff for October 13 , 1994 . (A 22 true and, correct copy of the 191.5 paper is attached hereto as 23 Exhibit L. ) Tlais shows, a substantial fluctiiation in the output 24 of Vichy Springs both before and after the drilling cf the well. . 25 The temperature f luctuaL ions are equally inconclusive . 26 According to his own figures , the 'Vichy Spring had a temperature 27 Of 93 degrees i..n 1989 . By March 20, 1993 , that temperature had 2 8 gone down by 4 degrees . After April. 7 , 1993 , the '_-emperature 9, 1994 18 Page 3671 of 4165 1 went down to 76 degrees and has since recovered to 86 . 5 degrees . 2 This information suggests that the Vichy and .ire eche Springs 3 have not maintained a consistent temperature or rate of flow 4 over time as Mr. Ashoff asserts . 5 Further review of the literature show significant historic 6 fluctuations in the flow and temperature of the Springs as shown 7 in Exhibit M. As documented, this table compiles flow and I 8 temperature data for Vichy Spring from 1889 , 1915, 1965 and 9 1979 . 10 3ased on my review of the literature, I believe that 11 mineral springs frequently change temperature and outpuL . These 12 variations can be due to intermittent mixing of surface water 13 with spring water, temporal variations such as seasonal changes 14 I or longer periods such as drought cycles , and seismic activity. 15 Even very minor, otherwise undetectable tectonic shifts can 16 influence both spring discharge and temperature . For example , 17 Exhibit L reports that the Vichy Springs outlet moved 3 -4 yards, 18 apparently—in response to a small local earthquake . Further, 19 the great 1906 earthquake reportedly did not affect Vichy 20 Springs , 21 Even if the flow and temperature of the springs changed 22 significantly thirty days after drilling well no. 92-4 , as the 23 Ashoffs claim, that fact alone does not , in my professiona]. 24 opinion, establish any cause and effect relationship between the 25 drilling of the well and the observed changes in the spring . 26 All of the objective hydrogeological evidence indicates 27 that there is no interconnection between the well and the 28 springs . 4'7 9 4\ Facemher iV 1191 19 Page 3672 of 4165 I true and carrec-L . 2 Executed LIllis 9t?i day cif December 1994 , at LJkia,�, Califor- 3 nia . 4 5 D �CAN F BR 7 8 9 10 11 12 13 14 15 16 17 is 19 20 211 22 23 24 25 26 27 281 9, ).99,1 20 Page 3673 of 4165 GEOLOGUST G Colo gist, CaEforma '-'cTt3f',e n riva,' Ciecll g'st, C ili:fornia R rod 'f> tf anal Gcologis Wyoming Rq;Aered : ttvirontrI Ul A. cam, C: ifbrctld. C SI ' 110aE t:y zzu`do" W&Stc At"Civiti s Training Private Pilot tic C roundwatezw SC ,utLts and Engine= of.NGW- Calh-fmaia Gmund a ur" Association Cy *Tic SoLiety of America GSA SCYCiety, for Serfime-nt ry Ciwjogy (S l C010'1- lc St ft UuiVer ity, Ft.. Collins, Co Thliv fty of C ili orrts"n, au C:cu :. C.A.l�.S. l^vth Sciences Mr. Brown wrr is a mfogi: t with over .tcja yam; of ex r in tkre .�1d� 1 It lr oto"Y, etaggme=I ,eulog�, and env�ir jim.mial geo has expeneace in: n, and rala e ac: ge laa,,icJ invest%gatioi s, hydxogcolog c characterizali,01, inve,-, �,aLion ..a tue-Ja.:linvesti aliordeasibilityStt i,= S for landfill-arrdiatdmstrial. sitaf,yil'Zzldous wash c: n a r.tton studics reruc iai a ticm design Ertel implementation f emu. a�ro ?,f0U dw-4Wr corm the action pmgn njs. fauLt and la tdslat' luvesti t ort. „ colonic d% tmtionS, borrow .inv=,clations, and enviruamentai it pv,,: At a irra.c to;ice, e is ,or a pplyingis epelicr, rat .�c.lne,t Of ge io tc artd lrydrogeoolog c lrrvesti. ati.ean in szupp rt of tht flt1's sanitary kmdfit and. lr rdo r waste 'J' -1 f"c"dty PJ)=ta_ F10 has supervised merrou 1&,,,lc d rltale ttavg ac ' md xa lta- rd" N EXHIBIT m^'e Page 3674 of 4165 cf 111me Inv stigati,o s have r ;ir;-1 photogeologic in")retaim oa-regi cxi[o c slapping, eOO QxPlura : , a� �a� �� � ��a� ��s a� �s��, �r� a z� monitoring, ouaa ry t rsnit or well ir' llwion, aquifer testingand yes, and soil aud ground or li qg and analysis. At waste, dqWsal its 1T .off. C� s �, dzv to t of":n ' and ��tu��d�,at r rrwoaitorirL ilorr a, he ha.i 3�laa cd and plaw, evaluation of wgim-al Sehsmiicity and g, and evaluation of I-dope stability. In addition, he has conductal borTo and final cover rove tig ptims for mste d Vosal l tilitie and invettgated MsPectad mil. and 9mundwat r COul �E m n at. a: number, of pdv .i dugt:rlaf sites. PAW LO joining l B , Mr. Brown emod ctcd a Fide range of geologtc svAes in C�lifomia. These, studies nclud waste di..; sal, regutato:ry comal.ia nm, site a�sss:raerLttrccu ii n, gWlu is ha ards and Tm-drch of acfivu and potentwly aefivoe, fault' inchiding the as Andreas, E(aYW-ad, (.'�Uavea-s &, M Gregorio, San Sime on:.- HOsgri, , argen . .ail d S Mors fAullzs. He a also ihC for c td :t aI site Specific geologic anal geotechniail iruv ° agauoas-tor rc.sid t hillside dcvelopaliLmt, landslido repair and e trttrol projects,ec f potentiat and sedi eAlt sport: studies, and, l tidies of S-ei cliff. rosion and littoral d-Tift.. Project c ct manager and ..nor ye alo,; t fox a f13m lfl"larICT-ll in Mendocino: County, CA. project, inclaides die, -,%panmoct of an oxistuig �g 111 la des and tlx: design cif,m ct v action altern Ives for dle acmediatio of :lt=Jiatc auad V C� impa ed rour. .l atc at die "T of the landd.Il. Identification and, mixing.ing of multiple hydr.ogeologic and by heel m-,,7an °a.s CritiCal to the d Vclet rtt and ev lu ti(zrc Of C dv Moirit:ori , and .,wrr :five ac i programs. The use of t ,ble.isot qx- g,&och .misty techniques!provided 54-, -cauL eat savings for water gtaaUty monitorin'g- Task's k6lude. ration of Report of Waste-Discharge ROWD)- u ratio of ROI)ort of N-sposal il<.� f limtcatiort (P. 1)- lc pment, of 1.'Water t, utility MonitoTia, is accoreiaat ;w.tlt C C a 1"itlo , Chapter 1 , �'ticl eta of . . o Rommel 1av atio esti nnfl ea.ihdit 'Study for l�hate awad OC impacted r ester. Piquiration of Remedial Action Alw-raafi.v PrJimimry ClosurelpostClosure M."'J'atmaTIM Pl:r s. Page 3675 of 4165 DAMDN F. BROWN. of 5 QM,Mzly water qu2liq- monik)rin,, NI)DZ'S PCMI lit stud SIT,17al q p,, an_ 0 -rved as P`oJect mana,-er for an cXtmgive jul ph SL yd_ invCfMgation and ckiarazw-ri�- a d h 'alit 11 for �Remedial lnvcSG9zti()DfFe�w-b, S for a Class I fixmidous landf-ill f,)(jlit3, in Los Ange iNt tI d I/FS) &v&OPing a ry--w i6eid offce .with orl_,,tz c Aes CoUn-Ly, CA. Tasj-s inclu(jed .,J hexnical and. geOMChnical au,-dydcMl caPabilities, SupexvLsing a 15 ram, fleld cmw =d Muld, driffirig wollcx1s;supervjqn * Pje dniff, ligs Using four difftrenj in=,Uatiorl Of Piewmeters aad Iysimet--rs;perfbnu.Ld I&Tmeability (pcck�q) testiag; downhole awry is rl 1 and groua�ivatcr --am -rMr performed aquifiar testillg P t" Progmm dusiga undkT. the Lnlida= cIf th Calif Depa,rtm Lnt Of Ilt!aItf, Sclvk5e-s (Ilow DTSC o-ru a 0 het inanagerrind CoustrucUon QLIRY Control(CQA)officer for closure c(,gI=uCIjon af-dviti-S at an 80 aele� ITT Manicipal landfill andCIMS f ha-&udoiis W-zwe Site in L NOrthcru Califo-InIa- Reslx)nsible for OvOrall project coordination including, borrow "'Ante investiPtiOn, test parl. analysLs, placem,,11 oIf engillet: clay cap, and drminzge control facihtic�,S. Ga)fo Md fill, low JKTnIcabilifY gy Proj=t nmnager i ve iavolved tlePning g Ille n stig=ion, roimd-w--ler flow t,*0nditiOI)L9 and PotLH.. fial ixith.ways for die Migration of(�Ontnminaa+s release" 1c)m the CI M landfill and C12&s I d hazardowi warz null. Presmtly prcx,,C��TIg with tf�e remedin]. P(Mts benec&the Lzn ass liqui requirtmeats of both the ' procM to Satisfy the DTSC and the RWQCB for beneath and downgradicul of the sjtc. cicautrp of Mnt;uirtmt reieaseq� &-rved as -WI02 b ,Jc PM i W man,%,(v for the "Pansion of an exiSting Clam TU,'IandTl in Napa Coun�y, (2alifo: Tanks included &"Iundwater -monitoriag wells, Polo,& field mapping, ��rcnof, tbilittudy, ReTons 19and �ll` sisOf galand gTou-ndwfor t.be Of & Mbsfor Develuprrr,Ute.and OPemliO-ns da-Scriptioas required in designed it) T-IlrnW, the I�eporf, the Report of wxqe ge (ROWD) for the Regiolull, Wal2r Q11 j, Co al tv atrol. Board, and dic Report of DJsN.,nI SitC- LafOrlluatiloa (RDSI) eaginecring Report for thf- W_ Mallav �,'WlOgist reSponsible fo en =- -eologic evalEwien Of cn� czxarvauons at a class l[I ('ouaty, California. ITcject illcludW ZeOlOgic mapping, fraeure aualysis� and idendfIcation and niilipption, )=ion m Perilleabdity subgrzute inalerials in five ex, odules. Sery zL for in-siw field P=, (-%VIiIiIY in"eligation. 'turd incl,ud ed s pro,(�Ct gcx)10_�ist ,c,�i in-SiLu field and for for r IWnilez,ibility testim- of naft ib , 11�criah d engin=ed of liner Page 3676 of 4165 DANtON F. �BIROWN r , R-G.' C-EAlf". 4 (if 5 gab-on to evdualz potential soil LU 1111andlailsin tht�Mcndocino National Fomst, f Cd""fccll� PrOject ificludeAl ins aftoii of grouadv4iL-r inonijojillg-we", ar,d 'm2iy-,Sis 0"soil aiid,;-r(nmdwaI-c';r- �zlmp]'ing aiW, r arc with CCR Title 1113, Cliapter 15, and Sudd Waste AssessmLmt Tait WAT) T��qlri'renl -SU'PCr4,%LXf "Wlogic and hy a .> .(fro-W'Iogic i"Wstigation for Solid Waste &s 'Ljlt rest (SWA'f) in -=rdance with thL- r Oquacments ()f B 525) at a (1,1, landfill in Santa, (.11ra ('.' fo , Caldema Bill (A] 3. ss a, groum(Imater contaminad "ounty, Cali '4L Ata�cd landfill ciiaractL,,rizaCjon, and cxisdn� bnort ark' T'CMcdi2Ii0a feaSibilitY Study (RI/FS) for an g Class III Landfill. PrOgmm designed in a=rdaNce Willi CCR, '-Fitle 23, Cha pwI7 15. Gcolo- U PrOJ= Manage',- req)m!dble fOr deVeloping &-sign crifexia u) effects of'sliallow groundwuter,and H'OlOcCne faulting associated vvitII Ib 2-CL-tss TU' land fill CxPansZou prcjject, Tasks incLidal ;:vW-nsiLve exploratury trcm- Ching across ar--ive of the Calav=.,3 fault, cond'uctirig a trexiinurn p1n,,)bable ea:rthcp2ake evulI,IIhc)n to develop strong,gimund motion-and grolmri rT.Ipture de!;agn p�3'rametam, aquifcr testmg, vado.,�x--z(,me irionitnrir,,g and expanding cxisting gioundwater monitoring syswm 10 evallurw hon' zonril and verti oil ,-,;rotradwater gmdiCnIs t�cneath base liner. 0 SI'Per'vised 9cx)IOgpa and f,ydr09Cx)l09iC Solid Waste Assewmenj ,inve�,;d. .I. Te-I (SWAT) gpation to ev,,I,JI1AtU Ntellfial siail mid. gTrOlindwatur cmiRmination, at tfx(,) Class I'Ll JAIAL-11 faddes in LA-e Cojrnty, C,11ifUr 1,1. qasks inclucled 1MI,1 and ly,,�.meters, a an nd soil �l groIITId%-atcI., sampliAly and anajysis 11;Uicyn of pimometen 0 !?reject 'P, 0109iSt Msporizible for die prrq)axati.O�a of I t of Wa th-reqg�rcments of lzqo �epoq: Di:;cbazgc 42 acco-'Wvrwe with 121 (�Ilality,io, Control Board, and a Rfivr of DiSPOSal Site bibrulatim Repait in d 3�� requirements of th[ e S�olid Wasta Maiiap acccr allc wi.th ,-he ,ement Nmrcj for, a I)r I (fislx)sai alto in cW'saj major CLWS I', Nalla Coulity, califtmlia- 0 Prclrara-d SoUd Waste AssensmeMt Teat. (SWAI) E-Kernp tio.11 for tram'fi stzimx l 6.1.ity loczed aa abando�, landfill site in S"ta C Canty, 0 I-tlglineen.',.I 10`0 MI resix)n-sible for conducAinll Holocene f, -it investip,ti t,�%pansiorn of a ClaF j� on atory tTCrIdII'M� _-e�v of t -UMO -a included c:qifor ju T� -il facility '11 S--nt�- C7;�Iml (:�)untY'� Cal f as. �IS tla� he Sh' n f ult, and Carbon-14 1010 dat-im.) Geologist ret"Tonsibie for conducting a �,e%,)IoD- cand hydrogoolo 'C. inve5ijgadon of suSp=I---J hazaidous ,v;Lste at a BLISS II SUH(I wuslx dispisaj site Santa Cara Coimty, (:afifornia_ Page 3677 of 4165 DAINTONF. BROWN, 'R-G., 5 of 5 0 Rcq,)oivvbIo for cx)nducting H(�IcKx,ae FmIlt iu"Vestigalioli and LjqtjrF tc- acjinn POL ,,ti,-1 and landsEde ha72j,,&' for (AxPaasiOn Of-,' Cl=, TIJ landfill ibcH.j Obispo CAminty, Ca.Ufumia- Tas.%-,s includbd explor-jin cross j ty in truiching ajr f t, Indial, K."oh-F4na ,faWL ry he IFi=L[ing GeGIO�,.S[ reSTX)'Dsil)le for the invatipwon (if rrginwd tectQn" and stismiziry and development of s6snlic desigll Imramctem fog` over 20 sauilary landfills wid Hmard(jn waqc hs?osaj SitLn� throu.tIout Califor .7 0 PrOity-t Ot*109iSt regmsibic for geologic mzPPiDg, Fvctud wiaiyms, and (xmstruction oba!rvation of a decp prcmjw-,AjL-r x, 9--rCLPtc-r tm-nch in highly ftnctured bodrock-as paft of a ?,romdvater contaminatimi remediatim progran, at a (� ,s It, landfill site jn AL=eedn. County, CA&omia,- L-VA-, Page 3678 of 4165 EBA. W'aswc1l,riologies has ix=Prmiding engjijc=ng and lrydiogetilogic UjL,;tj'Uin'qscT-vi= for 11,1e Cil-.Y Of TJIIa,h L UldfM,sime 1986. FBA has pefforined followin, technia3j invesdgatiolls: 0 1986 - Geologic and hydrogenlotc inVeSb9ation for Solid Waste AssmqnL-nt T t (SWAT) in accordance 'with the of Caldemi Bill (AB 3525) at - Land El 'rasLs iuLLu(jed installalion,of two rev groun dwatL thL kialt rrtorrita_Trig Urells, sampjing and analysis of RNe gjoundwateT jaiomfDring galls toy cbzn=,a7z ,potential,ijTVct to groundwater from landEll activi.tic& 0 L989 - Fngincers Report and PerInitting d0caments for the Uldah LandfiU. PtqxuW Discharge i)a accordwee, with requirements of E-ngi=-vs Rq)oTt, P: Rqynt of Was I RWQCB, and M Rqx1rt of Dispomi Site jmfOnllafton for submittal to, CalU 'ntegmted WaSW MaTmvernent Board. Tasks included instMation of nine addition'-d grOUndw-2termonitoring wells(maximum, 160.feet deep),drilli Ioratory,l)K)Tjngs Onaximwn 265 fm,-t deep), c sera to Mapping and prep2mlion f I Pedo,rjuingl aqiffer Permeohility analyses, an-djvms of 0 geo 0 ic cross secti()r1s, quality, per-peton of grarlin groundwater ajid surface water investigation. c and Ml.Plans, aml-Ysi's Of site capacity and barrow %ite 0' 1992 - Reinediat investigation and peTmtting d0CUU=tS for the Ulwh 114indfill- PTePazed. (1) revised Rclx)rt of Waste Discharge for submittal to RWQ(-'B,, (2)1 Report of Di-STA)sal Site Tmfarniatiun for awlylB, (3) Water RW MitorN pgram iact2nm with (,CIZ Title 23, Ompler 15; Article,-) for QCB, (4) IMES, jxm-r�t and Storm WaIL-q- Pollution Prevention Plan. 'rasks included installation of four additional -Tmimdwater moaftorino wel (maxim'Lm 130.5 feet da—,'p), dlillina' om t: exploratory boring (26 feet deep), air P410to analysis, 56.smic refi-,=ion. analysis of' Landfif4 hydrochemical wd stwistical analysis of groundwata and smfzce wamr qimility, stable isotope analysLs of 13Dundw-ater, chamL-ted72fton Of VOC impacted groundwater at the toe of the land W- 1, erosion and skWnerit, control analysis, and analysis of site Capacity. - Landfill gas migradoll investigation, pn*—a.re Preliminary Closure Plan and X-jLDtej=ce plwl, additional J1ydrogeojo,' m ji pC vC--U,11a on to furtfier c1=wA--rizc the cxfent of benzene implact and, diredi(nj of groundwater flow. Tasks included Us-ud&tion Of tuo, additional groi-mdw-ater =nitoring Wells (j>eZfbrU1cd sq)tember 1994, maxinium 7-5 deeP), devconr ML-12t, of I-andnil Gas Pctinewr tbTlitorim,,,; SY&U--In, installation of five landflU gas toring wells (Maximnrn 250 feet deep). Mr. Brown becirne actively,invoived in the nutnagament and ical oversight of the proj�j in November 1992. Ile %s MWusdble for conducting tfjt-- hydrc#� )j c ogi and en g incaing ,� investigations Performed at the. Mph Landfill sincxi November 199), Nr,. Brown directtgj in-s-lailation of gnmndwaa"1nonito n--wells 92-1., 9,, r! the ZP 92- 94-1, 94-2; and land-fill mouitormg weRs GAS-I thrOqgh GAS-5. gas Page 3679 of 4165 tj Er tzg�mrlitoriN well CY�"f� w�r5" 0 4,4glxk4"4,4-Ar'� ot"`y " Proposed mo6joiing weip $: d : 1 hx h 10001'�1t�r o P " fl -r' 6 . " � .. q,. 1 -" S- " , Vlchy springs " E — — 5-78 512 w y f Uk lab a .. d r car Ol-illy Well andPiC Page 3680 o .4165 STA�E OF CA1JF(-MMA CALWORNIA ENVMOMAENTAL PROTECTtON ACENCY METE VjWt S'011 Govea%,'�e CAUFORNiA REGIONAL WATER QUALITY CONTROL BOARD NORTH COAST REGION 5550 SKYLANE 13LVD,SUIITE A , SANTA R C 40()SA, A 953 A P110t,IE (707)tT ):V?-Piivl,-)er 17 , 1993 Ms . Sue Goodrick Public Works Administrator City of Ukiah 300 Seminary Avenue Ukiah , CA 95482-5400 Subject: Ukiah Landfill Dear Ms . Goodrick: This letter responds to your correspondence dated November 1 , 19913 , regarding the Ukiah landfill. Specifically, your letter requests direction regarding further investigation of the benzene contamination found in monitoring wells 90-8 and 92-4 . The groundwater quality data for the landfill indicates that the water in 90-8 and 92-4 is different from groundwater samples collected from wells along the toe of the landfill . It is our belief that these are separate aquifers which may or may not flow in the, same direction . The groundwater gradient for the toe aquifer is well established as flowing to; the northwest. The groundwater gradient for the aquifer to the southeast of the fill has not yet been established. A third well ( non-colinear with 90-8 and 912-4 ) is necessary to determine the gradient. The next step: in the investigation is 'to determine the direction of groundwater flow. Please submit a workplan for determining the direction of the groundwater gradient for the aquifer southeast of the landfill ,by December 15i 1993 . The wcrkplan should include well construction specifications and a site plan showing the proposed well location. Please call, if you have questions. Sincerely , David S . Evans Associate Water Resource Control Engineer DS,E, : tab/newwell cc : Dave Koppel., Mendocino County flealth Department Damon Brown, EBA Wastechnologies, 825 Sonoma Avenue, Suite C , P .O. Box 46001 , Santa Rosa, CA 95402 Gilbert Ashoff , Vichy Springs Resort, 2605 Vichy Spr.Lngs Road, Ukiah, CA 95482 71- lk' ", �"'; , Page 3681 of 4165 Prepared for: CITY OF UKIAH DEPARTMENT OF PU BLIC " T4P..1S 300 Seminary Avenue Ukiah, CA 95482 CITY OF UKIAH SANITARY ]LANDFILL GROUNDWATER MONITORING WELL INSTALLATION WORK PLAN MENDOCINOCOUNTY, CALIFORNIA January I 4 Project No. -4 I(I) Prepared by: 825 Sonoma Avenue Santa Rosa, CA 95404 : , < EXHIBIT Page�t82 of 4165 _ WSEtH1LGE Engineers & Environrnental Consultants January 24, 1994 Mr, Rick Kennedy, Director Public Works Department artment City of Ukiah 00 Serninary avenue Ukiah, CA 95482 RE: Ul IATI SANITARY LANDFILL, WORK 'LIEN .3-4t (1) Dear fir. Kennedy; EBA Wasteehnologies is please to submit this work plan for the installation of two additional groundwater monitoring wells at the Ukiah Landfill. The work Plan has been prepared to address the concerns expressed in conversations with forth Coast Regional "hater Quality Control Board (RW C B) personnel and letters froln the RWQC B dated November 17, 1993 and December 23,, 1993. As you requested, we have submitted this work plan directly to the RWQC B on behalf of the City of Ukiah Public Forks department. We look forward to working with you o13 this project and will be pleased to discuss any questions you may have. Sincerely, Damon F. Brown, R.G. C E.G. Senior Geologist cc: David Evans, RW C'l3 p..aVROIE G'WJIUE{tAs.9ai�kNORKPLAkRM.`S R N Faraaexe ��dn. 25, `onorna ,eve., Suite C P.O. Box 4600 Santa Rosa, (,:;,fiforn1a 95402 (707) 544-C'1784 rAX (707') 54.4.08 6,i e, 3'16 l G.1,ldl Camp Drivtr, Suite 25,0, Rancho Cordova, California 95670 (916) 852-6800:: FAX ( 116) 852.08 ,6 Ako Law V6-,ay, Nevada Page 3683 of 4165 TABLE CSC CONTENTS PAGE 1.0 INTRODUCTION . . . . . . . . . , I 1.2 PURPOSE AND SCOPE PE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 GROUNDWATER MONITORING WELL INSTALLATION . . . . . 2 2.1 MONITORING WELL 4-1 . . . . . .. . . . . . . . . . . , 2 2.2 MONITORING WELL 94-2 . . , . . . . . . . . . . . . . . . .. . . . . . 2 2.3 MONITORING ORING LL DESIGN . . . . . . . . . . . . . . . . . . . . . . . 3. .4 MONITORING WELL DEVELOPMENT PMENT 2.6 SAMPLING AND ANALYSIS PROCEDURES . . . . . . . . 3 2.7 SITE SANITATION PROCEDURES . .. . . . . . . . . . . . . .. . . . . 3.0 REPORTING . . . . . . . . . . . . . . . . . . . TILES Table I Groundwater Monitoring Parameters IG RI�..' figure I (Sheet 1) - Monitoring Well Location Ma Figure 2 Monitoring Well Design t o aarr c a-aa o a. t ss Wfif 1w We,"Wmi r Page 3684 of 4165 1.0 INTRODUCTION This Work Plan has been prepared for the Ukiah Landfill, Mendocino County, California, by EBA Wastechnologics (EPA) on behalf of the City of Ukiah. The landfill has accepted waste since 1953 and volatile organic compounds (VO:Cs) have been found in the uppermost water- bearing zone beneath the site. This Work Plan has been prepared at the request of the Regional Water Quality Control Board (RWQCB), In a letters dated November 17, 19193 and December 23, 1993, the RWQCB requested that an additional monitoring well be installed southeast of the landfill to aid in determining the groundwater flow direction and gradient in this area, This well will also be used to further characterize the extent of elevated levels of benzene detected in nearby monitoring wells. During subsequent discussions with RWQCB personnel, a second monitoring well has been requested. This well will be installed northwest of the sediment retention ponds located at the toe of the landfill and be used to further define the extent of VOC impact at the toe of the landfill. 1.2 PURPOSE AND SCOPE Groundwater contamination in the form of VOCs is evident in the groundwater beneath the landfill. The implementation of this Work Plan will provide additional information, concerning the hydrogeologic conditions that influence the movement of contaminates, and aid in additional evaluation of the vertical and lateral extent of VOC contamination in groundwater. The Work Plan described in this document outlines the activities for the Ukiah Landfill, including: 0 Proposed drilling and sampling methods 0 Rationale for the placement of the two additional monitoring wells 0 Monitoring well construction and development details 0 Proposed groundwater sampling and analysis L:1J1K0)EC1'%9r3-4M WKIMI 1. well Luleakwfm W�k PLM Page 3685 of 4165 2.0 GROUNDWATER INIONITORING WELL INSTALLATION 2.1 MONITORING WELL 94-1 The RWQC'B has requested that a groundwater monitoring well be established in the area southeast of the landfill to assess the groundwater flow direction and gradient, and to further characterize the extent of benzene contamination detected in ncarby monitoring wells 90-8 and 92-4 (see Figure 1). We propose to install one additional monitoring well (914-1) in this area. We anticipate that the total depth of a monitoring well in this area will be approximately 130 feet. Based on experience drilling wells -8 and 92-4, we anticipate that well 94-1 will be, drilled with a truck-mounted Schramm T685 air-rotary rig using steam-cleaned rod and a 7-7/8 inch, bit. In order to drill this area some grading will be necessary to provide access and a drilling pad. We understand that access an, road and drilling pad will be provided by the City of Ukiah. In addition to: the standard logging procedures utilized during past well installations, we are considering the use of down-hole wireline geophysical logging in wells 94-1, 92-4, and 90-8. 'Borehole logging will aid in tile interpretation of lithology, stratification, and occurrence of liquids in the subsurface materials,. The geophysical logs will help indicate changes in geology, help evaluate hydrogeology, and aid in setting the screened interval of well 94-1. Geophysical logs that may be run include: 0 EM Induction 0 Natural Gamma For the installation of monitoring well 92-4 (see Figure 1), the RWQC'B requested the preparation of a Work Plan Addendum which addressed specific concerns raised by the owner of the Vichy Springs Resort that installation of monitoring well 92-4 in the vicinity of tile resort property could impact the mineral springs (EBA, 1993, VVork, Plan Addendion, Insfallation and Developinev of Groundwater Monitoring Well 92-4),. Experience gained during exploratory drilling and well installation at the site in general, and wells 90-8 and 92-4 in particular, suggests that it is unlikely the relatively shallow monitoring wells installed in the area threatens the mineral springs. Therefore, the use of a blowout preventer and other specialized drilling equipment, which was used in the drilling of well 92-4, is not proposed for the installation of monitoring well 94-1. 2.2 MONITORING WELL 94-2 The purpose of installing this well is to further characterize the extent of VOC contaminants discovered in the vicinity of monitoring well 92-1, which is located next to the northeastern LAPROJEOP93-461 kUKTAH tuh L.Wa 2 WWI hwo"M Wvk A� Page 3686 of 4165 corner of the leachate containment pond, near the western boundary of the fill area (see Figure 1). We propose to install an additional monitoring well (well 94-2) northwest of monitoring well 9!2-1. Because groundwater in this area has been calculated to flow to the northwest, well 94-2 will aid in identifying groundwater contaminants which may be migrating to: the northwest from the lea hate pond. We anticipate that this well will be extended to a total depth of approximately 50: feet, in order to ensure penetration of the saturated zone throughout the year. However, the total depth of the well may vary, depending on the elevation of the drilling site and, local hydrogeology. Based on experience drilling the other monitoring wells in this area, we anticipate that the well will be drilled with a truck-mounted Failing FA-100, or Deep Rock drilling fig using steam-cleaned 8 inch O.D. by 4.5 inch I.D. hollow-stem augers. 2.3 MONITORING WELL DESIGN The monitoring wells will be designed in accordance with specifications outlined in Bulletin 74-90, Monitoring We�ll Siandards: State of California, prepared by the State Department of Water Resources in cooperation with the State Water Resources Control Board, They will be constructed of clean, two inch-diameter, flush-threaded PVC casing, and secured within above- ground locking monuments. Approximately ten to fifteen feet of perforated well screen will be installed from just above the highest seasonal groundwater level to the bottom of the well, and surrounded by a filter pack of washed Maunder sand, To ensure that the well casing is properly centered in the boreholes, it will be installed within the string of hollow-stem augers, or by using stainless steel centralizers, depending on the drilling method. The annular materials (filter pack, bentonite, etc.) will be placed within the hollow-stem as the augers are withdrawn, or through a tremie pipe. Figure 2 presents a schematic drawing of a typical groundwater monitoring well design for the Ukiah landfill. 2.5 MONITORING WELL DEVELOPMENT The monitoring wells will be developed by gently surging the wellbore with a stainless steel surge block, followed by continued purging using a bailer, a Brainard-Kilrnan 1.7 inch hand pump, and/or an air-lift pump driven by an oil-less compressor. At regular intervals (approximately after each well VOlUrne of water is rernoved) the pH, conductivity, temperature and clarity of the water will be tested to verify the effectiveness of the development process, 2.6 SAMPLING AND ANALYSIS PROCEDURE^S Specific sampling methodologies,, field and laboratory analytical methods, and Quality Assurance/Quality Control (QA/QC)procedures are presented in the Sampling and Analysis Plan FA4 Wmie�xler M'A err LTROJ EM93-461\LrK IAH 3 4,41 1wkilimm WOA AM Page 3687 of 4165 developed for the Ukiah Landfill site. These procedures are summarized below and are consistent with the following guidance documents: 0 Procedures Manual for Groundwater Monitoring at Solid Waste Disposal Facilities, U.S. Environmental Protection Agency (EPA), EPA-530/SW-61 1, August 1977 0 Test Methods far Evaluating Solid Waste: Physicallchemical Methods, EPA, EPA SW- 846, Third Edition, November 1986 0 Methods for Organic Chemicaal Analysis of Municipal and, Industrial Wastewater, EPA, EPA-600/4-82/057', July, 1982 0 RCRA Groundwater Monitoring Technical Enforcement Guidance Document, OSWER 9950.1, September 1986 Three and five well volumes of water will be purged from the monitoring wells prior to sampling, again testing the pH, conductivity, and temperature for signs of representative formation groundwater. If a well is completed in a zone of low productivity, the well would be purged dry, then sampled after there has been sufficient recharge, Groundwater samples will then be withdrawn from the wells with a bladder pump driven by an oil-less compressor, or a sanitized bailer. All groundwater samples will be stored in the appropriate containers, placed in a refrigerated environment, and immediately transported under chain-of-custody to a certified analytical laboratory for testing. The groundwater samples will be tested for the same parameters proposed in, the Article 5 Detection Monitoring Program prepared for the landfill and outlined on Table 1. LAM03 LCn"--OA I MOAH 4 W'U huww�W1**fta Page 3688 of 4165 Table I Groundwater Monitoring Paraineters for City of Ukiah Landfill 0 Halogenated Volatile Organic Compounds (EPA method 8010) 0 Aromatic Volatile Organic Compounds (EPA method 8020) 0 Title 22 Metals* 0 Major and Minor Dissolved Cations: Magnesium Sodium Calcium Potassium Iron I Manganese 0 Major Dissolved Anions: - Bicarbonate - Nitrate - Sulfate - Chloride 0 Other Parameters: - Total Dissolved Solids (TDS) - Specific Conductance - Boron - Fluoride - CO pH Dissolved Oxygen Dissolved Silica Title 22 metals include-antimony,arsenic,barium,beryllium, cadmiulm,chromium,cobalt,copper,iron, manganese,lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, and zinc. 5 Well 1MWkUfM War*Pk" Page 3689 of 4165 17 SITE SANITATION PROCEDURES All drill cuttings generated during drilling should be recycled as cover material for the landfill. Groundwater extracted from the wells, as well as finsate generated from steam cleaning augers and other equipment will be collected in suitable containers (i.e., D.O.T. approved 55 gallon drums) and deposited in the leachate containment pond, ]-:"OJ EM"-46 I k11K1..kFP 6 W111 bvkAmm w-* Page 3690 of 4165 3.0 REPORTING Upon cornpletion of the field tasks, EBA will prepare a written report surnmarizing our methods, our observations, monitoring well logs and construction details. The report will also mcoMorate the recent data into the hydrogeologic framework of the site, include an analysis of laboratory testing restilts, and a presentation Of Our conclusions regarding environmental concerns at the site. EM WW1'dWk-dog0x LAFROIEM93-44MAPMAN 7 Welt hvmxkw� W�k f1m Page 3691 of 4165 F�4S*RE ICN """" v 1} 1.1 w. L: ,. TEMPORARY' SEDI (0) gar. s r• uv a �.�f� �'�"� ✓y aNa P � LLIJ BBB � A � J 5,» i w r m Y r t ,f i ; 9�4 1 .r OXNATE f M1 #U1T Q 0FILL ! RESORT y C�ryNgo�s, ram, ,� ✓ ..n ; r }p P F rr ,A r r r ' ; Petp 369 lof 4165 STEEL RISER W TH LOOKING COVER EXISTING SURFACE ��, vv • V NCI I TE GROUT" SEAS, + + + + OREH .E + + ++ ++ - BLANK PVC CASING, + + + + + + + + + 2% BI NT'O NITS CONCRETE + + + + + BENTONITE SEAL SAND PVC MACHINE-CUT WELL SCREEN (VARIES) -BOTTOM CAP N.T.S. i CITY OF UKIAH SANITARY LANDFILL 1=1'CUI U IAI , CALIFORNIA .- GROUNDWATER MONITORING WELL 2. ..... TYPICAL CONSTRUCTION UCTION DETAIL. Ppaq,e 3693 f 4165 STATE CF CA[,IFO 1 YA C'Al WCi�?Nl A @ 9�VIr1G1NNM-'1'°ITAI f Il OTR CTVXO AT,f'NCY PETT' VAPrT aA',N (30VC,mor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD , NORTH COAST P GGGN 55 5a SKYV ANE'Bt'✓D SUITE A � February 1 , 1994 r. dick: Kennedy, Director Department of public works City of Ukiah 300 Seminary Avenue Ukiah, GA 954 ! 'Subject: Ukiah Landfill Dear Mr. Kennedy: This :letter responds to the Groundwater Monitoring Well Installation ' orkplan dated January 1994 , prepared by EBA Wastechnolog .es . The Workplan appears to be in order and it: ,is hereby approved. We concur with the recommendation that borehole logging technigL'ies be employed to develop as much subsurface information as possible. please contact this office at least a Meek, in advance of scheduled drilling so that we can arrange to have a staff member present . Please call if you have questions on this smatter.. Sincerely, David S . Evans Associate Water Resource Control Engineer 1 E.tab/ukiah ap cc : leave Koppel, ,Mendocino County Health Department Damon Brown, EBA Wastechnologies , 825 Sonoma Avenue, Suite G, P.O. Box 4600, Santa Rosa, CA 9540 Gilbert Ashoff, Vichy Springs Resort, 2605 Vichy Springs Resort, Ukiah, CA 9546 EXHIBIT 2 Page 3694 of 4165 k CITY OF UKIAH ("I AMENDMENT TO MASTER AGREEMENT FOR PROFESSIONAL CONSULTING SERVICES DATED NOVEMBER 12, 191912 !F-I NTS AND CONDYMONS All terms and conditions of Master Agreement for Professional Consulting Services between city of Ukiah and EBA Wastechnologies dated November 12, 1992 shall rernain in force and effect except as modified by this and previous executed amendments. &UJ�LIORIZATIQN Upon execution of this amendment, consultant is aUthorized to perform the work described under "Scope-of-Work" of this amendrilent, on a time and expense basis not to exceed the total amount of compensation indicated for each work task. The following work tasks shall be performed under this amendment. Task I - preparation of a Preliminary Closure and Postclosure Maintenance Plan including closure and postclosure cost estimates all in compliance with 14 CCR and 23 C(.,R. Documents shall be cornpieted for City's review no later than April 1, 199!4. Total cornpensation for this task shall not exceed $29,138,. Task 11 - Perform gas Monitoring well installation and field evaluation related to City"s effort in determining the extent of any gas migration along the south boundary line of the landfill in the vicinity of existing gas probe PP4. All work shall conform to applicable sections of 14 CCR and Subtitle D. Perform reporting, monitoring and other- required work as outlined in Cori su Itant's proposal dated December 8, 199 . Total compensation for this Task shall not exceed S34,000. Work shall begin promptly after LEA approves Landfill Gas Monitoring Work, Plan and shall be completed by the following dates: well and/or probe installations April 15, 1994 Monitoring May 13,, 1994 Report May 27, 1994 Page 3695 of 4165 Task III Perform, two (2) groundwater monitoring well installations. One well shall be installed at the toe of the landfill north of Wells 90-2 and 92-1 to further characterize the extent of containination in that area. The second well shall be installed in the area southeast of the, landfill in order to further characterize the extent of grOUndwater contamination and to aid in the determination of groundwater gradient of the aquifer monitored at Well 901-8 wid 92-4. Work includes preparation of report documenting the well installation procedures, boring, logs, applicable maps an(] drawings. Reference is made to consultants proposal dated December 8, 19193. Work shall begin promp:tly after LEA approves Groundwater Monitoring Work Pan and shall be compleleti in the most expeditious;itious; manner, Total compensation for this work Task shall not cxc=J $24,960. EBA WASTECHNOLOGIES C.IT Dale Solheim Charles L. Dough, Jr. Project Manager City Manager U- -2—le ..................- D:Jane 13titier DATE Principal H t�A G R 1-1 9T S EBB. Page 3696 of 4165 T� TN,- OF CAt lF";F�NM•CAW�#=ORNNIA ENVIRONMENTAL NdTAL @"'f OI ECTION.J AGENCYT�4�T9 ' li T7NN,� eay,raaar CALIFORNIA REGIONAL"'CATER QUALITY CONTROL BOARD NORTH COAST REGION PHONdE':(707)576-22,20 May 23, 1994 Mr.. Rick Kennedy, Director Department of Public Works City of Ukiah 0O Seminary Avenue Ukiah, CA 9548 ' Subject: Ukiah Solid Waste Disposal Site Dear Mr. Kennedy: This letter is to review the status of landfill regulatory requirements and to outline additional work which needs to be accomplished in the forthcoming fiscal year. e have begun drafting waste discharge requirements for the Ukiah landfill to reflect compliance with Chapter 15 and Subtitle D solid waste disposal regulations,. We have received and conditionally approved the Article g Monitoring Proposal and Report of Waste Discharge earlier this year. The approval conditions pr%marilly involved additional monitoring, capabilities to completely define the extent of groundwater contamination and submittal of a corrective action plan. These issues are discussed separately below: Groundwater Investigation There are two areas of concern regarding groundwater beneath the landfill . The irst is the presence of volatile organic compounds (Ilk's) in the stream bed alluvium along the landfill toe. The second is the presence of benzene in a deeper aquifer beneath the ridge which separates the landfill from the 'Vichy Springs Resort. Two additional wells are needed to complete the investigation of the contamination in the alluvial aquifer. One needs to be installed to the northwest of the bottom of the fill and another in the canyon above the fill to serve as a background well . It is our expectation that these two additional wells will complete this part: of the groundwater investigation. The wells should be installed, developed and sampled during this summer.. The benzene problem was initially encountered in MW g -8 at the landfill gate. Additional contamination was detected in MW g -4 further down the access road toward Vichy Springs. The next step in the investigation is to determine the direction of groundwater flow for the affected aquifer. Once this gradient information is available further thought can be given to isolating the benzene source. Since it is not certain what the results of a third monitoring well in this area would be, contingency funds should be set aside in this year' s budget beyond funding a single additional monitoring well .. We are aware of the stated concerns by representatives of 'Vichy Springs that the existing and any new monitoring wells might affect their water supply. They have EXHIBIT Page 3697 of 4165 Mr. Rick Kennedy May 23, 1.9914 Page 2 recently requested that MW 90-8 and MIS' 9:2-4 be removed. We have had numerous communications with Vichy Springs representatives regarding these monitoring i wells. We do not believe that evidence has been submitted which warrants the removal of MW 90-8 and 92-4. It is our understanding that the City of Ukiah is currently compiling a summary of groundwater quality data and h:ydrogeological information in advance of a meeting with consultants for Vichy Springs, the Regional Board and the local Health Department. We look forward to participating in this discussion at the earliest possible opportunity because we want to see the groundwater investigation completed in a timely matter. Corrective Action Plan Corrective action will likely be performed in two separate phases. The first will involve removal of VO,C's, from the alluvial aquifer. The second will be to abate the benzene problem in the area between the landfill and Vichy Springs. It is difficult and perhiaps premature at this time to budget for the cost of remedial work regarding the benzene problem. Decisions on that matter will need to be made after the site investigation has been completed. However, most of the information is already developed to design a corrective action: plan for the alluvial aquifer VOC problem. The City of Ukiah should plan for completion of the remaining two, monitoring wells, and design of an extraction, treatment, and disposal system for contaminated groundwater. The actual construction of physical facilities as well as start up and operation and maintenance can be deferred until the 1995/96 -fiscal year. I hope this clarifies, our expectations regarding progress to correct groundwater problems related to the Ukiah: landfill; in the upcoming fiscal year. Please give me a call if you have further questions., avid S. Evans Associate Water Resource Control Engineer DSE:bp\ukiahltr CC.* Dave Koppel , Mendocino County Health; Department Gilbert Ashoff, Vichy Springs Resort Damon Brown, EBA Wastech:nologies Page 3698 of 4165 STATE OF CAI.VFOHNI A- CA[L.IFORMA ENVRONMENTM.PROTECT 6ON AC�FNCY PFTE WI-SONCoo-mor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD NORTH: COAST REGION 5550 SKYt.ANE BLVD.SUITE A SANTA ROSA,CA 95403 PHONE:(707)576 2220 August 1 , 191914 Mr. Rick Kennedy, Director Department of Public Works City of Ukiah 3001 Seminary Avenue Ukiah, CA 9548,2 Dear Mr. Kennedy: Subject: Ukiah, Solid Waste Disposal: Site This letter regards the groundwater investigation at the Ukiah landfill and, in particular, the investigation of the presence of benzene and toluene in IOW 910-8 and 92-4. In previous discussions and correspondence we have indicated that additio�nal:: monitoring wells are necessary to understand the presence of benzene and toluene in the groundwater as well as to design: measures to correct the problem. This work has been delayed by concerns put forth by Filbert Ashoff at Vichiy Springs Resort that monitoring wells in this area will damage his geothermal springs at the resort. We would like to see those concerns resolved so the groundwater investigation can continue. In this regard, we request that a technical report be prepared which summarizes the information which the City has developed to date in support of the position that additional monitoring facilities will not adversely impact geothermal water sources located on the Vichy Springs property. A similar request is being made to Mr. Ashoff to support his contention that his springs are in real ,jeopardy. This request is made pursuant to Section 13267 of the California State Water Code. Please submit your report by September 1, 191914. Your attention to this matter is appreciated. Sincerely, David S. Evans Associate Water Resource Control Engineer DSE: lmf/ukrpt cc: Dave Koppel , Mendocino County Health Department Paul Blais, Cal EPA Gibert Ashoff , Vichy Springs Resort EXHIBIT Page 3699 of 4165 �WAS7r-,FCH�NO4�001,Eff Engineers & Environmental Consultants August 31, 1994 Mr. Rick Kennedy, Director Department of" public Works City of Uk-ia-h 3,00 Seminary AvellUe Ukiah, CA 95482 R E': UKIA11 LANDFILL SITE MONITORING WELLS AND VICHY SPRINGS RESORT Dear Mr. Kennedy: This, letter report surnniarizes the data we have developed to date regarding the Potential for groUndwater impact to Vichy SPri119s by groundwater monitoring wells at the Ukiah landfill. This report was prepared, in accordance with as letter dated August 1, 1994, fron'i the California Regional Water Quality Control Board, North Coast Region (RWQCB)!, requesting a summary of information supporting OUr C011CILISiOn that tile existing or ftItUre grOUndwater monitoritig wells at the landfill will not adversely inipact Vichy Springs. It is our understanding that tile RWQCB has, niade a similar request for data and as technical report from Mr. Ashoff, tile owner of the Vichy Springs Resort. BA(AW'ROUND As you are aware we have examined tile available hydrogeologic, and geochemicai data, and fOL11ld no evidence supporting Mr. Ashoff Is claim that Ukiah Landfill site monitorimy wells have adversely affected geothermal spring activity at Vichy Springs Resort. The R%VQCB has requested a summary of relevant facts so that concerns can be resolved and the hydro geologic groundwater investigation at the landfill can continue. This letter presents the data supporting OUr conclusion that (lie i1nanitoring wells at [lie landfill do not inflLience geothermal spring activity at the Vichy Springs Resort. Through a letter, dated May 6, 19:94, from attorney James R. Mazzoni, Jr,, -Nlr. Ashoff contends that inlinediately following the installation of the well 92-4, (installed March 15, 199,3 through March 18, 19913) the temperature at Vichy Springs declined 12 degrees (a six degree increase was later observed, for a net decrease of six degrees from its "historic tenilmrature"), Mr. Ashoff fUrther alleges an accompanying decrease in discharge of thirty percent from a R TROY EC'flaV,i U All ii WQCBJTP' EXH1131*T '-i r-'Q'3 "'on c")",-i 'Im-- SuiW C PO Bo\ 4600 Sama Caflifnrnia 95402 (707) 544-07,94 P,,�X -Pletod)3700 of 4165 'I CO�)rm Rd- Suite 2,15 (-Wdd tq%j,j , r 7 A V ,1�-, - ? �'Po) , . Mr. Rick Kennedy, Director August 31, 199:4 Page 2 reported flow of 65 gallons per minute (gprll). This decrease in flow of 19.5 gpm (30% of 6,5 gpm) is also attributed to the presence of monitoring well 92-4. We believe it is highly improbable that either monitoring well 90-8 or 92-4 (see sheet 1) can adversely impact Vichy Springs. The two principal arguments for this position are 1) there are a number independent lines of evidence (geologic, hydrogeologic, and hydrochernical) supporting the conclusion that the monitoring wells are completed in a water-bearing zone that is, different, distinct and physically separate from that of Vichy Springs, and 2) the monitoring wells can not physically account for the quantity of heat loss clairned, and volume of groundwater extracted from tile monitoring wells is far too low to account for the reduction in spring flow attributed to them. Mr. Ashoff, to date, has not presented records of groundwater temperature or flow rate data for Vichy Springs to document the deviation frorn historic temperature or discharge referred to; in Mr. Ma7zoni's letter. HTE GEOLOGY The geology and hydrogeology of the area have been studied by a number of researchers (Blake and Jones, 198 1; Cardwell, 1965; Farrar,1986; Treasher, 1958; and Upp, 1982) and is discussed in the Environmental Monitoring Program (EBA, 1993a) and the Report of Waste Discharge (ROW D) prepared for the landfill. (EBA, 1993b). Based on a review of available geologic maps (Cardwell, 1965; Farrar, 1986) and site field reconnaissance mapping of the area, there appear to, be three major geologic units represented in the vicinity of the landfill site. These include rocks from the coastal belt of the Franciscan Assemblage, Pliocene Pleistocene Continental Basin Deposits, and contemporary (Holocene) alluvial deposits® 1 1,he central belt of the Cretaceous-Ju rassi c age Franciscan Assemblage, underlies the majority of the Mayacarnas range east of the Maacarna fault (Blake and Jones, 1981). The Franciscan Assemblage outcrops, in the Sulphur Creek drainage to the south of the landfill site, near Vichy Springs Resort. The central belt of the Franciscan Assemblage predominantly consists of what is known as a tectonic melailge. The melange consists of an admixture of disrupted sandstone and assorted metavoicanic, greenstone and chert inclusions, within a highly sheared and deformed, dark-gray shale matrix. Bedding deformation within blocks of interbedded sandstone and shale turbidites indicates that there has been a complex and varied strain history within the Central belt of the Franciscan Assemblage. As a result of the intense deformation history, the primary porosity of the Central belt of the Franciscan Assemblage has been greatly reduced. Accordingly, the ability of the Franciscan Assemblage melange to absorb, store and transmit water is almost entirely dependent on the degree of faulting, fractufing and weathering. Water often percolates into, large upland areas underlain by Franciscan basement, and later discharges from springs and/or provides base flow for tributaries to the Russian River. Discharge of thermal water, such as Vichy Springs, is also quite common throughout the area. Historical records, however, indicate that groundwater yield to wells within, Franciscan bedrock is UTROI U.'r461 UKILkII'IRWQCB.LTR FM ;��Vwh"�Oes Page 3701 of 4165 Mr. Rick Kennedy, Director August 31, 19194 Page 3 generally unpredictable and in most cases volumetrically insignificant (Cardwell, 1965; Farrar 1986), Vichy Springs flows from fractured Franciscan bedrock exposed in a hillside along the southern edge of the Sulphur Creek drainage basin (see Figure 1). The entire landfill site is underlain, by Pliocene-Pleistocene Continental Basin Deposits, which are referred to locally as the Ukiah Beds (Treasher, 1958). These relatively undeformed deposits consist of poorly sorted, highly consolidated, partially indurated, silt-dominated conglornerates, clayey sands, and silty clays which unconformably overlie an irregular surface of Franciscan bedrock. The maximurn thickness of the Continental Basin Deposits is estimated to be in, excess of 2,000 feet (Cardwell, 1965). The basal contact of the continental deposits, where it overlies the Franciscan bedrock, has not been encountered in any of the test, borings, or monitoring wells drilled at the site to date, including a deep test boring (T1 -90-4, see Sheet 1) which was, abandoned at a depth of 265 feet below the surface, approximately 545 feet MSL (EBA, 1993b). Tile hydraulic properties of the Continental Basin Deposits, in the saturated zone at selected groundwater monitoring wells at the site were determined by in-situ testing. Hydraulic conductivity values, were obtained from rising- and falling-head slug tests and are reported by EBA (19:9:3b). Hydraulic conductivities reported from slug tests for the Plio-Pleistocefle Continental Basin Deposits ranged from 7.5 x 10-' cm/sec to 2.8 x 10" cm/sec, and Holocene alluvium tested from 1.6 x 10' cm/sec to 1.6 x, 10' cm/sec. Lithologic boring logs of monitoring wells 901-8 and 92-4 (EBA, 1993b) indicate they are drilled through a continuous section of Continental Basin Deposits consisting of low permeability silty clays and clayey silts. No perched groundwater, aquitards or Franciscan bedrock were encountered during drilling. This demonstrates that the monitoring wells are completed in a distinctive and separate geologic formation, consisting of significantly different hydrogeologic properties, from the Franciscan bedrock in which Vichy Springs occurs. . UEAT LO S The alleged energy loss associated with a 12 degree (assumed fahrenheit) decrease in temperature of Vichy Springs, immediately following the installation of well 92-4, was calculated assuming an aquifer with a conservatively small area of influence consisting of 1,01010 feet by 2,000 feet by 50: feet deep, with 30% porosity. The energy loss was calculated as 22.3 x IW British thermal units (Btu) or 6,533,841 kWh. Oil a practical level it is extremely improbable that an energy transference of this, magnitude could solely occur via a monitoring well with a 2-inch PVC casing without destroying or resulting in significant damage to the well. Mr. Singer, in a letter to Mr. Ashoff, dated March 19, 1994, presents examples of adiabatic LTROJ E(7\461 tXJAIRRWQCR.LTR Page 3702 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 4 cooling related to the rapid release of pressure in rocket rnotors and explosions designed to extinguish oil well fires. It is well established that rapid decompressive cooling may be achieved in gasses, however, Mr. Singer states "it is clear that cooling of the spring ivater resulted �oin formation pressure and release of the natural carbon dioxide gases in the a reduction in f j fonnation by the drilling of this single well", Mr. Singer fails to present any site specific hydrogeologic data to support this conclusion or his recommendation that no further drilling be allowed in the vicinity of the springs. No significant changes in pressure (other than barometric variations) were observed during drilling or following installation of monitoring well 92-4. In addition, monitoring well 92-4 is located in relatively low permeability materiaJ,, making it unlikely that gasses would migrate at the rate Comparable to Mr. Singer's cited past experience. Based on the discussion presented above, and in the absence of historic temperature data for Vichy Springs, it is reasonable to assume that the temperature oscillations observed in Vichy Springs water are likely within the range of normal fluctuation. Evaluation of a detailed temperature database should allow tile identification of historical temperature ranges and possibly temporal variations in temperature. Recent observations by the Mendocino County Environmental Health Department indicate that the temperature of Vichy Springs has evidently returned to a "normal level" (personal communication, Mendocino Environmental Health Department personnel, 7/28/9,4). This further suggests the landfill monitoring wells are not influencing Vichy Springs, ELOW REDQC-T1O]Y A flow reduction of thirty percent from a "historic level" of 6:5 gpm has apparently been observed at Vichy Springs. This equates to a 19.5 gpm reduction in flow or an, annual reduction of 10,249,200 gallons. This loss has been attributed, by Mr. Ashoff, to monitoring wells 90-8, and 92-4. To date sanipling records show that the volume of water extracted from the two wells due to development and sample purging is approximately 172 gallons from 90-8 since April 1991 (an annual total of 57 gallons) and approximately 36 gallons from well 92-4 since May 15, 1993. Additionally, during the drilling of both monitoring wells no zones of high permeability were encountered, Further, no free water was, encountered in well 92-4 during drilling. Well 92-4 was completed an March 18, 1993 and groundwater was not observed until April 27, 1993, 40 days later, Both well 90-8 and 92-4 have slow recharge rates following sample purging consistent with the low permeability SUbsurface materials in which they are installed. Clearly, the monitoring wells are not physically capable of extracting groundwater at flow rates sufficient to account for the reduction in discharge from Vichy Springs. Further, the thickness of the Continental Basin Deposits and the depth to the Franciscan bedrock (tile geologic formation associated with, Vichy Springs) beneath the site is not known, however T APROJECT�461 U'K1Afl)RWQCBA.1TR Page 3703 of 4165 Mr, Rick Kennedy, Director August 31, 1.994 Page 5 exploratory borings from the site, as previously discussed, illustrate that the thickness of the low permeability Continental Basin Deposits is significant. Therefore the likelihood of groundwater flow from the water-bearing zone encountered in wells 90-8 and 92-4 to Franciscan bedrock is very low. ORGANIC AND MORGANIC HYDROCHEMICAL ANALYTICAL RESULTS Wells at the Ukiah I-andfill have been analyzed for a number of water-quality parameters since 1987. As part of this analysis available chemical data for Vichy Springs was evaluated to examine the similarities and differences in groundwater hydrochemistry between groundwater encountered beneath the landfill and mineral water from the Vichy Springs Resort, These analytical results are presented and discussed in detail by EBA (EBA, 1993a; 199i3b). Sampling of landfill wells has identified three areas of groundwater impact (well 87-1; wells 90- 4 and 90-5, and well 90-8), based on the consistent detection of volatile organic compounds (VOC's). Samples analyzed frorn Vichy Springs in 1987, 1990 and 19911 did not detect VOC's. Analysis of groundwater samples from Vichy Springs for total (unfiltered) metals has also, been performed in 1987, 19190, 19911 and 1993 of which a number of metals (antimony, arsenic, beryllium,, cadmium, chromium, cobalt, lead, mercury, niolybdenurn, selenium, silver, thallium, tim, titanium, vanadium and zinc) have not been detected above their respective MDL's. To date, no pesticides or PCBs have been detected in any landfill groundwater samples or samples collected from Vichy Springs. Analysis of major anions and cations suggests, in general, that the landfill monitoring wells exhibit significant variations in the concentration of all, parameters evaluated but do not appear to exhibit a consistent pattern. No monitoring well is significantly different from all other wells for all parameters evaluated. Well 90-8 and Vichy Springs, generally exhibit higher parameter concentrations than most other monitoring wells. Compositionally, however, the analysis indicates that well 90-8 and Vichy Springs exhibit significant differences from each other in cation and anion content. As noted in the Hydrochernical and Statistical Evaluation of the City of Ukiah Landfill (EBA, 1919i3a; 19193b) the general hydrochernical signature of Vichy Springs is similar to some landfill wells and different from others. Vichy Springs is readily distinguishable from all landfill wells. VOC's have been identified in specific monitoring wells and have not been detected in samples from Vichy Springs,. Boron is believed to be associated with recent volcanic activity in the northern coast ranges, and is commonly reported in groundwater on the east side of the Ukiah Valley (Cardwell, 19165; UIPROJECTA461 I-XIAW,RWQ(,'b A.TR FR4 Page 3704 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 6 Farrar, 1.986). Boron was detected at Vichy Springs in t990, 1991, and 1993 in concentrations, ranging from 100: mg1l to 126 Ing/I, significantly higher than any of the landfill monitoring wells, Based on data from the July 12, 1994, sampling event, boron concentration in landfill wells ranged from <0.5 to 54 mg/l. Boron concentrations in well 90-8 d 92-4 were 23 mg/ an 1, and 54 mg/l, respectively. Boron concentrations for southeastern landfill well locations (90-6, 90-8, and 92-4) are not significantly different from one another but appear to be significantly higher than all other monitoring wells, suggesting a possible relationship between location and concentration, Temperature data provided by Mr. Ashoff collected on December 6, 1979i indicates that the temperature of Vichy Springs was 20.5 , significantly higher than the temperature of groundwater water in monitoring wells 9,01-8 and 92-4, which ranges from 20a, to: 21 OC and 1.5o to 25oC, respectively. However, as discussed previously, evaluation of a detailed temperature database from Vichy Springs is needed to identify historic temperature ranges,. STABL,E ISO,TO,PE AI LALYSj][S To further characterize the hydrochemistry and hydrogeologic relationship between the shallow groundwater beneath the Ukiah Landfill and Vichy Springs mineral water, stable isotope studies were performed (EBA, 1993b, 1994a, and 19,94b). Important trace isotopes of hydrogen and oxygen atoms in water (H2160) are deuterium (D) and oxygen-18 ("0) which can provide a "Fingerprinting':' of a source water by its stable isotopic signature. This fingerprinting can provide a very effective method for water charactenzation, with particular application in tracing the source, migration, recharge, and history of a particular groundwater. Rather than relying solely on the concentrations of constituents that are Susceptible to: chemical, physical, and biological transformations, stable isotopic identification of a water type allows tracking of its subsequent flow and mixing, independent of its chemical concentrations. The results of the stable isotope analyses exhibits very distinct 'Isotopic variations in grouridwaters in the Ukiah Landfill area, and that the different waters can be easily distinguished. In a plot of 6D vs (31�10 the majority of the samples lie along the Meteoric Water Line (MWL) at values appropriate for coastal California (Craig, 1961). Tile plot clearly shows that Ardeche Spring and Vichy Springs water have isotope characteristics distinct from all other groundwater s at the landfill (see Figure 2). Furthermore, no mixing trend between Vichy Springs/Ardeche Springs water and any other water is apparent. Non-mixing further indicates there is no interconnectivity between groundwater at the Vichy Springs Resort and any of the groundwaters collected from the landfill wells. As discussed previously, Ardeche Springs and Vichy Springs both flow from fractures and joints in the Franciscan bedrock exposed in the Sulphur Creek drainage. Both of the springs plot close L 1I+RO71 CT%46E tT,,1AWRWQCB,UT'R FBA Wmre,f.w #" Page 3705 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 7 together, well to the right of the MWL, appropriate for connate or mineralized formation waters. Samples with 0 and 6"0 values that plot to the right of the M`WL have usually undergone isotopic enrichment by evaporation or water-rock interaction associated with older waters that have also undergone mineralization through long residence time in contact with bedrock. Water- rock isotopic exchange is not significant in cool, meteoric groundwaters, including most young shallow groundwater (Dr. Bob Criss, personal corn munication, 1993). Samples from wells 90-8 and 92-4 also plot to, the right of the MWL, but are signifiewitly separated from those of Ardeche Springs and Vichy Springs. As described in the ROOD (EBA, 1993b) these low yielding wells have been installed in silts and clays of the Continenta,fl Basin Deposits along the northern divide between the Sulphur Creek drainage basin, where the Vichy Springs Resort is, located, and the landfill drainage basin, 'rhe City Range Spring is located on the north side of the ridge which divides the two drainage basins. The City Range Spring flows from the Continental Basin Deposits, and plots closet y with sang le frorn wells 90-8 and 92-4. It appears likely that groundwater in wells 90-8 and 924, and the City Range Spring are related, and represent another formation water in tire area. In a letter dated July 26, 1994 to Mr. AShoff, Mr. Davisson concurs with tile results and interpretation of the stable isotope evaluation. He further presents a hypothetical exampl:e in which two formation waters may belong to the same general hydrologic system and recommends that a hydrogeologic investigation be performed in the region. Unfortunately, Mr. Davisson rnav be unaware of the results of the ongoing hydrogeologic investigation and the geologic and hydrogeologic information developed which supports a different scenario. Mr. Davisson, also does not present an opinion regarding the probability of site monitoring wells impacting Vichy Springs. CONCL IQN, Local and regional geology, hydrochemical analytic results and stable isotope analysis provide data supporting the conclusion that monitoring wells 90-8 and 92-4 are not impacting Vichy Springs because they are installed in a water-bearing zone significantly different from and not connected to, or intermixing with, the water-bearing zone of vichy Springs. Further, calculations examining heat loss and flow reduction reported to have occurred at Vichy Springs, clearly demonstrate that the "'norlitoring wells are not physically capable of influencing the hydrology or temperature of Vichy Springs. Based on the data developed, it is Our opinion that tile likelihood of future landfill site monitoring wells adversely impacting vichy Springs is extremely improbable. It should be noted that Mr. Ashoff has demanded that in in-depth surface arid subsurface hydrogeologic investigation be performed in the area, Tile City of Ukiah has been attempting LAMM FITT46 t 1JK1AH'�RWW_'8,LTR EAA Page 3706 of 4165 Mr. Rick Kennedy, Director August 31, 19914 Page 8 to: perform hydrogeologic investigations at the landfill site to identify and characterize the vertical and lateral extent of impacted groundwater, which could pose a threat to the waters of the State. Any responsible and detailed hydrogeologic study most include the installation of monitoring wells in order to further evaluate groundwater conditions. These investigations have been delayed by Mr. Ashoff and are as yet incomplete. In order to further characterize benzene contamination detected in groundwater samples collected from 90-8 and 9:2-4 and aid in the determination of the direction of groundwater flow in the area, the installation of additional groundwater monitoring wells at the site is required. As you requested, we have submitted this letter report directly to the RWQCB on behalf of the City of Ukiah. We trust this provides the information you require. Please call me if you have any questions. Sincerely, E13A WASTECHNOLOGIES Damon F. Brown, RG, CEG Senior Geologist Duane Butler, P.E. President DFB/DB/1yv attachments cc: David Evans, RWQCB UK1ARRWQ,CR,LTR EBA Page 3707 of 4165 Mr. Rick Kennedy,Director August 31, 1994 Page 9 REFERENCES IT Blake, M.C., and D.L. Jones, 1981, The Franciscan Assemblage and Related Rocks in .Northern California: in Ernst, W. G., ed., The Geotectonic Development of California, Prentice-Hall Inc., NJ,p306328. Cardwell, G.T., 1965, Geology and Ground Water in the Russian River Valley Areas and in Round, Laytonville and Little Lake Valleys, Sonoma and.Mendocino Counties, California; U.S. Geological Survey Water Supply paper 1548, 154p. Craig,H., 1961,Isotopic Variations in Meteoric Waters, Science no. 1.33,pp. 377 397. EBA Wastechnologies, 1993a, Proposed Article 5 Detection Monitoring Program and Financial Assurance Provisions, City of Ukiah Solid Waste Disposal Site, Mendocino County, California, EBA Wastechnologies, Santa Rosa, CA, April 1993,217p. EBA Wastechnologies, 1993b, Report of Waste Discharge for City of Ukiah Solid Waste.disposal Site, Mendocino County, California, Volumes I&11, EBA Wastechnologies, Santa Rosa CA, May 1993, 354p. EBA Wastechnologies, 1993c, Report of Disposal Site Inf6rination, Uiah Disposal Site, Mendocino County, California, Volumes I & H, EBA Wastechnologies, Santa Rosa CA, May 1993, 307p. EBA Wastechnologies, 1994a, Ukiah Landfill, Recent Stable Isotope Analyses, letter report to City of Ukiah,EBA Wastechnologies, Santa Rosa CA,April 14, 1994, 4p. EBA Wastechnologies, 1994b, Ukiah Landfill, Stable Isotope Analyses Ardeche Spring, letter report to City of Ukiah,E BA Wastechnologies, Santa Rosa CA, June 10, 1994, 3p. Farrar, C.D., 1986, Groundwater Resources in Mendocino County, California; U.S. Geological Survey Water-Resources Investigations Report 85-4258. Treasher, R.C., 1958, Russian River Reservoir (Coyote Valley) Project, California: Geological Society of America Engineering Geology Case Histories,No. 2,p. 33-36. Upp, R.R., 1982, 11olocene Activity on the Maacama Fault, Mendocino County, California: Ph.D. Thesis, Stanford University. [,:\PROJECT\4611JIUAHaWQCB.I,'rk fBA Wastechnologies Page 3708 of 4165 k *" xIle 41 " f 7 d1 x i .. ��� ✓ rub tr r„� f•F �, � rr so. Y4 .,Y ' ,f '� �' I 1�,.�.+�w � N � (d VNI t zf °", _✓<- � a..�1�..17 `r '&6 + _ �� f�T �'�h""�'~ti`�� ,%,P `" ,r $��)�i���� r,�^` -,� r �^ t Iq r ` `r. _ �1 N w..� � / �yr ' M�"r. � !ti. ,�.„,, .�, .--�- '* 1f� �G °�. rn " �ti -.'"r''1+.,'. �i ''` �'r. ytl,b! �, r� � { h ��rrff, rP r Ttr ryS my 4'..t �' � � ' �W"V d,[p t�.-.. � ����. s �•� �duyy ��I��rl��Ka ^� +1�1pj' N�r"`",�N �{ "".� ,. '*" ��"f4t �I � �'� a 4 ol I d 7 �� �'" t 1 p7 i r,. I� �k' y 1. " �� .a.... 'it � •ro "' t f�r l 5 11 ,.a"r�"g ' V �" � E `E" � � IY� �411 b� a fAkS�t """��'.i�l` ,� �,s `"R . ��.,qr'tt � �9 `u� M r "-••""",,.,:w , .' � 1,.`, iI ��Y4 e t �a �ti���db�»� •,lr;..��Y"�-�-3t��«�',J''h^��dff��.�i�r� ,. "'�r��yM, ,�� ,�4�°i'�w�,�c� trt�(���� ,,ti.. Id6.��i� 1d..rl nr-.,• w 4 . �,.��. .�,r','�l I r*i r n � Asa arr as CITY OF MAH LANDFILL, FIGURE g 5 mmJ i ' M MAC Pa e 3 09 dfi 41 �a i OEM lot a�a ca. cc 00 co CL cc co tn I Cal' b 1 1 r ram, w 6/94 CITY OF UKIAH LANDFILL Fof4W .. ...... _ E.I�DOCI O COUNTY, AL.IFOR�"'�'IPage 37 Nii-icn UdA'iif CONTROL BOARD State of California REFAnN 1 MEMORANDUM OCT 3 1 '94 To: Benjamin Kor Date: 0 e---, North Coast RWQCI3 0 9=rt&L F1 FR El XD Ti OPG JS 13 SW a7ny M. Sc eller, Chief C3- 13,uply �io t 0 All STAfT FIF Division Clean Water Programs C' ST" W F�R From: STA"T WA�TER RESOURCES CONTROL BOARD Subject: REVIEW OF UKIAI-1 LANDFILL MONrrORING WELL INFOI?-MATION As you know, you contacted us recently to request brat we review info nation relating to the drilling of a monitoring well near the Ukiah Landfill and its possible effects on the temperature and flow rate of a spring at the Vichy Hot Springs Resort, We have reviewed the information forwarded to us regarding the possible effects of drilling monitoHng well 92-4 in March, 199�3. The well was drilled by the City of Ukiah to monitor water quality in the vicinity of the Ukiah Landfill. The inforniation we reviewed consisted of- 0 October 24, 1994 letter from Gilbert Ashoff to Benjamin for 0 October 17, 1994 letter trorn Gilbert Ashoff to Benjamin for 0 October 14, 1994 letter from Robert E. Mackensen to Paul Blaic 0 October 13, 1994 letter from Alisto Engineering Group to Gilbert Ashoff 0 August 31, 1994 letter fiorn EBA Wastechnologies to Rick Kennedy 0 September 20�, 1994 letter from Judy Pruden to Chuck Rough and Rick Kennedy 0 July 26, 1994 letter from M, Lee Davisson (Lawrence Livermore Lab) to Gilbert Ashoff Page 3711 of 4165 UKIAH LANDFILL Page 2 of 2 0 March 19, 1994 letter from Stanley J. Singer to Dam Renan 0 U.S. Geological Survey Water-Supply Paper 338, 1915 0 U.S. Geological Survey Professional Paper 492, 1965 Our review of these materials, indicates that: (1) the monitoring well was drilled into a difTerent geological formation from the formation underlying the hot springs; (2,) apparently no pressure effects were noted during drilling; (3) the temperature of the water in the monitoring well apparently ranges between 59"-77'F, in contrast to the 90T temperature of the hot spring; and (4) data from Lawrence Livermore Lab shows that the water in the monitoring well and the hot spring have different oxygen isotope values and therefore are from separate water sources and have no apparent mixing relationship. One would expect waters which are in the same hydrothermal regime to have similar oxygen isotope values and elevated temperatures. Furthermore, if the monitoring well were in fact responsible for the drop in temperature of the spring, one Would not have expected the temperature in the spring to, have recovered almost to its pre-drilling temperature without a subsequent change in the condition of the well, e.g., plugging. In Summary, we have not seen convincing evidence to support the conclusion that the drilling of this monitoring well could have impacted the temperature and flow rate of the hot spring. In order to better ascertain any relationship between drilling boreholes and the hot spring, the following information could be collected if subsequent monitoring wells are drilled: the temperature of the borehole during drilling; insofar as possible, the pressure of the borehole during drilling; the temperature of the spring during and after drilling; and flow rates of the spring during and after drilling. If you have any questions,, please contact Liz Haven at (916) 227-4395 or Calnet 498-4395. cc: Dave Evans Page 3712 of 4165 V1 cilf� Ql�'j IRHIKS (IjKlAH - MUT"I NO Co.:) HYDROG"EOLCK,I CAL FIELD TESTS PERFrYED SI/ Ji. WA[.GP,,1W7'TZ (BRG",I) .......... Dc,c'ember S — 9 19179 AT"T'BVIXES, 1 . 1 . ito 1 . 4 . An i nve s t I' ga t lon Ca r r I a a I ongs i.de the river c a I I ed Su I p'm.ir cr e.r, sh+:.,,vn the lack of relati.om.;hi.p bf.-%t-ween surface water and carbon diox- h S P r 1.TI S Nun-p tests on the Vichv and Arduchi,',',� 9c,aut— spr1rigs (apper)d i xe s .2 . ;in:, 7 3 ph o i o s � t o 3,) d i d s h o w 11 e s i d e s , t 11;..i r r h o s e t w o s p r I j..; d o,,,, ha'.'t' dir(".,ct � ink as far as water—heads are concerned . At,d.161che spring' s d1l"sc,.harge-, ( 1 .0 1 /s) cannot increased Lhrcw�,^', "where'.-is in Vichv spring case L'W Meall di.SChargC:' PUMI)ed during ',"ICU,' (8 .8 1/ �) is more th,'�n d'ot5hde tha-n that. nwasured jt.ist after openin,-., the 1)1 .,e '4 alto"..:ing to fc-recast ilhe 11c1ssll771l-1. ty of ptim-, 111tm 01" SiMICMI 12 for ei i f t hours in Succession , The discharge meassured the next day, af."er 18 lh()urs IDnE on can be rnad(.,? betwoen tl-iis vakje and ["De not. t 'wi-,S not po s s i b I e to men sure the d i s c ha,r ge� I rom r..he over f T'he d r i I I e,,.1 we ; I I' n 11 1he c-o ur tya and p rod uc e d wa t e r era t h a s mo e M i nQ r,:i I on[r:.,n t t han, r-ha t. of the s p r i n gs (3 .6 A!,/1 1 n s t e ad o f i L t � dewa we1 in aucc)nfin iferthe erme aL .ty ;e ,;,nm,:v t k)c,, coninutcd due to t�Re lac -, of the ,;ell lo- andi t c amp be a sse cs(,d t 1ja s R"1 a i3i f,,-,r I s f e 1,d ho L h by :Ile L eori c t e r .-mcl by mi.ne,"ZI titer EXHIBIT Page 3713 of 4165 w. " �",yy ' 1'1W f,,,,,l•Y'4F g��1 w �yes^ �" c t� .� � �,,�, •"^°"�'� ' ,;.t d`"M'.,� }�c�y y.'� °N'4gvn �yF � �4d !r�r �,i"•" �'�'M.y10��"-�r"d�, �"�"�"!��°"hMM�9 � Pum pin F, test on Vichy spri"1 ,. t(.) t1jc rigl-it she(i sheltering the basin. to t4)(, I e f t ra1c:j 19 "11 century barhs at the batc°k Mr . Hans " oopa 1 , I''.`W. dot'��" �Ad �" 4 •�° � .,��., s� �m� ��� �� w I i. fee- i � 7 Owlei rAIrMV1 MI Mm .W A'S 'C Lb P17 ^"`J C�"' 7 r" S o r 1'rip, t c") t h e p I A n t ". Page 3714 of 4165 VICHY SPRINGS HISTORIC FLOW AND, TEMPERATURE DATA PRIOR TO DRILLING OF MONITORING WELLS 90-8 AND 92-4 UKIAH, CA .......................- ................ Date Temperature Flow Reference (FQ) (um), .................... 1889 93` 333.3 Anderson�2� .............................. ........... 19115 88c' 16 Waxing(3) .... .............. .................... 1965 50_90,,1(4) �5) 30(`)1 Waring 1979 86-90 53.9 Walgenwiti')' Notes: (1) gpm gallons per ininute (2); Anderson, W., M.D., 1889, Mineral Springs and Health Resorts of California ivith a Complete Chemical Analysis oj'Every kiporiant It Water in the World, Pacific Medical Journal, San Francisco, CA. (3) Waring,G.A., 1915,Springs qffalr�fbrnia,U.S.Geological Survey,Water-Supply Paper 338, 410 p. (4) Reported temperature is range for all springs at site; reported 'flow represents combined discharge frorn all springs at site. (5), Waring, GA., 1965, 7hertnal Sprin,;)s of the United States and Other Countries of the World -A Swronary, U.S. Geological Survey, professional Paper 492, 383 p. (6) Walgenwitz, M , 1979, Vichy Springs, Ukiah-Mendocino County, Hydrogeologic Field Tests Perfortned, Bureau de Recherches Geologiques en MinieTes,Orl6ans C dex, France I_AeA UK1ARR,0W-TEMP.TR1, EXHIBIT' Page 3715 of 4165 NK-l'iNE-E',,AL SPRENGS AND B.1-111TH RESORTS OF CALIF0.11MA WITIT & COM.PLETE CHEMICAL ANALYSIS or EVERY IMPOIUANT MINTERAL WATER TN TH IMMT) A PRIZE ESSAY AN-NUAL P,RIZE O�F THE MEDICAL SOCIETY OF T111' STATI,' or CALIFORNIA, ANVAnDim APRIL 20, 1889 By WINSLOW ANDERSON, M. D. Joint Editor and Publisher of the PACIFIC )IFDICAL ToURNAL XUL ClAil hfcIVZAJ C11cmistry Ad Molhca,..d TAcber of Ch,mdsjry to the Llk.wwira.1 c%t V,,&,",gy r..f C&I I fllrI,-M 9 he MediW..d tl)cnl#ti Ott,--f, Actr"SfenF—of the Amncaaa Mcf4c,%l A��ia"on,a gul of the Mcutc a I Sery of thf. atAle txfC as Actimmc Mef,",,,rxf v1nr ;f rcwumu. C.—Y M,a t Y.r'—cty,aod of me C.Hze of Fl,vul" o pf"l-,"—w.)I S,ocy 5-chary—d of tire Alrvnrrumo A.W.muorf of the Me&c.I Det—1 W lbe 0,--t ,y of Cdd—,ia. Memf,ct o the Jotod ull Memc.R E-mulem flan tt,SjAtp,Of C,I il_I Mtl-L—of fhe Nau,-A Edu-la.nak ASs+�;,tuo- A..1 y tdcy4 C h, to the Cortot p I of O'o G,ty.6 S.- F—�O. ".I.,cvf 'Adtihc—ons m F-1 p"w.f.ct,- -W' ,tg,n Vu—lm- m.ttAfity llpbch—A,-M.qhio-144—, rw.,E.M. SAN FRXiz�%7l:SZcD ' THE BAINCROF'r COMPANY 1&90 PRICE $1.50 SpociSal reties to Spril-Ig o s The'The'Ir ac tit�u is almost identical.s as indeed is their cheirlical. Nr a cc lrlpc sltacll with the acted Ems on the Lallrl ° . 1 of Nassau,, Germany ; and Vichy of Grande Grille, France. Y 'roin the f llo ill: , chemical analysis,made in Is88it x will be observed that the waters from the .foal Vichy are M heavily charged with carbonic acid gas and carbonates and f that they contain some iron and potassium salts_. �>s laxa'w,t9teints' VICHY Sold Tugredic L i,z 11"I�k.t°SC F r s xt a.t ,iwE'ttssnrs of California (IrarreeG:jilt Geresaraaz 1"�i ��t�Tt r OneC,a69tazii _dB u. rscZcs .� Germany�' aaaaalvrt Lre Baal x *� xa Grains �R. a ��c�uuas aau � rd by an lvxc�3 y a c xlvxt p by — *QMT F°RE"SENICS t'aaisa-rocs a TrMz O F; Tc�a ?� V' atarizuzaz� C lzlaasade 28.tiU 32.80 cut3aurza. 3G.44 r S Carkaaauu.z¢r....».....,... El 1�„p 1`95�52 208.00 155.84 84,24 sodium Sul pbata cn sgdlazrn 3 18,32 1<.12 trace ' �Il trns l.a ate 6.24 .41 Potassium Carbonate...—.... trace t �� M Potassium sul'phate...., . tract 18 32 Magnesium Magneswmcarbonate carbon ate.., .. 3 03 ,i 1U1 lt'.85Calcium Carbonate 6.80 18.48 16.09: 4 Ferrous Carlarzate........... 10.00 Strontiuni Carbonate ». t'? 16 .64 ,1kr Barium Carbonate.......... .. . 8 trace trace Li hium Carbouaate trace literates.. trace .............. trace w - A rseniat.fl s ± 0lurruzsrate Q8 silzra.... ... .» trace trade. trwao�e uu' 5.9 .40 ?.Ii3' a 22 2 Gases,cubie Inches --- ±'f a Mcd C arl r0uxtie Add as. 224.75 ...... 14.74 263,76 54,2,1 4 For an antacid, tonic, aperient diuretic and aalterativea i ineral water the C.J`kiall �r� 11r i ranks axuon a�n a w . r � R the Coast. `l"hey leave proved highly beneficial inr� on x disease, tOr t ity of the bowels and liver. For d l and acid conditions`� � tions of the urine and the blc cl the y are a excellent. M m � The waters are son to be "old commercially. Owing to recent developments the flow has increased � 37,as enorinousl%,, flOwing now about 20,aoo gallons per hour. l On the pl'elnises are numerous sprili �vll<ich will sooll he developed and analyzed. A. 17 F' D Mill I ' kw .w 1 y CENT„ O IcTRJ ,j 1� 9 � r"J UPI III` 14 INC ,.UU w� .U, .12 UPART40T Or TUN IMMAtolt OA LIFORNIA a , E r� a 4, O y< J 7u ()' 6 �u wa p u tl WASHIMITON vivirwTING EXHIBIT n I 4 y M irT�� fly r I�i��' / u'�^.���•� i P Page 3718 of 4165 +��iMrtrr ,ta'ttt+� Alt"3`rltr�, , LaMtr t tw t d iat taf tlttt r rMlttrcl rjtr�llmttt t. tlydtt truer>t° t l Ott wt trfltrtt �trarri� >3ttr�ttt- w tlaatt t��i11t"��t41� rya �t1M'�t� �lctp ,aPtrlydtti � �,r�M�Mxrt�Cr3�'r[� �Ir�, ,� rnr,trpd trra�rlrttctl� �� r�atrrt urt tit �l ttt�dtt= lt,�rrtrl,C�� ttcrtartt "Out rtrdltttw rttrrtls +0t rrf Cluftdtjtr. Its 110,at not hooll l�nrdrarCtrrrrt+tl� Ito ,r, Mid h tt ttwtrri 0111,y 04aVAmiull&RY h,r drinklyd , t'dtlr� "NOLZIM $OVA, RVjttW(p (*tr'rat 0jtr 1t) love Aa err 6 Olt �' 9 ddr aarr thtr Inwn l"4#ttl �tdtMrtv�tt ,�Jf'Itl �Ir�drrtw•dlly" alyd�attL # �l�r�r ttat"ttrrwt�t f ths,, ldtttor lr1tt00, hu r„ w lrt,t,trU rQuilloustr Ago 1ho tirit (Or 4 tt txl r of k trdknntttO tttW6 tcatt an d tho l co t l � � hlt bctt l "Prt�c d rty tarr ttlrtlln , �t WORY m'raurall t ctl+l'laa�rr�srtti Ytl apt r �r+r ftr ro rt l bt � r t�l �ilttr! rarp rralltvw Pjdrrtlrlrr t �ltltttatlale1Gt11t artttttfor r 00 rtrrcl 40vordrtll cott&M'* prtxtrltltatl a v.ctatatttt aldatln Mid tub 1a� 119 wrrr,4 stt llccl m f'trr 60 trrrtt�t�, r�tttt tlrs>trrtttlttrrrt lcltr t tl r� r 1 �ti t 1 t r u e" Tr101h hOU11, Ono of thor4, k1101vrt M Ardechn Sprini, t n ��rrra,rtdi�tl l bill 00ut" a by 15 tttrrt 1tt 11160 at d 2 "tot tlmp rtlrtl Sulrtllem lrntt' d0ro tubs Ott rt t*tlaltrrujt hchltjtr 14, 1tf�rrg lattlrlr100 rltrtt Withth" WAWr, radticlt is v4W%Uy olt,tttlod m l� la A � lttltl rtla 1d11 tl rt tq a ,an ly tt" t !c unt r drtttttl,ltforms—nirIAW of r 1r�. �urfrtr� Ito wow is tmtatirOSM t� naUt+utt llo It M It d t lqc aatm ar#nr abu t 14"O r�tt�tahkitt ,tod rlind tltcrlttnMVc;rtatu . Ita�trd* tl"" lr , lrtatt G4 dltrttr y tlt�rtr rtwutrd, ' rAt"Oun fmul li ha ; rlrtgP, 1c11y �rble lt't It lttrrrl ttf lrl�crytrrlrrr" >rtlrra tttrr ,, 1!tt W90', lbt tt t`ttttrtr�al �, talt�,ttt by 1t� fat Tdtrr matt of 1''htPatt trt rlrrm ato. It 6 rral,� to draava tut t"l,y i"SUM at It ltrrlrtt ,ydr& hirthor turret latrt tM g&,a to. tlrtt m ltputtt ott�tit tlarrdd tadrtttttl trrrrlhrtrrtlte�. dro �rtlt uttda f A drl �l l , t , l,A law not to lrrt+vtr rttYaamotl it hQW9 or""v,640 1, cltr m%ttrr rrlr`Ylt'lr h"gtrin wax 11�attrt�a�lrt rt r t�l,t ,"toratt tl�t rtlt �, t�rltr , trt at rrara r�r�tir,rrlalt rt� dtit [ ar° ry A4 1�ttdrtrrtdoud ton, nt►r to �, rww lth&t , tt �,vrtat � latrlar a rld #r, �ltrrb,�t«� rrl � �+' �xt t �,t a,f 1 �, ttt ItA slbtt"l,nt�4rt taw dtlrpr,, iXnAt0ly f%ripiw MA, I re Bl"multo oftho tomp6rAtUro of t1t,r ttR�t„nw Of �, � mt+ lrr � rr1 G 1wa rtlt tv ont tt� rt t 1P1. , itt, 1"kot) swtlraatrtel� rr t but t1my am 1r t kttrrwtrr fur their � rrwttt�+t1 tkr�r :t , r WAt r of Vitally s rill, tw ho t llr,tr+ltd hotttwr "l1061dar It MIA" t Y Otte, trt ter, fh ugla t�rl'►1 lrt tt lrrttlt. " �llt�lr+ art ,�,�trw 11tt 1v cuwttaNl b s+tttnll ltazlrtrlo,tef rd4rltvia d'lr,,edtlt++t q tl py, � ,dlltrG.t i'4t� o 10441or rM s d" " a a # I�� Page 3719 of 4165 M11 ry, o ry'L., 7IQ! 44 1 414":.) OCT y��y 4.SV..�.y1"� �L'j" d:S',14' y }w l a.. a , « l '..+ h.,r{ Os�.++'«w..,.a,...�....,., '', x ..rv« x4NN.WW rP,....•,py,n n 1 � s�nnnarrrwa r°s,ar.rar"w"wwan�r�a. is to ribotl t�, nrr oi'a�a'trio propertyf tbo ^arsr�t,�wr, Two ot�"1c,a' 0aaa�la�nar,t�aai � "'' r A,in tintw gwel At taw orsA olluo 11 sl'scla41t1's Why Mug thu rawtaa 1 11tat tltca awavar nat trt t1 'rc1' a+rl "�t4k i;wwitl ��tsi taitltrt tul�ar4ruta," twntwa.}� v rallrltis' rt rtr� A �ratlawrr�4 rt rrtia�wato And hua s tho rt�ttt0 trlrwnlntal"A. pulholl taa t,rtr w cot Spring. "ttrw o lta Alm tltNtall ow ping of known fis In � �� w tllwa JMtrwstarnits 8 n1im cant tbww bank tr vardA w oAtmird 7ivm Arde1�m w� wll a kt� snot tt�rwt is +�rwl latl r � t�nw aw Irtwa " b �'a t�a41" � t cr[to ttamiaa nr of eNttw0row tho araca(tt rt't upr an t1rwn la id# 25 or 30 toot itbovo the fora 46 " amrook, to t ird watwrla g of importance truos bi as rock-wolkiii WItt t"het Mslah, prcaw(Ad by it roof,smd ;trlo)drw parh&ps to qusa,Vor of is gaU n n min. brtrt'kl 4rsral ut", Me tho othor raprillp, It wlrwrovits twit 1nud ttf waAar hk a it troo rat t a slightly ralkallrno taa%;Wa It,iwa krtrawwtl ,ntr Ory0a)hprinjr and In A favor- troll"Min 1w for atr4%kirg,('tote It*wittor 6 tusol (601) aaaral plaslraaralttl r rarbo nwatort" fats ntw salt 1 Another small ,loo o"1 L4 d'nrmed by a +lam s m rink lwrn 10 11111Mt rw ,1 is tr sl awr w warllrs abawrtr Orytital tltsdA , '4 It hviww not boon ilmp,roved. T116 f611OW1119 AROYS100 of t O thM lVi4a lord O'prihU4 JAlscrasr tlasnzr wr t>aars to lsoprunattr„y ilk e,llnttt bii ehArsoter; & lr Lt uR d ,4%#(y0 a qug4a�rr0w "N &pviv4t, ,11144aq�aC'ov Cuunty,rul, dot"al of uJ rc swarssls�rllr ""Waal, nklia J1+1 IsjW1 wa4*4 nt' 60 low . . .. ,. " .... , �. - ..�. the 11'rwrllarw,i 04"0,1Wwr) k4"1",(vgP.) 160aw"(Ito r,) 1,40110011118 t 0AX1 'A��+1. 1Jr 4,11 lttkl,, IL C"a' aasassssafi. tMRIt1M, rw,a« M'f4wAF"'�. w�4wat, ryalat. Maaw�wlrtllirY a" I '4"111l1R1Y. w, s �10 r, 71,11 wr at w;'w'm oj,' lra +tlautlaw 'err w a 4 so:x� r n, a tall w; I�At�t " ilia rna "1'dn o '1'ldit artrw 1 1� "1,y�W.w Pa1^yy�7y11�""r, 71 +T w r t h� k a rPt� WN b+NgaVab�r wq kJ r� .« , a,s.. �9NVC1 411r I 9Y.YMP a�L a,t1,a r r1Y"a r"1�w1 tMbs a „" awwc w slow w hots laC .,41a �. ,. �,w � drat'rri�rlrawan r"rs1't+ral,ar rllrws cttrr➢ .,,. n"wrw OR IA fit'"laws was It I I , 14asv11 ,� w11wr fWlng, 1144;j,)o zd Ca ltan. AV� tw1 rX 11.A.441.41 Out"e na"rw,ft i xwraww,rw �p6nN[ ��� r t t� a4ww "w� C'wY, q�r r° '4'P'&Wr from thwo uplillgo lasso not b0011 bottlod 4sawrwwrwntarvi ally,C1114Y 'teal ttaaa lrm lr'orltradro Nome t4io tart And oalottuatr, it cootaing 4rtataa tlwc t,w'lrtla%a �wlwacrl h110 la rwnws insiwarsa ttww Maio. 1�a1�o1111411 r "; b 4 i t D 0 Page 3720 of 4165 6 N6 .UW ljlv� OADIJONATZ0 MP11ING0, Two otho The roolm of the 100AIlty ;lTo soft 01hy Mfiallw. ^Sito vivhy A10119 tho orook fol' isoWlo jILA(unco bWow Um F�prinp Q ero ;A A Cott. vs of f4bollt 91("110"10 t'11" hilt' WON14Y Wtll CSIMMAW fly 11MO ojirbon4w e totapot&- poDA04 froln the SION11V wmsr kilimi a a0um" 00104 rawllaa th A smull mllvbonajx:tl qtin t, k1lMy" its 04613 Sollm Spillng, r6f", at kbVO tbm,D bopo of the MJU jl, rnj e tttlawtaaa,4 q q1t, I)UK,,n m jwdon or' lambs 1juit Mail. A bdok-lhmllu 1-ollmol-Uke Wtsin him )A(fll UU110ruabd in 01) U'Du t.vnill� I b4a)t, and ill itulIll"Or 010 4141119 6 v4koa for driuklng W44r. As is r4wr 114A a f"Ale At W03t of tho other 0A)'Wilated Rp011p, thoto 1A oonsWoroblo iA r,favor. Irort opill alollf; i,ta Outflow '41(mrist, bmt tivp v0st 66" not sem to ArhnnAlAd. ba atrMily m1porollismL The rock rat tho lowlity to a0ft, 844. W1 410 O oo1oro4 Witilo Heart All'Ids 4 01ty sail. s4ow Iteir At Shomilitkor NU, 1, area untAfit rimorl, Ill t1lo 1a 11,1 0 w0st Of Ukift1l, thow m a[lumbO Of(!#rb011UW1 f3prinp that Ato mod' Of tho 100O11tY, Olaf or two gal tho NpriiqN or gill(I to ba molvICAIv, 1114 M49)MINd. Iforived koin umpiMinnim mmtMut tggoelatml uith thill 10difilalitflry Nerles, niffy be prOm"t ill "lluAll"i m1notint, Aovom,- I A"9%(60:V4 p alodatilmo)for About W gughts weril PrOVI(I'M at Tfoo propwy in 1010. ThrCo 1=14 APH)JO that,Arb impil for dAnklal;nj%gittiritutj nt Rhop] ttf MU, 4 ormil lijountain rmoTt alonsift:jj jnjj(*ll0pj.ljwt44 of(jovIlt,1010. k 0111Y wo A f Wing IISK 144111 InIflinVed fly n 06MOSIt b"JI, h%jt t1loy tI urnfish coo drinking wofar. Thip iG ,n' rk i oprng 1odprot'sly car- brollatod; f1m, other two nre Tolpootivoly gulphuraw mod forruginvio fill d4fill80tAll. VAXM0xA%TxD ly"tmum rjX" "IfVW9 (,"Xoqcuo 11). MIUMbPring Nottlomont about 4ri mIlAm norlim0*1, of(Movordalo. thol% 01"' "Y'll W th1*6 l;hM11 CkAllont-OH] ArXil"0q, 011A 0 wvA forwrly visitod by pioill(i pnj�j,lm, blit Ill j as yoAlv If, 4W Of fllkA -oop 11U IW4)nle pi%rtly "Ad 'JI'L A 2004(st wvli titn't tho wlater uIlki,sup pliom a TA111 polld In 110 lloigllbor- 1404)4 4100 Y1,6111A wnttv thnL In imrhnnikwol, WAXXI4 a,"AL prAUtag (MXjtD0(jjN0: by^11id tin the hankm of a apmeft iktit t1l4f, is to al watr,r0 Towid Ill A va hi*bimin A somill umping 1*4orf.for Nqvor4 y*Qu, %nd thorn oro flvO Mall Miunvidapringoorgy thoProm-tY. ('J Page 3721 of 4165 �•" « '��" ,.a mf'"� '",k�,° .. ,•arm ��! 6 �, G m ° a �m '+411MXW�M"^T as F � � r a T W�„'• .. M Kw..+ tM w',' gar o, . �.,�.� v k tl feq P. q N Y. lv } N x 4r �. ALI Z8 6. x 1 i�Jl w� mM, ld, 40 awr kaaaa rear MR w+ r'yrn aa. 6�raa+"XM+rarAp'r1 11 Nq,.A�iw. loolibus vim '. •---•"^^kr.'�arnww»wwwa�.... !..xrnkMwa.�...' I J ( I " . k 1 determination which the City was required to make in deciding 2 whether the project is categorically exempt . 3 Even though the plaintiffs' experts disagree with t1he City' s, 4 the, City must make a factual determination as to whether there is ,5 a reasonable possibility that the activity �Yill have a 6 significant effect on the environment due to unusual (:..,ircumstanc- i 7 es . (14 CC R §15 3 0 0 . 2 (c) It must also determine whether the 8 project will 11 . . . result in a serious or major disturbance to, an 9 environmental resource . " (14 CC: 15306 . ) 10 In making these determina.twions the City is entitled to rely 11 upon substantial evidence . (See Dehne v. County of Santa Clara 12 C1.981) 1-15 C'al . App. 3d 827, 844-845 [11 courts in similar 13I situations [reviewing categorical exemption determinations] have 14 cots sisten,tly refused to exceed the scope of their authority, on 15 , review of administrative decisions , by undertaking independent 16 evaluation of the evidence . instead, they have properly limited 17 themselves to application of the substantial evidence test , 18 (Citations ornitted. ) ,11 . ) 19 If the Court were to adopt the plaintiffs' standard of 20 review, it would order the City to conduct more studies to 21 determine whether the projiect will adversely affect the Vichy 22 Springs ; that is, whether the project is categorically exempt . 213 CEQA clearly contemplates that the C..L.Ly make this threshold 24 factual determination, based on substantial evidence . 25 B. The Cit s determination that drillipq the monitor- 26 ing well will not harm the Vi h sin i rted la a ratan- tial evidence. 27 Plaintiffs contend that the flow and temperature of their 28 springs declined significantly one month after the City drilled 94 20 Page 3723 of 4165 1 monitor-.i.ng well no . 9:2 4 . They contend that ,.-io other charige took 2 place that could account for t.his decline . Based on tl-)iis fact 3 alone , they contend t.-hat dr.illing any additional monitoring wells 4 in the same area could further dai-rrage their springs . 5 Their experts, then, hypothesize a seL of circur�istances that 6 could explain how monitoring well no . 92-4 caused these reduc- 7 t ions . Recognizing that well 92-4 has tapped a (lifferent 8 grou,11dwater aquifer than the one which supplies L.he springs , the 9 p.laintiffs ' ex-perts contend that well 92-4 could have: tapped the 10 pressure zone that causes, the springs to flow. Mr. Singer, the 11 plaintiffs ' retired rocket scientist , explains that if gas is 12 allowed to escape, the resulting reduction in pressure could cool 13 the water which that pressure inf luences . (See, also, Declaration 14 of David Evans , para 113 , p. 5, which also explains this fundamen" 15 tal principal of physics . ) 16 Th.e Cavity' s hydrogeologist has cons.,idered the plaintiffs, 17 theories . H i s firm has been conducting hyd:rogeotechnic�al 18 invest igat ions of the landfill for the last eight years . Mr . 19 Brown personally supervised the drilling of wells 90 -8 and 92-4 . 20 1-le has studied the borl.'ings from thosE-,,� wells . He has studied 21 aerial phot-,ographs of the area where the wells were drilled. 'he 22i photographs provide information on the cracks and fissures 1..11 the 23 geo. zone logi,c where the wells were drilled. fie has studied and 24: mapped the geology of the area . 25 Based on his investigations and his specific knowledge of the 26 area , lie believes that the plaintiffs' theories are high.1y 27 improbable . First , it is highly improbable for a well. with a two 28 inch diameter located 980 feet from the springs to cause the R-,-.ind 1,vichyj..opp C11C1Cn Cq' 1-r 2, 1994 21 'Cq Page 3724 of 4165 1 of pressure reduction that could account for the amount c>f 2 temperature and flow reduction reported by the plaintiffs , 3 Sec.ond, it is hiq1-ily improbable that a well drilled in one 4 geologic zone could inf luence pressures in a separate geologic,, 5 zone . 6 Third., the Continental Basin Deposits where the C-i.ty has and 7 will drill the monitoring wells does not con-Lain the cracks and 8 fissures through which gases could travel from the Franciscan 9 Deposits , where the Vichy Springs are located, 10 Fourth, if well 92-4 had caused a release of sufficient 11 pressure to cause the changes in the springs which plaintiffs 12 report , the pressure in the well would have changed significantly. 13 Neitlier during the drilling nor after the drilling has Brown. 14 detected that kind of pressure change in the well. . Mrown 15 Declaration, p. 15 . ) 16 Eit_r mow, if well 924 had tapped the pressure zone influencing 17 the springs, it would have penetrated a, confining layer capable of 18 maintaining gas under pressure . The soils extracted when the city 19 drilled well 92-4 indicates that the City did not penetrate such 20 a layer . (Brown Declaration, pp . 1.4- 15 . ) 21 Mr. Brown states that there is no evidence of a cause and 22 effect relationship between the d:rillin.g of well 92 -4 and t-he 23 reported reductions of the springs temperature and flow, (Brown 24 Declaration, p . 19 . ) If sun. spots appeared thirty days before 25 these reductions occurred, it would make just as much sense to 26 blame these redticti..ons on them. 27 Based on a review of the data developed by EBA, both David 28 Evans of the RWQC.B, who is a registered (-ivil Engineer, and Liz \vichyL,cpp 12, 199,1 22 Page 3725 of 4165 Haven, a geologist 2 independently determined err'T4rne I.h::it the existing m(_:+]11toY .1.ng wells have 3.. r.aot. caused the reported t`~ec:, reduction o:t.:: flow and temperature atur.e at the Vichy Springs and the e proposed benzene well will not cause further 5 reductions . (Evans Declaration, pp.. 10 _1"1 , Kennedy Declaration, 6 para . 17 , 1'_p . 6 .7 w Exhibits N a n d 0 thereto. ) There is also considerable uncertainty over the consistency of the springs, flow w and temperature ur e before the City dr::.rw1...1_ed well g 92 . 4 . 6 Although the sha f' s claim t.1rr-:rr both the flow and t empera- 11 ture of the springs declined in April 1993 , they did not inforin 2 the City or the RWQCB about the decline 'untmri.ii January 1994 , e:ight. 3 months later. During that time, they made rrr.r'mer.ous contacts with other agencies �-aaafm �. rw.�m,�w defendants b:am�� ruxrrrra�ar � � � officials . T lao sN: 5 communications reported many complaints about the operation of the 6 landfill , the drilling of well l :`gip 2 -4 , ;r r"k a:`l, their adverse effects k:"±1"-1, F the Ashoff' s resort business . However,. none r"'r,one o those letters or jg hd~rTr.e calls referred e to a reduction in flow d»}2_ temperature, r_,.1'en 19 though the plaintiffs' now characterize these effects a. "d r s as t._. 2g raror.as " (Evans Declaration, pp 1 0 _ _L1 ) 21 When Gilbert t sfaPuf f contacted David Evans in January 1994 4 ,And. 22 later Margie Awrho f contacted Rick Kennedy in February ua'rry 1994 , t.iaG.y 3 ar^v,7'l4lp.la.irr.ed ai::.7o'1,r.t a. temperature reduction, but not a.. reduction o't'.:: 24 x lOw (Evans Declaration, para . 22 , it 7 , xhi i..t:: Z thereto; 25 Kennedy aiy Declaration, para. 6 , p, M Exhibit D thereto. ) ) 26 ,.1:he first mention of ra flow r'ed.t..r.ct.r.on came in a letter to tMi'.re 27 City Manager from attorney James Mazzoni who reported tee 'a flow 2 reduction of 30% This is a sl"mrall_er reduction ttrnrran the Ash offs .,..y Page 3726 of 4165 I represented in Exhibit I to the Ashoff Declaration, dated October 2 24 , 1-9�m, , which was the first time temperature and flow figures 3 were provided to the City and the RWQCB . (Evans Declaration, para . 4 28 , p. 10 . See also note 4 , p , ante . ) 5 Moreover, the record of temperatures and flows for the 6 springs at the Vichy Springs resort show a considerable fluctua- 7 tion in both, temperature and flow over the more than 1.00 years for 8 which there is a record. (Brown Declaration, 1..) . 1.8 ; Exhibit M 9 thereto . ) The historic record shows fluctuations that are greater 10, than those reported by the Ashoffs for the period after March 11 1994 , when t-he City drilled well no. 92-4 . Ud- ) 12 Fluctuations of this type are common for mineral springs and 13 can be caused by a number of natural events, including very small 14 seismic events . (Brown Declaration, p. 1-9, . ) 15 Given the total absence of evidence showing an interconnec- 16 tion between the monitoring wells and the Vichy Springs , the 17 considerable uncertainty as to the "'normal " temperature or flow of 18 the springs and the likelihood that a natural event and, not the 19 monitoring wells are responsible for any observed changes in 26 spr.-ina flow or temperature, this Court must conclude that 21 substantial evidence supports the City' s deter-mination that 22 Idrilling the monitor.,ing well is categorically exempt from CEQA. 23 DATED - December 12, 1-994 Respectfully submitted, 24 RAPPORT AND MAR TO 25 26 By: DAV �PPI'(OR] (,!i-f'y Attorney 27 Attorneys for City of Ukiah 23 12, �9�14 24 Page 3727 of 4165 DATE : DECEMBER 9 , 1994 PAGE C1,1ENT : UKIA14 LIBRARY : CAL FILE : CAADMN YOUR SEARCII REQUEST IS : 23 CCR 2205 NUMBER OF SECTIONS FOUND WITH YOUR REQUEST THROUGH : L,EV E L, i . . . Appendix No. 1 Page 3728 of 4165 Page 3729 of 4165 PACE 21 1ST SECTION of Level 1 printed in FULL formaL . BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS Copyright (C) 1994 by Barclays Law Publishers All rights reserved * *THIS SECTION IS CURRENT THROUGH REGISTER 94 , NO. 47, NOV EMBER 25 , 1994 ** TITLE 23 . WATERS DIVISION 3 . STATE WATER RESOURCES CONTROL BOARD CHAPTER 9 . WASTE DISCHARGE REPORTS AND REQUIREMENTS ARTICLE 2 . WASTE DISCHARGE REQUIREMENTS FOR DISCHARGES OTHER THAN FROM POINT SOURCES TO NAVIGABLE WATERS 23 CCR 2205 ( 1994 ) @ 2205 . Preliminary Procedures Each waste discharge report togethor with the required filing fee shall be suhmitted to the appropriate regional board on forms supplied by the board , Relevant supplemental information as required by the board shall also be provided . The report shall contain all the available information required by the form and shall be sworn to or submitted under penalty of perjury. The board shall determine the adequacy of a report and fee within the time limits set forth in Government Code Section 65943 . Pursu ant to Section 13260 of the Water Code , the board may waive the filing of a report , in which case it will notify the sender and return any fee that has been paid , ATTIPHORITY : Nfote : Authority cited : Section 1058 , Water Code . Reference : Section 13260 , Wat , Code . HISTORY : 1 . Amendment filed 6 - 30-80 ; effective thirtieth day thereafter (Register 80 , Nc 27) . 2 . Amendment filed 10-26-88 ; operative 11 -25 -88 (Register 88 , Page 3730 of 4165 DATE : DH""—�:�"M-7,ER 9 , 1.994 3 GIBRARY : CAL, FII,E : C7,ADMN C I'.i7AT 1 1 23 CCR 2240 (1994 ) YOUR, SEARCH REQUEST TS .. 23 CCR 2205 Page 3731 of 4165 213 CCR 2240 ( 1994 ) printed in FULL format , PAGE BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS Copyright (c) 1994 by Barclays Law Publishers All rights reserved **THIS SECTION 1S CURRENT THROUGH REGISTER 94 , NO. 47 , NOVEMBER 2S, 1994 ** TITLE 23 , WATERS DIVISION 3 . STATE WATER RESOURCES C01,17701.., OARID CHAPTER 91 . ENFORCEMENT PROCEDURES ARTICLE 1 . CEASE AND DESIST ORDERS 23 CCR 2240 ( 1994 ) @ ",2 2 4 0 When Issued A cease and desist order should be issued whenever significant violations of waste discharge requirements or prohibdtions are threatened or such violations are occurring or have occurred and there is a likelihood that the violations will continue in the future . AUTHORITY : Note : Authority cited : Section 185 and 1058 , Water Code . Reference : Section 13283 and Chapters 4 , 5 and 8 Of Division 7 , Water Code . HISTORY : 1 . New Subchapter 9 . 1 0@2240 through 2245) filed 12- 3 -70; effective thirtieth day thereafter (Register 70 , No. 49) . 2 . Amendment of title in subchaptem 9 , 1 filed 11-21-78 ; effective thirtieth da'y' thereafter (Register 78 , No . 47) . Page 3732 of 4165 DA'I'E DECEMBER 9 , 1994 PACE CT LIBRARY : CAL F 7 1..,E : CAADMN CITATION: 23 CCR. 2242 ( 1994 ) YOU'R SEARCH REQUEST l.'S : 23 CCR 220'.) Page 3733 of 4165 23 CCR 2242 (1994 ) printed in FULL format . PAGE 16 BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS Copyright (c) 1994 by Barclays Law Publishers All rights reserved "THIS SECTION IS CURRENT THROUGH REGISTER 94 , NO. 47, NOVEMBER 25 , 1994** TITLE 23 . WATERS DIVISION 3 . STATE WATER RESOURCES CONTROL BOARD CHAPTER 9 . 1 . ENFORCEMENT PROCEDURES ARTICLE 1 . CEASE AND DESIST ORDERS 23 CCR 2242 (1994 ) @ 2242 Threatened violations of Time Schedules Failure of the discharger to meet an intermediate date in a time schedule issued pursuant to Water Code Section 13300 should, if the failure jeopardizes compliance with the final date in the schedule, be treated as a threatened, violation of requirements and a cease and desist order should be issued. AUTHORITY : Note : Authority cited : Sections 185 and 1058 , Water Code . Reference : Section 13300 , Water Code . HISTORY : 1 . Amendment filed 12 -7 -8i ; effective thirtieth day—thereafLer (Register 50K Page 3734 of 4165 :4 k E N N D D k E N NN I.) D k N N D ;k FFEEL N N DDDD SEND TO . RAPPORT, DAVIE) p 7.T��L� HENRYCALIFORNIA �T.. T A 4 82 -4355 Page 3735 of 4165 I PROOF (,. SERVICE BYMAIL OR HAND j,,ZLIVERY I am employed in the County of Mendocino, State of California, I am over the age of 18 years and not a party to the within action; my business address is that of Rapport & Marston, 200 West Henry Street, fl.O. Box 488, L)Tkiah, CA 95482. Ori December 12,, 1994, 1 served the below listed docurnent(s) described as: MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSFTION TO PLAINTIFFS' APPLICA"I"ION FOR PRELIMINARV INJrUNCTION by depositing X true copy _ original thereof enclosed in a sealed envelope addressed as follows: PANO ST EP,HENS, ESQ. (by Hand Delivery) Attorney at Law 2,01 North State Street t3kiah, CA 95482 JOHN DAVIDSON, ESQ. (by Mail) Deputy Attorney General State of California Justice Department 455 Golden Gate AvCtILIC, 462,00 San Francisco, CA 94102-3658 X BY MAIL, X 1 deposited such envelope in the mail at Ukiah, California, 'I'he envelope was mailed with postage thereon fully prepaid. As folk:ws: I arty "readily familiar" with the firm's practice of collectiori and processing correspondence for mailing, tinder that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at t3kiah, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. X BY PERSONAL SERVICE (I caused said envelopes to be delivered by hand to the offices of the addressees). X ST'A,rr,,, I declare under penalty of perjury tinder the laws of the State of California that the foregoing is true and correct. .............. FEDERAL I declare that I am employed in the office, of a metriber of the bar of this court at whose direction the service was made. Executed on December 12, 1994, at Ulkiah, ( <alifea aria. CAROL NOT ARO Page 3736 of 4165 WASMCHNOLOGIES Engineers & Environmental Consultants August 31, 1994 Mr. Rick Kennedy, Director Department of Public Works City of Ukiah 300 Seminary Avenue Ukiali, C'A 9:5482 RE: UKIAII LANDFILL SITE MONITORING WELLS AND VICHY SPRINGS RESORT Dear Mr, Kennedy: This letter report summarizes the data we have developed to date, regarding the potential for groundwater impact to Vichy Springs by groundwater Monitoring wells at the Ukiah landfill. This report was prepared in accordance with a letter dated Atigust 1, 199:4, from the California Regional Water Quality Control Board, North Coast Region (RWQCB), reqUesting a summary of information stipporting our conclusion that the existing or future groundwater monitoring wells at the landfill will not adversely impact Vichy Springs. It is our understanding that the RWQCB has made a similar reclijest for data and a technical report from Mr. Ashoff, the owner of the Vichy Springs Resort. BACK"JROUND As you are aware we have examined tile available hydrogeologic and geocheirlical data, and found no evidence supporting Mr, Ashoff's claim that Ukiah Landfill site monitoring wells have adversely affected geothermal spring activity at Vichy Springs Resort. The RWQC13 has reqUested a suniniary of relevant facts so that concerns can be resolved and the hydrogeologic groundwater investigation at the landfill can continue, This letter presents the data supporting our conclusion that the monitoring welts at the landfill do riot influence geothermal spring activity at the Vichy Springs Resort. Through a letter, dated May 6,, 1,994, from attorney . ames R. Mazzoni, Jr,, Mr, Ashoff contends that ininiediately following the installation of tile well 912-4, (installed March 15, 1993 through March 18, 1993) the temperature at Vichy Springs declined 12 degrees (a six degree increase was later observed, for a net decrease of six degrees froni its "Ifistoric tem1mrature"). Mr. Ashoff further alleges an accompanying decrease in discharge of thirty percent from a LAPROJECTA61 MAI VRWQC'B,I,'Tk EM W-wlmlvg eT 825 Sonoma Ave., SLIfte C P.O. Box 4600 Santa Rosa, California 95402 (707) 544-0784 FAX (707) 544-08,66 11344 Colorna R&, Suite 245 Gold River, California 95670 (9116) 852-6800 FAX (91'6) 852-0866 Also Las Vegas, Nevada Page 3737 of 4165 r Mr. Rick Kennedy, Director August 31, 1994 Page 2 reported flow of 65 gallons per minute (gpm). This decrease in flow of 19.5 gpm (30% of 65 gpm) is also attributed to the presence of monitoring well 92-4. We believe it is highly improbable that either monitoring well 90-8 or 92-4 (see sheet 1) can adversely impact Vichy Springs. The two principal arguments for this position are 1) there are a number independent lines of evidence (geologic, hydrogeologic, and hydrochemical) supporting the conclusion that the monitoring wells are completed in a water-bearing zone that is different, distinct and physically separate from that of Vichy Springs, and 2) the monitoring wells can not physically account for the quantity of heat loss claimed, and volume of groundwater extracted from the monitoring wells is far too low to account for the reduction in spring flow attributed to them. Mr. Ashoff, to date, has not presented records of groundwater temperature or flow rate data for Vichy Springs to document the deviation from historic temperature or discharge referred to in Mr. Mazzoni's letter. SITE GEOLOGY The geology and hydrogeology of the area have been studied by a number of researchers (Blake and Jones, 1981; Cardwell, 1965; Farrar,1986; Treasher, 1958; and Upp, 1982)and is discussed in the Environmental Monitoring Program (EBA, 1993a) and the Report of Waste Discharge (ROWD)prepared for the landfill (EBA, 1993b). Based on a review of available geologic maps (Cardwell, 1965; Farrar, 1986) and site field reconnaissance mapping of the area, there appear to be three major geologic units represented in the vicinity of the landfill site. These include rocks from the coastal belt of the Franciscan Assemblage, Pliocene-Pleistocene Continental Basin Deposits, and contemporary (Holocene) alluvial deposits. The central belt of the Cretaceous-Jurassic age Franciscan Assemblage, underlies the majority of the Mayacamas range east of the Maacama fault (Blake and Jones, 1981). The Franciscan Assemblage outcrops in the Sulphur Creek drainage to the south of the landfill site, near Vichy Springs Resort. The central belt of the Franciscan Assemblage predomipantly consists of what is known as a tectonic melange. The melange consists of an admixture of disrupted sandstone and assorted metavolcanic, greenstone and chert inclusions, within a highly sheared and deformed, dark-gray shale matrix. Bedding deformation within blocks of interbedded sandstone and shale turbidites indicates that there has been a complex and varied strain history within the Central belt of the Franciscan Assemblage. As a result of the intense deformation history, the primary porosity of the Central belt of the Franciscan Assemblage has been greatly reduced. Accordingly, the ability of the Franciscan Assemblage melange to absorb, store and transmit water is almost entirely dependent on the degree of faulting, fracturing and weathering. Water often percolates into large upland areas underlain by Franciscan basement, and later discharges from springs and/or provides base flow for tributaries to the Russian River. Discharge of thermal water, such as Vichy Springs, is also quite common throughout the area. Historical records, however, indicate that groundwater yield to wells within Franciscan bedrock is L:\PROJECCW6ILWJAH\RWQCBXTR M WMteAndogles r Page 3738 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 3 generally unpredictable and in most cases volumetrically insignificant (Cardwell, 1965; Farrar 1986). Vichy Springs flows from fractured Franciscan bedrock exposed in a hillside along the southern edge of the Sulphur Creek drainage basin (see Figure 1). The entire landfill site is underlain by Pliocene-Pleistocene Continental Basin Deposits, which are referred to locally as the Ukiah Beds (Treasher, 1958). These relatively undeformed deposits consist of poorly sorted, highly consolidated, partially indurated, silt-dominated conglomerates, clayey sands, and silty clays which unconformably overlie an irregular surface of Franciscan bedrock. The maximum thickness of the Continental Basin Deposits is estimated to be in excess of 2,000 feet (Cardwell, 1965). The basal contact of the continental deposits, where it overlies the Franciscan bedrock has not been encountered in any of the test.borings or monitoring wells drilled at the site to date, including a deep test boring (17B-90-4, see Sheet 1) which was abandoned at a depth of 265 feet below the surface, approximately 545 feet MSL (EBA, 1993b). The hydraulic properties of the Continental Basin Deposits in the saturated zone at selected groundwater monitoring wells at the site were determined by in-situ testing. Hydraulic conductivity values were obtained from rising- and falling-head slug tests and are reported by EBA (1993b). Hydraulic conductivities reported from slug tests for the Plio-Pleistocene Continental Basin Deposits ranged from 7.5 x 10-1 cm/sec to 2.8 x 10' cm/sec, and Holocene alluvium tested from 1.6 x 10' cm/sec to 1.6 x 10' cm/sec. Lithologic boring logs of monitoring wells 90-8 and 92-4 (EBA, 1993b) indicate they are drilled through a continuous section of Continental Basin Deposits consisting of low permeability silty clays and clayey silts. No perched groundwater, aquitards or Franciscan bedrock were encountered during drilling. This demonstrates that the monitoring wells are completed in a distinctive and separate geologic formation, consisting of significantly different hydrogeologic properties, from the Franciscan bedrock in which Vichy Springs occurs. HEAT LOSS, The alleged energy loss associated with a 12 degree (assumed fahrenheit) decrease in temperature of Vichy Springs, immediately following the installation of well 92-4, was calculated assuming an aquifer with a conservatively small area of influence consisting of 1,000 feet by 2,000 feet by 50 feet deep with 30% porosity. The energy loss was calculated as 22.3 x 109 British thermal units (Btu) or 6,533,841 kWh. On a practical level it is extremely improbable that an energy transference of this magnitude could solely occur via a monitoring well with a 2-inch PVC casing without destroying or resulting in significant damage to the well. Mr. Singer, in a letter to Mr. Ashoff, dated March 19, 1994, presents examples of adiabatic LAPROIEM461UKIAIMWQCB.LTR EM Wmtedmiogke Page 3739 of 4165 Mr, Rick Kennedy, Director August 31, 1994 Page 4 cooling related to the rapid release of pressure in rocket motors and explosions designed to extinguish oil well fires. It is well established that rapid decornpressive cooling may be achieved in gasses, however, Mr. Singer states "it is cleat-that cooling of the spring wafer- re'sulted,ftom a reduction in form ation pressure and release qf the natural carbon dioxide gases in the f0t7nation by the drilling off""this single well". Mr. Singer faits to present any site specific, hydrog solo gic data to support this conclusion or his recommendation that no further drilling be allowed in the vicinity of the springs. No significant changes in pressure (other than barometric variations) were observed during drilling or following installation of monitoring well 92-4. In addition, monitoring well 92-4 is located in relatively low permeability material, making it unlikely that gasses would migrate at the rate comparable to Mr. Singer's cited past experience. Based on the discussion presented above, and in the absence of historic temperature data for Vichy Springs, it is reasonable to assurne that the temperature oscillations observed in Vichy Springs water are likely within the range of normal floctuation. Evaluation of a detailed temperature database should allow the identification of historical temperature ranges and possibly temporal variations in temperature, Recent observations by the Mendocino County Environmental Health Department indicate that the temperature of Vichy Springs has Healthll dentyrtrmal level" (personalcommunication,Men:ocino EnviTomnentalepartment personnel, 7/28/94)., This further suggests the landfill monitoring wells are not influencing Vichy Springs. DAM-REMUM A flow reduction of thirty percent from a "histoile level" of 65 gpin has apparently been observed at Vichy Springs,. This equates to a 19.5 gprn reduction in flow or an annual reduction of 10,249,,200 gallons, This loss has been attributed, by Mr. Ashoff, to nionitoring wells 9,0-8 and 92-4. To date sampling records show that the volume of water extracted frorn the two, wells due to development and sample purging is approximately 172 gallons, from 90-8 since April 1991 (an annual total of 57 gallons) and approximately 3,6 gallons from well 92-4 since May 15, 1993. Additionally, during the drilling of both monitoring wells no zones of high permeability were encountered, Further, no free water was encountered in well 92-4 during drilling. Well 92-4 was completed on March 18, 1993 and groundwater was not observed until April 27, 1993, 40 days later. Both well 90-8 and 92-4 have slow recharge rates following sample purging consistent with the low permeability subsurface rnaterials, in which they are installed. Clearly, the monitoring wells are not physically capable of extracting groundwater at flow rates sufficient to account for the reduction in discharge frorn Vichy Springs. Further, the thickness of the Continental Basin Deposits and the depth to the Franciscan bedrock (the geologic formation associated with Vichy Springs) beneath the site is swot known,, however 1..APROJEM)461(X1A1"WQCOJ,:1-R EA4 W"we*AAJiff Page 3740 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 5 exploratory borings from the site, as previously discussed, illustrate that the thickness of the low permeability Continental Basin Deposits is significant. Therefore the likelihood of groundwater flow from the water-bearing zone encountered in wells 90-8, and 92-4 to Franciscan bedrock is very low, QRGANIC AND INORGANIC HYDROCHEMICAL ANALYTICAL RESULTS, Wells at the Ukiah Landfill have been analyzed for a number of water-quality parameters since 1987. As part of this analysis available chemical data for Vichy Springs was evaluated to examine the similarities and differences in groundwater hydrochemistry between groundwater encountered beneath the landfill and mineral water from the Vichy Springs Resort, These analytical results are presented and discussed in detail by EBA (EBA, 1993a; 1993b). Sampling of landfill wells has identified three areas of groundwater impact (well 87-1; wells 90- 4 and 90-5; and well 90-8) based on the consistent detection of volatile organic compounds (VOC's). Samples, analyzed from Vichy Springs in 1987, 1990 and 1991 did not detect VOC's. Analysis of groundwater samples from Vichy Springs for total (unfiltered) metals has also been, performed in 1987, 1990, 1991, and 1993 of which a number of nietals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, mercury, molybdenum, selenium, silver, thallium, tim, titanium, vanadium and zinc) have not been detected above their respective MDL's. To date, no pesticides or PCB's have been detected in any landfill groundwater samples or samples collected from Vichy Springs. Analysis of major anions and cations suggests, in general, that the landfill monitoring wells exhibit significant variations in the concentration of all parameters evaluated but do not appear to exhibit a consistent pattern. No monitoring well is significantly different from all other wells for all parameters evaluated. Well 90-8 and Vichy Springs generally exhibit higher parameter concentrations than most other monitoring wells. Compositionally, however, the analysis indicates that well 9,0:-8 and Vichy Springs exhibit significant differences from each other in cation and anion content. As noted in the Hydrochem,ical and Statistical Evaluation of the City of Ukiah 'Landfill (EBA, 1993a; 1993b), the general hydrochernical signature of Vichy Springs is similar to some landfill wells and different from others. Vichy Springs is readily distinguishable from all landfill wells. VOC's have been identified in, specific monitoring wells and have not been detected in samples from Vichy Springs. Boron is believed to be associated with recent volcanic activity in the northern coast ranges, and is commonly reported in groundwater on the east side of the Ukiah Valley (Cardwell, 1,9 ; UNPROI WrWI%JKIAIUWQCBJ_TR FAA Waviechs"oo" Page 3741 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 6 Farrar, 1986). Boron was detected at Vichy Springs in 1990, 1,991, and 1993 in concentrations ranging from 100 mg/l to 126 mg/l, significantly higher than any of the landfill monitoring wells. Based on data from the July 12, 1994 sampling event, boron concentration in landfill wells ranged from <0.5 to 54 rng/l. Boron concentrations in well 90-8 and 92-4 were 23 mg/l and 54 mg/],, respectively. Boron, concentrations for southeastern landfill well locations (90-6, 90-8, and 92-4) are not significantly different from one another but appear to be significantly higher than all other monitoring wells, suggesting a possible relationship between location and concentration,, Temperature data provided by Mr, Ashoff collected on December 6, 1979 indicates that the temperature of Vichy Springs was 30.,60 , significantly higher than the temperature of groundwater water in monitoring wells 90-8 and 92-4, which ranges from, 20o, to 210C and 15o to 25oC, respectively. However, as discussed previously, evaluation of a detailed temperature database from Vichy Springs is needed to identify historic temperature ranges. STABLE ISOTOPE ANALYSIS To further characterize the hydrochemistry and hydrogeologic relationship between the shallow groundwater beneath the Ukiah Landfill and Vichy Springs mineral water, stable isotope studies were performed (EBA, 1993b, 1994a, and 199!4b). Important trace isotopes of hydrogen and oxygen atoms in water (1-12160) are deuterium (D) and oxygen-18 ("0) which can provide a Fingerprinting" of a source water by its stable isotopic signature. This fingerprinting can provide a very effective method for water characterization, with particular application in tracing the source, migration,, recharge,: and history of a particular groundwater. Rather than relying solely on the concentrations of constituents that are susceptible to chemical, physical,, and biological transformations, stable isotopic identification of a water type allows tracking of its subsequent flow and mixing, independent of its chemical concentrations. The results of the stable isotope analyses exhibits very distinct isotopic variations in groundwaters in the Ukiah Landfill area, and that the different waters can be easily distinguished. In: a plot of 6D vs 6,"0 the majority of the samples lie along the Meteoric Water Line (MWL) at values appropriate for coastal California (Craig, 1961). The plot clearly shows that Ardeche Spring and Vichy Springs water have isotope characteristics distinct from all other groundwaters at the landfill (see Figure 2). Furthermore, no mixing trend between Vichy Springs/Ardeche Springs water and any other water is apparent. Non-mixing further indicates there is no interconnectivity between, groundwater at the Vichy Springs Resort and any of the groundwaters collected from the landfill wells. As discussed previously, Ardeche Springs and Vichy Springs both flow from fractures and joints in the Franciscan bedrock exposed in the Sulphur Creek drainage. Both of the springs plot close FRA WarmcA,"ooes Page 3742 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 7 together, well to the right of the MWL, appropriate for connate or mineralized formation, waters. Samples with BD and VO values that plot to the right of the MWL have usually undergone isotopic enrichment by evaporation or water-rock interaction associated with older waters that have also undergone mineralization through long residence time in contact with bedrock. Water- rock isotopic exchange is not significant in cool, meteoric groundwaters, including most young shallow groundwater (Dr. Bob Criss, personal communication, 1993:), Samples from wells 90-8 and 92-4 also plot to the right of the MWL, but are significantly separated from those of Ardeche Springs and Vichy Springs. As described in the ROW D (EBA, 1993b) these low yielding wells have been installed in silts and clays of the Continental Basin Deposits along the northern divide between the Sulphur Creek drainage basin, where the Vichy Springs Resort is located, and the landfill drainage basin. The City Range Spring is located on the north side of the ridge which divides the two drainage basins. The City Range Spring flows from, the Continental Basin Deposits, and plots closely with samples from wells 90-8 and 92-4. It appears likely that groundwater in wells 90-8 and 92-4, and the ,it Range Spring are related, and represent another formation water in the area. In a letter dated July 26, 1994 to Mr. Ashoff, Mr. Davisson concurs with the results and interpretation of the stable isotope evaluation. He further presents a hypothetical example in which two formation waters may belong to the same general hydrologic systern and recommends that a hydrogeologic investigation be performed in the region. Unfortunately, Mr. Davisson may be unaware of the results of the ongoing hydrogeologic investigation and the geologic and hydrogeologic information developed which supports a different scenario. Mr. Davisson also does not present an opinion regarding the probability of site monitoring wells impacting Vichy Springs. CONCLUSIONS Local and regional geology, hydrocheinical analytic results and stable isotope analysis provide data supporting the conclusion that monitoring wells 90-8 and 92-4 are not impacting Vichy Springs because they are installed in a water-bearing zone significantly different from and not connected to, or intermixing with, the water-bearing zone of Vichy Springs. Further, calculations examining heat loss and flow reduction reported to have occurred at Vichy Springs, clearly demonstrate that the monitoring wells are not physically capable of influencing the hydrology or temperature of Vichy Springs. Based on the data developed,, it is our opinion that the likelihood of future landfill site monitoring wells adversely impacting vichy Springs is extremely improbable. It should be noted that Mr. Ashoff has demanded that an in-depth surface and subsurface hydrogeologic investigation be performed in the area. The City of Ukiah has been attempting ERA:,wmtefhnaMsks Page 3743 of 4165 Mr. Rick Kennedy, Director August 31, 1994 Page 8 to perform hydrogeologic, investigations at the landfill site to identify and characterize the vertical and lateral extent of impacted groundwater, which Could pose a threat to the waters of the State. Any responsible and detailed hydro geologic study rnust include the installation of monitoring wells in order to further evaluate groundwater conditions. These investigations have been delayed by Mr. Ashoff and are as yet incomplete. In order to further characterize benzene contarnination detected in groundwater samples collected frorn 90-8 and 92-4 and aid in the deterrnination of the direction of groundwater flow in the area, the installation of additional groundwater monitoring wells at the site is required, As you requested, we have submitted this letter report directly to: the RWQCB on behalf of the City of Ukiah. We trust this provides the information you require. Please call', me if you have any questions. Sincerely, EBA WASTECHNOLOGIES Damon F. Brown, RG, CEG Senior Geologist Duane Butler, P.E. President DFB/DB/Iyv attachments cc: David Evans, RWQCB ERE WeutechnMv�#,rj Page 3744 of 4165 Mr. Rick Kennedy,Director August 31, 1994 Page 9 REFERENCES IT Blake, M.C., and D.L. Jones, 1981, The Franciscan Assemblage and Related Rocks in .Northern California: in Ernst, W. G., ed., The Geotectonic Development of California, Prentice-Hall Inc., NJ,p306328. Cardwell, G.T., 1965, Geology and Ground Water in the Russian River Valley Areas and in Round, Laytonville and Little Lake Valleys, Sonoma and.Mendocino Counties, California; U.S. Geological Survey Water Supply paper 1548, 154p. Craig,H., 1961,Isotopic Variations in Meteoric Waters, Science no. 1.33,pp. 377 397. EBA Wastechnologies, 1993a, Proposed Article 5 Detection Monitoring Program and Financial Assurance Provisions, City of Ukiah Solid Waste Disposal Site, Mendocino County, California, EBA Wastechnologies, Santa Rosa, CA, April 1993,217p. EBA Wastechnologies, 1993b, Report of Waste Discharge for City of Ukiah Solid Waste.disposal Site, Mendocino County, California, Volumes I&11, EBA Wastechnologies, Santa Rosa CA, May 1993, 354p. EBA Wastechnologies, 1993c, Report of Disposal Site Inf6rination, Uiah Disposal Site, Mendocino County, California, Volumes I & H, EBA Wastechnologies, Santa Rosa CA, May 1993, 307p. EBA Wastechnologies, 1994a, Ukiah Landfill, Recent Stable Isotope Analyses, letter report to City of Ukiah,EBA Wastechnologies, Santa Rosa CA,April 14, 1994, 4p. EBA Wastechnologies, 1994b, Ukiah Landfill, Stable Isotope Analyses Ardeche Spring, letter report to City of Ukiah,E BA Wastechnologies, Santa Rosa CA, June 10, 1994, 3p. Farrar, C.D., 1986, Groundwater Resources in Mendocino County, California; U.S. Geological Survey Water-Resources Investigations Report 85-4258. Treasher, R.C., 1958, Russian River Reservoir (Coyote Valley) Project, California: Geological Society of America Engineering Geology Case Histories,No. 2,p. 33-36. Upp, R.R., 1982, 11olocene Activity on the Maacama Fault, Mendocino County, California: Ph.D. Thesis, Stanford University. [,:\PROJECT\4611JIUAHaWQCB.I,'rk fBA Wastechnologies Page 3745 of 4165 jkndr awrw..W i« ¢I�'s�" "w�n .mnu¢ amr" ��+� e �,.^'Y � M„4 �� � " ���d � Pi •^'� � ! .� i�'�..�.— ..�A 7 � n ( 777 X 0�K I ti� �'` �, �' �r„6r 0 ._.^'f t ! E� »,d �• yt... 4'w M � y k q�,6� /r�a.,r ='�r W ati r I 'a � ; w �`Er �"M t-� G'I`� r�, ✓�,^u t '� � � ���P 9 r.. 'S� " �`kl�a 2 ..... tiro ry Max r Aft, v3 a . f a Q71 u� x G /^.. P " i r C Vier_ w1E. ." wX, " , 'a... 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J1' � u "�" Cwy�S a q�tti ,• ���� / �"`'.i'^+ C l °". � - ✓ r" d I! ti I I. i f I yM�°�s 1 P r M�•. �. _ y� d�,�t `y � ds,` �itl II( y� I f I I�t'J�,14(}'�Pq�t i7 Y i�4 a" h grv1Y < �'•".."".v.. 4"Y �ff' 1,�" �• E � �•'', �� �S y%�.y r•,•�«� � �1,, d aAN��a..t { ���R�r:E� u°6���11��, a ''�.w..��� .;•;.,��.1� "�a W~w�u�b iy�� � A ffff J�0 `"r�, A ..::h,rP�. ; ti�.t� .++Yd y�li.r". ,0.tl1��� -��a s, ,.� " f v allf I '� � �«. r,. YP !� ^.M, �Eu�TaJd 4a�•^", x r— z >. 0 mo M o^ 0� 3 CL CITY OF UKIAH; ImmAhiDF6 L FIGURE MENDOCM COUNTY, CALIFORNIA SITE LOCATION, a$EPT�M4 Page 3746 of 4165 1 1 P as u c W t4 r ol 00 er V N 00 as � J 0 �a i N .m._ 1 1 N i 4 N VI: 6/94 CITY OF UKIAH LANDFILL FIGURE MENDOCINO COUNTY, CALIFORNIA STABLE ISOTOPE RATIO$ _.... __.. ,... _ Pa e',3isiR.� 6 . UUA'Ll I CONTROL BOARD State of California REFAnN 1 NI OR AND U M OCT 3 1 n4 To: Benjamin Kor Date: 0 North Coast RWQ,CB 0 9 T-1 FR ri XD Ti Opt; [J JH []JS 0 SW a7rTy M. Sc eller, Chief C3- x1ply t 0 All STAfT Division Clean Water Programs STD" E�R From: STA"T WATER RESOURCES CONTROL BOARD Subject: REVIEW OF UKIAYI LANDFILL MONrrORING WELL INFORMATION As you know, you contacted us recently to request that we review information relating to the drilling of a monitoring well near the Ukiah Landfill and its possible effects on the temperature and flow rate of a spring at the Vichy Hot Springs Resort. We have reviewed the information forwarded to us regarding the possible effects of drilling monitoring well 92-4 in March, 199�3. The well was drilled by the City of Ukial'i to monitor water quality in the vicinity of the Ukiall Landfill. The infortnation we reviewed consisted of- 0 October 24, 1994 letter from Gilbert Ashoff to Benjamin for 0 October 17, 1994 letter ftorn Gilbert Ashoff to Benjamin for 0 October 14, 1994 letter from Robert E. Mackensen to Paul Blais 0 October 131, 1994 letter from Alisto Engineering Group to Gilbert Ashoff 0 August 31, 1994 letter from EBA Wastechnologies to Rick Kennedy 0 Septernber 20�, 1994 letter frorn Judy Pruden to Chuck Rough and Rick Kennedy 0 July 26, 1994 letter from M, Lee Davisson (Lawrence Livermore Lab) to Gilbert Ashoff ' ,e 1' 1 7 Page 3748 of 4165 4 UKIAH LANDFILL Page 2 of 2 0 March 19, 1994 letter from Stanley J. Singer to Dani Renan 0 U.S. Geological Survey Water-Supply Paper 338, 1915 o U.S. Geological Survey Professional Paper 492, 1965 Our review of these materials, indicates that: (1) the monitoring well was drilled into a different geological formation from the formation underlying the hot springs; (2) apparently no pressure effects were noted during drilling; (3) the temperature of the water in the monitoring well apparently ranges between 59°-77°F, in contrast to the 90T temperature of the hot spring; and (4) data from Lawrence Livermore Lab shows that the water in the monitoring well and the hot spring have different oxygen isotope values and therefore are from separate water sources and have no apparent mixing relationship. One would expect waters which are in the same hydrothermal regime to have similar oxygen isotope values and elevated temperatures. Furthermore, if the monitoring well were in fact responsible for the drop in temperature of the spring, one would not have expected the temperature in the spring to have recovered almost to its pre-drilling temperature without a subsequent change in the condition of the well, e.g., plugging. In summary, we have not seen convincing evidence to support the conclusion that the drilling of this monitoring well could have impacted the temperature and flow rate of the hot spring. In order to better ascertain any relationship between drilling boreholes and the hot spring, the following information could be collected if subsequent monitoring wells are drilled: the temperature of the borehole during drilling; insofar as possible, the pressure of the borehole during drilling; the temperature of the spring during and after drilling; and flow rates of the spring during and after drilling. If you have any questions, please contact Liz Haven at (916) 227-4395 or Calnet 498-4395. cc: Dave Evans Page 3749 of 4165 ATTACHMENT 4 Correspondence Received for Agenda Item I I 1 WATER AND POWER LAW GROUP PC Paul Stanton Kibel (Bar No. 168454) 2 2140 Shattuck Avenue Berkeley, California 94704-1229 3 Phone: 510.296.5588 Email: pskibel(��7z,waterpowerlaw.com 4 5 HOLDER LAW GROUP Jason W, Holder(Bar No. 232402) 6 317 Washington Street, #177 Oakland, California 94607 7 Email:j_a ,qp holderecolaw.com 8 Attorneys for VICHY SPRINGS RESORT 9 CITY OF UKIAH CITY COUNCIL 10 11 VICHY SPRINGS RESORT, ) Case No. RUSSIAN RIVERKEEPER and MATEEL 12 ENVIRONMENTAL JUSTICE FOUNDATION ) CEQA NON-COMPLIANCE FOR CITY OF 13 UKIAH'S FINAL ENVIRONMENTAL 14 Petitioner ) IMPACT REPORT (FEIR) FOR LANDFILL CLOSURE PLAN 15 V. 16 CITY OF UKIAH PUBLIC WORKS ) DEPARTMENT and CITY OF UKIAH 17 ) CITY COUNCIL 18 Respondent 19 20 21 I. OVERVIEW: THE FEIR FAILS TO DISCLOSE, EVALUATE AND MITIGATE 22 FIRE HAZARDS,WATER QUALITY IMPACTS AND SCENCIC EFFECTS THAT WILL ADVERSELY IMPACT THE BROADER COMMUNITY 23 1. VICHY SPRINGS RESORT is a business and land-owner located immediately adjacent to the 24 location of the City of Ukiah ("CITY")landfill on Vichy Springs Road in Mendocino County, 25 California, and immediately adjacent to the location of the CITY's proposed Landfill Closure Plan. 26 VICHY SPRINGS RESORT was established more than 160 years ago in 1854 and is a California 27 28 1 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3750 of 4 65 I Registered Landmark. People come to VICHY SPRINGS RESORT for the outdoor naturally 2 effervescent"champagne" mineral baths and to explore the extensive hillside hiking trails. As the 3 current brochure for VICHY SPRINGS RESORT states: "Guests are invited to explore and hike the 4 700-acre private reserve where wildlife abounds in woods, meadows, streams and hills." The natural 5 scenic beauty and quietude of the grounds and trails of the VICHY SPRINGS RESORT are a main 6 reason people come and return. 7 2. RUSSIAN RIVERKEEPER is a nonprofit organization focused on the protection and restoration 8 of the Russian River and its tributary waters. There are streams and creeks below and in the vicinity of 9 the former Ukiah landfill that are part of the Russian River watershed. RUSSIAN RIVERKEEPER co- 10 submits these comments along with VICHY SPRINGS RESORT and MATEEL ENVIRONMENTAL 11 to ensure that the CITY's Landfill Closure Plan does not pose a threat of harmful releases of landfill 12 contents and toxic materials into such tributary waters. 13 3. MATEEL ENVIRONMENTAL JUSTICE FOUNDATION("MATEEL ENVIRONMENTAL") 14 is a California nonprofit organization focused on the prevention of pollutants and toxic releases into air 15 and water and the protection of ecosystems. MATEEL ENVIRONMENTAL co-submits these 16 comments along with VICHY SPRINGS RESORT and RUSSIAN RIVERKEEPER to ensure that the 17 CITY's Landfill Closure Plan does not pose a threat of harmful releases of pollutants into the air and 18 into streams and creeks near the landfill site. 19 4. In December 2019, the owner and legal counsel for VICHY SPRINGS RESORT attended and 20 participated in a public hearing in Ukiah on the draft environmental impact report("DEIR") prepared by 21 the CITY for the Landfill Closure Plan. On January 9, 2020, VICHY SPRINGS RESORT submitted 22 written comments to the CITY on the DEIR prepared for the Landfill Closure Plan. In both its December 23 2019 public hearing testimony and its January 9, 2020 written submission, VICHY SPRINGS RESORT 24 explained the numerous tangible ways that the currently proposed Landfill Closure Plan would 25 adversely impact the local community and natural environment and why the DEIR for the Landfill 26 Closure Plan failed to comply with the requirements of the California Environmental Quality Act 27 ("CEQA"). 28 2 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3751 of 4 1 165 1 5. As set forth in VICHY SPRINGS RESORT's January 9, 2020 written submission, and as set 2 forth herein, the CEQA non-compliance concerns raised by VICHYS SPRINGS RESORT, RUSSIAN 3 RIVERKEEPER and MATEEL ENVIRONMENTAL are not trivial or procedural in nature, but focus 4 on critical substantive environmental concerns that will have a lasting impact on the surrounding 5 community and broader natural environment for decades to come, such as: the enhanced fire risks and 6 public safety hazards associated the toxic highly flammable cover proposed for the landfill; the pollution 7 of nearby streams, creeks and the Russian River due to microplastic and PFAS releases from the 8 synthetic cover proposed for the landfill; the long-term scenic degradation of the beautiful natural 9 hillsides where the former landfill is located; the noise impacts that may ruin the outdoor recreational 10 experience for people living, hiking and walking near the landfill; the operation of groundwater 11 monitoring wells that have previously depressurized the carbonated subsurface mineral springs that are 12 the namesake of the Vichy Springs. Beyond these environmental impacts, in terms of the true costs of 13 the current Landfill Closure plan to Ukiah taxpayers, there is the fact that project budget provided to the 14 Ukiah City Council and the public in the CEQA documents do not include the costs of the additional 15 financial assurances and fire insurance that will be necessitated by the proposed synthetic plastic landfill 16 cover and do not include the likely costs of removing, disposing and replacement the interim synthetic 17 landfill cover. The failure to disclose the financial assurance, fire insurance and likely 18 removal/disposal/replacement costs associated with the proposed synthetic landfill cover indicates that— 19 in direct contradiction to claims in the CEQA documents for the project—the selection of the synthetic 20 landfill cover will cost the CITY and Ukiah taxpayers more than the selection of a clay/earthen landfill 21 cover. 22 6. In late April 2020, the CITY released its proposed final environmental impact report ("FEIR"), 23 and indicated its intention to certify the FEIR and move forward with the proposed Landfill Closure Plan 24 which included the proposed synthetic landfill cover. Unfortunately, as explained and detailed herein, 25 the FEIR released in late April 2020 does nothing to address or remedy the fundamental CEQA 26 shortcomings and omissions of the earlier DEIR, and as such the CITY's certification of the FEIR would 27 constitute a material violation of CEQA. If need be, VICHY SPRINGS RESORT, RUSSIAN 28 3 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3752 of 4 1 165 I RIVERKEEPER and MATEEL ENVIRONMENTAL will file a Petition for Writ of Mandamus in 2 Mendocino County Superior Court to have the CITY's certification of the FEIR and the CITY's 3 approval of the Landfill Closure Plan set aside. However, the preference of VICHY SPRINGS 4 RESORT, RUSSIAN RIVERKEEPER and MATEEL ENVIRONMENTAL would be for the CITY to 5 instead prepare and recirculate an EIR that complies with CEQA by properly addressing and mitigating 6 impacts thereby obviating the need for litigation. 7 8 IL CERTIFICATION OF THE APRIL 2020 FEIR WILL EXPOSE UKIAH TAXPAYERS TO EXTENSIVE LIABILITY FOR ATTORNEYS' FEES FOR THE 9 FAILURE TO COMPLY WITH CEQA 10 7. In the unfortunate event that VICHY SPRINGS RESORT, RUSSIAN RIVERKEEPER 11 or MATEEL ENVIRONMENTAL is forced to pursue litigation to ensure that the CITY prepares and 12 certifies an EIR for the Landfill Closure Plan that complies with CEQA's requirements, such litigation 13 may come at a significant cost to Ukiah taxpayers. In addition to the legal fees Ukiah taxpayers will 14 need to directly pay its own outside private legal counsel to litigate the case, under CEQA, the CITY 15 may also be liable for the reimbursement of VICHY SPRINGS RESORT's, RUSSIAN 16 RIVERKEEPER's and MATEEL ENVIRONMENTAL's attorneys' fees in the event that VICHY 17 SPRINGS RESORT, RUSSIAN RIVERKEEPER or MATEEL ENVIRONMENTAL prevails in the 18 lawsuit. 19 8. To provide Ukiah taxpayers and the Ukiah City Council with a sense of potential magnitude of 20 the CITY's exposure for attorneys' fees in this instance, it is useful to recount the outcome of a CEQA 21 lawsuit brought against the County of Madera(and brought by the legal counsel now representing 22 VICHY SPRINGS RESORT)for its unlawful certification of an FEIR for a project. In that previous 23 litigation, the County of Madera lost the case at trial, the FEIR certification (and project approvals) were 24 all set aside by the court, and the County of Madera ended up paying the petitioner more than $600,000 25 in reimbursement for the attorneys' fees expended in bringing the litigation. Again, for the CITY and 26 Ukiah taxpayers, any attorneys' fees awarded to VICHY SPRINGS RESORT, RUSSIAN 27 RIVERKEEPER and MATEEL ENVIRONMENTAL would be in addition to the monies the CITY 28 4 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3753 of 4165 I directly paid its own outside legal counsel to represent the City. 2 9. As discussed in more detail in the January 9, 2020 written submission by VICHY SPRINGS 3 RESORT, it should be noted that, according to documentation provided by the CITY in its DEIR and 4 FEIR, the additional upfront costs of using the clay/earthen landfill cover advocated for by VICHY 5 SPRINGS RESORT, RUSSIAN RIVERKEEPER and MATEEL ENVIRONMENTAL (as well as by 6 the North Coast Regional Water Quality Control Board)would be about$460,000. As set forth herein, 7 VICHY SPRINGS RESORT, RUSSIAN RIVERKEEPER and MATEEL ENVIRONMENTAL believe 8 this $460,000 figure to be illusory because it fails to account for the additional financial assurances and 9 fire insurance that will be required if the CITY selects the synthetic landfill cover. However, even if for 10 argument's sake one were to assume that the $460,000 figure was in fact somehow accurate, this 11 $460,000 figure is considerably less than the amount of legal fees (and liability for reimbursement of 12 attorneys' fees)that the CITY can reasonably be expected to pay if this matter proceeds to litigation. As 13 explained further herein, it should also be noted that this $460,000 figure is significantly less that the 14 likely removal, disposal and replacement costs for the proposed interim synthetic plastic cover(costs 15 which can be avoided altogether if the CITY opts for the permanent clay/earthen landfill cover rather 16 than the interim synthetic cover). From a fiscal standpoint, it is therefore hard to understand why Ukiah 17 taxpayers would support a decision by the Ukiah City Council to certify the FEIR prepared for the 18 current Landfill Closure Plan and proceed with the proposed interim synthetic landfill cover. 19 20 III. CEQA VIOLATIONS PERTAINING TO THE CITY'S FEIR FOR THE LANDFILL CLOSURE PLAN 21 10. As set forth herein and in VICHY SPRINGS RESORT's written comments dated January 9, 22 2020, which are part of the administrative record in this case, the underlying concerns with the 23 shortcomings of the CITY's FEIR for the Landfill Closure Plan are not of a trivial or merely procedural 24 nature. To the contrary, these concerns address fundamental and important issues, such as: whether the 25 proposed synthetic cover for the landfill presents fire and public safety hazards to the local community; 26 whether microplastic releases from the synthetic landfill cover will pollute nearby creeks, streams and 27 the Russian River; whether the landfill closure will mar and degrade the landscape for decades to come; 28 5 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3754 of 4 165 I whether the landfill closure construction activities will generate noise impacts that will ruin the outdoor 2 recreational experience for the surrounding community. The CEQA violations noted below go well 3 beyond the interests of VICHY SPRINGS RESORT and relate to impacts that will affect the broader 4 public, the broader community in Ukiah, and the entire Russian River watershed. The CITY's 5 compliance with the CEQA requirements noted below is the only means to ensure that the CITY has 6 properly studied, disclosed and incorporated feasible alternatives and mitigation measures to avoid 7 enhanced fire hazards/fire risks, water quality and biological resource impacts, long-term scenic 8 impacts, and construction-related noise impacts on outdoor recreation. This CEQA compliance may, in 9 turn, help avoid the unnecessary and avoidable waste of Ukiah taxpayer money on removal, disposal and 10 replacement costs associated with the interim synthetic landfill cover, and on the additional financial 11 assurances and fire insurance associated with the interim synthetic landfill cover. 12 13 First CEQA Claim —Failure to Evaluate Fire Hazards and Fire Risks of Proposed Proiect 14 11. As those who live in the County of Mendocino know all to well from the recent experience with 15 the deadly Paradise wildfire, and with many other wildfires that have broken out in the hillsides around 16 Ukiah in recent years, the public safety threats posed by wildfire in this regional are tremendous. This is 17 why Appendix G of CEQA now expressly requires that EIRs address the fire hazards and risks 18 associated with proposed projects, as a means to ensure that lead agencies consider feasible alternatives 19 and adopt feasible mitigation measures to reduce such fire hazards and risks. The California Department 20 of Fire (Cal Fire) has specifically identified Ukiah as a high wildfire hazard area. More specifically, Cal 21 Fire's Fire Hazard Risk Map for Mendocino County (attached as Exhibit 1 to these written comments) 22 identifies the area around and immediately to the east of Ukiah as a high fire hazard zone. 23 12. The synthetic landfill cover that is currently proposed as part of the Landfill Closure Plan is 24 particularly flammable, and given the synthetic toxic materials that are part of this synthetic cover may 25 release dangerous toxic materials if it catches fire. More specifically, the opinion letter from Pangea 26 Environmental Services (attached as Exhibit 2 to these written comments) documents that the synthetic 27 landfill cover is composed of polyethylene fibers that emit numerous airborne toxins (including 28 6 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3755 of 4 165 I hydrogen cyanide)when ignited and that present acute health and safety risks to both firefighters and 2 nearby residents that would not occur with a clay/earthen landfill cover. This is in contrast a clay/earthen 3 landfill cover, in which the clay is not particularly flammable and in which the natural grasses on the 4 surface do not present the prospect of toxic releases if they burn in the event of a wildfire. The fire 5 hazard/fire risks associated with the proposed synthetic landfill cover were noted in the January 9, 2020 6 letter submitted to the CITY by the North Coast Regional Water Quality Control on the DEIR prepared 7 for the Landfill Closure Plan. In its January 9, 2020 comment letter to the CITY, the North Coast 8 Regional Water Quality Control Board stated: "Lastly, regarding the Proposed Project-turf-based 9 design, Regional Water Board staff has reviewed and expressed concerns unique to a turf-based system 10 with the City of Ukiah representatives. Given the State of California's recent experience with 11 catastrophic wildland fires which resulted in significant infrastructure loss and damage, the 12 Proposed Project's synthetic turf design has an inherent surface-based vulnerability in this 13 regard." (bold added.) 14 13. The DEIR and the FEIR prepared by the CITY for the Landfill Closure Plan did not disclose or 15 identify the additional fire hazards and fire risks (and associated public safety risks to firefighters and 16 nearby residents) associated with the selection of the proposed synthetic landfill cover, did not compare 17 these fire hazards and fires risks with those associated with selection of a clay/earthen cover, and did not 18 identify or evaluate alternatives or mitigation measures to reduce such fire hazards and fire risks. The 19 DEIR and FEIR did not disclose and discuss that firefighters would need to wear full hazardous material 20 gear and use breathing apparatuses if the synthetic cover ignites in a wildfire, and the DEIR and FEIR 21 did not identify or discuss the financial liability the CITY and Ukiah taxpayers may face in the event of 22 personal injury claims by nearby residents should the synthetic cover ignite in a wildfire. Instead, in the 23 FEIR(in the final paragraph of its Response to Comment B-1), the CITY conceded the fire hazards and 24 fire risks associated with its proposed synthetic landfill cover and stated as follows: "The City also 25 shares concerns about catastrophic wildfires and its potential to adversely impact the landfill cover. As 26 such and as standard City practice, the City has addressed the maintenance and replacement values in 27 the Final Closure and Post-Closure Maintenance Plan ("FCPMP") and will take out an adequate 28 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3756 of 4 165 I insurance policy(s)to cover the costs of replacement in the event of a catastrophic such as a fire." The 2 procurement of an insurance policy to cover the costs of"replacing" the synthetic cover in the event of a 3 wildfire is not a substitute for CEQA's obligation to evaluate and avoid such additional fire hazards and 4 fire risks. More specifically and more importantly, the CITY's promise to procure such an insurance 5 policy does not provide the Ukiah City Council and the public with a comparison of the respective fire 6 hazards/fires risks associated with the proposed synthetic landfill cover vis-a-vis a clay/earthen landfill 7 cover, and does not provide the Ukiah City Council and the public with an evaluation of feasible 8 alternatives and feasible mitigation measures to avoid or reduce the fire hazards and fire risks associated 9 the proposed synthetic landfill material. The omission of such information and analysis constitutes a 10 material violation of CEQA. 11 12 Second CEQA Claim —Failure to Analyze Microplastic Releases into Waterways 13 14. The synthetic landfill cover that the CITY proposes to use in its Landfill Closure Plan is 14 manufactured by ClosureTurf The statutory duration of the postclosure maintenance period is a 15 minimum of 30 years. (See 27 CCR §§ 21180, 21190.) In the ClosureTurf product information included 16 in the FEIR, on the page titled "Weathering", ClosureTurf explains after a 30-year period"[t]he tensile 17 strength of the engineered turf fibers is projected to have 75%retention." This claim also means that, 18 according to ClosureTurf, by the end of a 30-year period the tensile strength of the engineered turf fibers 19 is anticipated to lose 25% of their retention. This substantial and increasing loss of structural integrity 20 means that the synthetic fibers on the surface of the ClosureTurf cover(the strands of plastic designed to 21 resemble strands of natural grass)will disintegrate and detach over time. The decrease in tensile strength 22 will likely increase beyond this amount as the synthetic cover ages and is exposed to ultra violet light, 23 rainfall, and wind. (See, e.g., The effects of natural and artificial UV exposure on the physical properties 24 of synthetic turf used for various sports fields, available at: 25 https://core.ac.gk/download/ IF54 85067.pff.) The disintegration and detachment of these plastic 26 strands on the ClosureTurf synthetic landfill cover will result in such plastic strands (or the disintegrated 27 28 8 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3757 of 4 165 I microplastic materials in such strands)being washed downhill by rains into nearby streams and creeks, 2 where they will then make their way into the Russian River and eventually the ocean. 3 15. Attached as Exhibit 3 to these written comments is a May 2019 paper published by Stockholm 4 University's Department of Physical Geography titled Tracking Microplastics f°om Artificial Football 5 Fields to stormwater Systems (2019 Stockholm University Paper). The 2019 Stockholm University 6 Paper reports that a recent study found that artificial turfs are the second largest sources of microplastics 7 released into waterways and oceans and that"Microplastics from artificial turfs are discharged to 8 stormwater during precipitation events which can be then recognized as a pathway of transporting 9 microplastics to the marine environment." The 2019 Stockholm University Report further found that: 10 "Microplastics in the marine environment can be ingested passively or actively by a wide range of 11 organisms from small invertebrates to large mammals. —Ingestion of microplastics affects life activities 12 such as feeding, digestion and reproduction, and even leads to mortality directly by entanglement and 13 choking, especially in fish in larval stage." In terms of artificial turf coverings, such as the synthetic 14 landfill cover proposed by the CITY as part of the Landfill Closure Plan, the 2019 Stockholm University 15 Report explained: "At the selected field sites, runoff due to rainfall is a main pathway transporting 16 microplastics to stormwater wells during the summer and autumn, while in the spring 17 microplastic accumulated in cleared snow can be transported by meltwater." The 2019 Stockholm 18 University Report therefore documents data and research showing that, as they degrade and breakdown, 19 artificial synthetic turf coverings such as the one proposed in the Landfill Closure Plan tend to release 20 microplastics when subject to rainfall. Presumably, on a sloped environment such as where the former 21 Ukiah landfill is located this would cause the microplastics to wash into the streams and creeks downhill 22 from the landfill site. 23 16. The DEIR and the FEIR prepared by the CITY did not contain analysis of what happens to the 24 synthetic plastic strands in the ClosureTurf landfill cover when they begin to degrade and lose structural 25 integrity (a 25%loss of retention after 30 years according to ClosureTurf s own analysis). The DEIR 26 and FEIR prepared by the CITY did not contain analysis of how, as a result of this anticipated 27 degradation, microplastics are likely to be released and (propelled by rains and runoff)washed into the 28 9 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3758 of 4 165 I streams and creeks located downhill of the landfill site, and from these creeks and streams into the 2 Russian River and the ocean. The DEIR and the FEIR did not contain analysis of the financial liability 3 of the CITY and Ukiah taxpayers for polluting waterways with microplastics, such as civil penalties, 4 remediation costs and natural resource damages under environmental laws such as the federal Clean 5 Water Act and California's Porter-Cologne Water Quality Act. The failure of the DEIR and FEIR to 6 identify and analyze the environmental risks presented by the release of such microplastics into nearby 7 waterways constitutes a material failure under CEQA to assess hydrologic resource/water quality 8 impacts and well as a material failure to assess impacts on biological resources (fisheries). 9 10 Third CEQA Claim —Failure of Evaluate Reasonable Range of Alternatives 11 17. As set forth in detail in VICHY SPRINGS RESORT's written submission dated January 9, 12 2020, CEQA requires that an EIR consider a reasonable range of alternatives to avoid or reduce the 13 environmental impacts of a proposed project. This decision of whether to provide full evaluation of the 14 environmental impacts for alternatives to a proposed action is not a discretionary decision left to the lead 15 agency preparing the EIR, it is a black letter law requirement of CEQA. The failure to provide full 16 evaluation of alternatives to the proposed action is unlawful under CEQA. 17 18. In the case of the current FEIR for the Landfill Closure Plan, the CITY only provided full 18 evaluation of one alternative—the proposed action (which included the use of a synthetic landfill cover, 19 and which omitted any mitigation measures to reduce construction-related noise impacts). The CITY's 20 FEIR mentioned the "no project" alternative of simply not doing a Landfill Closure Plan at all, but then 21 acknowledged that the"no project" alternative was not in fact an alternative at all because the California 22 Health and Safety Code requires the adoption and implementation of a closure plan for all landfills. 23 19. In the DEIR for the Landfill Closure Plan that was prepared before the current FEIR, the CITY 24 had made a finding that the use of the more permanent clay/earthen landfill cover alternative was not 25 "feasible" and based on this "infeasibility" finding eliminated the clay/earthen cover option from more 26 detailed evaluation. Only after receiving written comments on the DEIR highlighting the use of 27 clay/earthen landfill covers is standard practice throughout the State of California, and highlighting that 28 10 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3759 of 4 165 I the additional incremental costs of using the clay/earthen landfill cover (as provided by the CITY and 2 accepted as correct) would be minimal in the overall budget of the project, the subsequent FEIR 3 prepared by the CITY removed the earlier"infeasibility" finding in the DEIR regarding the clay/earthen 4 cover. Sidestepping the question of whether the clay/earthen cover was a"feasible" alternative, Chapter 5 4 of the FEIR then went on to include a cursory new analysis discussing why there might be certain 6 advantages (such as reduced upfront installation costs and possible reduced slippage)with the synthetic 7 cover option versus the clay/earthen cover option, and based on these few additional sentences in 8 Chapter 4 then, again and just as with the DEIR, eliminated the clay/earthen cover from further 9 evaluation. That is, the clay/earthen cover alternative was not then independently analyzed in subsequent 10 sections of the FEIR—for reduced fire hazards/risks associated as compared with the proposed synthetic 11 landfill cover, for avoiding the risk of the release of microplastics into waterways with the proposed 12 synthetic landfill cover, for reduced adverse visual/aesthetic impacts as compared with the mono-color 13 synthetic landfill cover, for reduced risks of damage by wild boar populations as compared with the 14 proposed synthetic landfill cover. The FEIR did not therefore provide further substantive analysis of 15 these important environmental advantages of the use of clay-earthen cover, it just provided a few 16 additional sentences in Chapter 4 to explain why it was not going to provide any further analysis of this 17 alternative, of why this alternative was being eliminated from further analysis. 18 20. The FEIR's added discussion of an earthen/clay final cover alternative does not cure the DEIR's 19 complete failure to include a discussion of this alternative in the alternatives analysis (Chapter 4 of the 20 DEIR). By omitting the required discussion and information concerning this feasible alternative the 21 City deprived the public and responsible agencies of the ability to meaningfully comment on the 22 comparative environmental impacts such an alternative would cause in relation to the proposed project 23 design. 24 21. In particular, in terms of whether the clay/earthen landfill cover is a feasible alternative to 25 the proposed synthetic landfill cover, it should be noted that the CITY had previously proposed using 26 a clay/earthen landfill cover as part of its Landfill Closure Plan for the Ukiah landfill and that the use of 27 such a clay/earthen landfill cover had previously been approved by both the North Bay Regional Water 28 11 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3760 of 4 165 I Quality Control Board (Regional Board) and CalRecycle—two state agencies with extensive experience 2 with landfill sites and closures. (see WDR Order R1-2002-0061, incorporated herein by this reference) It 3 is only more recently that the CITY has indicated its changed preference to select a synthetic landfill 4 cover instead of the previously approved clay/earthen landfill cover. The fact that the Regional Board 5 and CalRecycle had previously approved the use of a clay/earthen landfill cover for the Ukiah landfill is 6 inconsistent with the CITY's current claims (in the DEIR and the FEIR)that the use of a clay/earthen 7 landfill cover would somehow present a dangerous and unacceptable risk of slippage due to the slope of 8 the site. If such slippage concerns had been present, the Regional Board and Cal Recycle would not have 9 previously approved the use of such a clay/earthen landfill cover as a permanent closure remedy for the 10 Ukiah landfill. Additionally, since the Ukiah landfill stopped receiving waste 20 years ago and placed a 11 preliminary clay/earthen cover over the landfill, it should be noted that there have not been problems 12 with slippage of this cover. This 20 years of actual experience on the site of the former Ukiah landfill, 13 with a clay/earthen cover that in fact did not experience slippage problems, contradicts the current 14 claims by the CITY that the option of clay/earthen cover should be limited from further consideration as 15 an alternative in the DEIR and FEIR because this option presents an unacceptably high risk of slippage. 16 The 20 years of actual experience at this site, with a clay/earthen cover that did not suffer slippage, is 17 something that the DEIR and the FEIR fail to disclose. 18 22. In terms of construction-related noise impacts on nearby outdoor recreation areas, the DEIR did 19 not give full consideration to any alternatives to the proposed action—which involves weekday 20 construction activities from 7:00 am to 7:00 pm (essentially during all the weekday daylight hours when 21 outdoor recreation would take place), includes no seasonal restrictions to restrict construction activities 22 at times of the year when outdoor recreational usage is at its highest, and includes no measures to reduce 23 vehicular and equipment noises. Such construction-related noises include the relentless pounding thud o 24 the soil compaction machines (which pursuant to the Landfill Closure Plan will need to compress 25 material under the synthetic cover across the entire 40-square acres of the site) and the continuous 26 piercing sound of the backup beepers used on all trucks and motor vehicles on site. In regard to 27 alternatives to the use of backup beepers on motor vehicles, Regulation 1926.601(b)(4)issued by the 28 12 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3761 of 4 1 165 I federal Occupational Health and Safety Administration (OSHA)provides: "No employer shall use a 2 motor vehicle having an obstructed view to the rear unless: (i) The vehicle has a reverse signal alarm 3 audible above the surrounding noise level or (ii) The vehicle is backed up only when an observer 4 signals that it is safe to do so." (bold added.) OSHA guidelines therefore explicitly provide that the use 5 of an observer is a feasible alternative to backup beepers for motor vehicles used at construction sites. 6 Instead of considering any alternatives to avoid or reduce construction-related noise impacts on outdoor 7 recreation, the CITY's FEIR simply declares (without any data or support or analysis)that construction- 8 related noise associated with the proposed action will not affect the "quiet and enjoyment" of hikers on 9 the trails at VICHY SPRINGS RESORT or other outdoor recreation users in the vicinity of the project. 10 No information was provided in the FEIR to suggest that the alternatives available to reduce 11 construction-related noise were infeasible. The FEIR(and the DEIR)just omitted evaluation of any 12 alternatives to reduce construction-related noise impacts. 13 23. In terms of compliance with CEQA, VICHY SPRINGS RESORT, RUSSIAN 14 RIVERKEEPER and MATEEL ENVIRONMENTAL recognize that CEQA vests some discretion with 15 lead agencies to develop a reasonable range of alternatives in an EIR that would reduce some of the 16 anticipated adverse environmental impacts of a proposed project. In the case of the proposed Landfill 17 Closure Plan, the administrative record is clear that the action proposed by the CITY will have fire 18 hazard and fire risks, adverse water quality impacts associated with microplastic releases, adverse scenic 19 impacts (by converting a hillside of natural grasses to one of a mono-color synthetic cover), and adverse 20 noise impacts on outdoor recreation resources. While CEQA provides the CITY with some discretion to 21 develop a reasonable range of alternatives to address these environmental concerns, CEQA does not 22 provide the CITY with discretion to simply forgo the comprehensive analysis of alternatives altogether 23 and only provide full evaluation of the proposed action. Simply put, full evaluation of only one 24 alternative does not satisfy CEQA's requirement that a reasonable range of alternatives be evaluated, 25 and the CITY's failure to comply with this requirement undercuts the very heart of the CEQA process — 26 to provide decision-makers (the members of the Ukiah City Council) and the public with a meaningful 27 comparison of feasible alternatives to be able to meaningfully weigh the competing environmental 28 13 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3762 of 4 165 I impacts associated with different feasible alternatives. The CITY's consideration of only one alternative 2 in the FEIR for the Landfill Closure Plan is therefore not an exercise of lawful discretion. CEQA simply 3 does not allow it. 4 5 Fourth CEQA Claim —Failure to Provide an Accurate and Complete Proiect Description 6 24. CEQA requires that an EIR provide an accurate and complete description of all the component o 7 the proposed project being evaluated. CEQA similarly prohibits the"piecemealing" and "segmentation" 8 of a larger comprehensive project into smaller discrete "projects" (in terms of the project description)to 9 avoid having to acknowledge and evaluate the larger comprehensive project and thereby fail to disclose 10 the true costs and true environmental impacts associated with the larger project. 11 25. In the EIR, the CITY proposes the use of an interim synthetic plastic landfill cover for the 30- 12 year period of the Landfill Closure Plan. (See, e.g., DEIR, Appendix A, Final Closure and Postclosure 13 Maintenance Plan, p. 1-1, 4-1.)Neither the DEIR nor the FEIR address what will become of the 14 synthetic turf cover beyond 30 years. Because the plastic cover will inevitably disintegrate over time due 15 to multiple weathering forces (including UV light, rain, and wind), at some undetermined point 16 following this 30-year period, according to discussions with staff at the Regional Board, the interim 17 synthetic cover would then likely need to be removed and replaced with another more permanent landfill 18 cover. Although it is likely that the interim synthetic landfill cover will need to be removed, disposed 19 above and replaced with a permanent cover, the DEIR and the FEIR do not include such landfill cover 20 removal, disposal and replacement components as part of the project description. By omitting such 21 landfill cover removal, disposal and replacement components as part of the project description in the 22 DEIR and FEIR, the DEIR and FEIR as a result did not contain an estimate of the costs associated with 23 such removal, disposal and replacement components nor did they contain any analysis of the 24 environmental impacts associated with such removal, disposal and replacement components. This is a 25 classic example of what is referred to as "piecemealing" under CEQA, of unlawfully using an 26 improperly narrow project description to avoid having to acknowledge and evaluate the full 27 environmental impacts of a broader-integrated project. In the case of the Ukiah landfill, the strong 28 14 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3763 of 4 165 I likelihood of eventual removal and disposal of the interim synthetic cover (and the replacement of the 2 interim synthetic cover with a permanent cover) are not some remote speculative possibility —they are a 3 foreseeable and likely component of the overall closure process. The CITY's failure to include these 4 components in the project description is therefore a violation of CEQA's piecemealing prohibition. 5 Every aspect of the environmental impact analysis is compromised by this failure to consider the long- 6 term removal, disposal and replacement of the interim synthetic cover. 7 26. As explained further below, as part of the Landfill Closure Plan, the CITY will be required 8 by the Regional Board to provide additional "financial assurances" if the CITY selects the synthetic 9 landfill cover option, due to concerns by the Regional Board regarding fire-related risks associated with 10 the synthetic landfill cover as well as concerns the Regional Board has about the interim synthetic 11 landfill cover being subject to degradation and breakdown from ultra-violet exposure, heat and other 12 weather elements. As the Regional Board stated in its January 9, 2020 comment letter on the DEIR: 13 "Given the State of California's recent catastrophic experiences with wildland fires which resulted in 14 significant infrastructure loss and damage, the Proposed Project's synthetic turf design has an inherent 15 surface-based vulnerability in this regard. Also, the surface-based turf system and underlying synthetic 16 geomembrane liner have a greater exposure to ultraviolet light,weather/temperature impacts and 17 potential degradation and cracking over the buried type of liner systems...For these reasons we have 18 requested the financial assurance mechanism to address the possible replacement scenario in the 19 event the surface-based liner system fails. The Proposed Project description should adequately 20 reflect this." (bold added.) As also further explained below, the CITY has conceded that(due to the 21 enhanced fire hazards and fire-risks associated with the proposed synthetic landfill cover)it will be 22 necessary to maintain fire-related insurance throughout the minimum 30-year duration that the interim 23 synthetic cover will be in place. The DEIR and FEIR failed to include any information about the 24 additional financial assurances and fire-related insurance policies as part of the project components and 25 project description, and as such failed to provide any information about the what these financial 26 assurances and fire-related insurance policies will cover. For instance, in terms of fire risks and fire 27 hazards associated with the synthetic plastic landfill cover, are the amounts included in such additional 28 is VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3764 of 4 165 I financial assurances available to cover these fire-related risks? For instance, in terms of the enhanced 2 risks of degradation and liner failure with the proposed synthetic landfill cover, are the amounts in such 3 additional financial assurance adequate to cover the costs of the anticipated damages that would result if 4 the synthetic cover failed? For instance, will the fire-related insurance policy provide coverage for 5 personal injuries to firefighters or nearby residents if the 40-acre synthetic landfill cover catches fire, or 6 will such insurance policies only apply to the costs of"replacing" the synthetic cover after such a fire? 7 In terms of public safety concerns and impacts, the answers to these questions are critical. Yet, because 8 these items were excluded from the project description for the DEIR and FEIR prepared for the Landfill 9 Closure Plan, these items were not analyzed in the DEIR and FEIR, in terms of either costs or 10 environmental impacts. 11 27. Pursuant to CEQA Guideline 15124(d)(1), the project description in an EIR must include a list o 12 all other agencies and agency approvals that it is anticipated will reply on CEQA compliance by the lead 13 agency. In the case of the Landfill Closure Plan for the Ukiah landfill, the CITY is the lead CEQA 14 agency Although the CITY is aware that there will be other agency approvals required for the Landfill 15 Closure Plan to proceed, including but not limited to approval by the Mendocino County Environmental 16 Health Department(the lead enforcement agency/LEA under the California Health and Safety Code), 17 CalRecycle and the North Coast Regional Water Quality Control Board, and that these other agencies 18 will need to rely on the CITY's preparation of a legally-adequate CEQA EIR, the DEIR and the FEIR 19 failed to disclose that the Mendocino County Environmental Health Department, CalRecycle and North 20 Coast Regional Water Quality Control Board would be relying on the EIR prepared by the CITY to 21 satisfy their own CEQA compliance obligations. The failure of the CITY to include the information 22 required pursuant to CEQA Guideline 15124(d)(1)in the DEIR and FEIR constitutes a material failure 23 to provide an adequate and accurate project description. 24 28. Without an accurate and complete project description, an EIR cannot provide decision- 25 makers and the public with a true accounting of the anticipated costs associated with a proposed action, 26 and will be unable to provide decision-makers (Ukiah City Council) and the public with a proper 27 analysis of the environmental impacts and concerns associated with a proposed action. The DEIR and 28 16 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3765 of 4 165 I FEIR prepared for the Landfill Closure Plan fail to include the likely removal, disposal and replacement 2 of the interim landfill cover as part of the project description, fail to include additional financial 3 assurances (to be required by the Regional Board) and the procurements of fire-related insurance 4 policies, and fail (as expressly required by CEQA Guideline 15124(d)(1))to identify the other agency 5 approvals that would rely upon the EIR as part of the project description. In this regard, the DEIR and 6 FEIR prepared by the CITY for the Landfill Closure Plan fail to satisfy this core and basic requirement 7 of CEQA. 8 9 Fifth CEQA Claim —Failure to Provide Accurate Description of Baseline Conditions 10 29. As set forth in detail in VICHY SPRINGS RESORT's written submission dated January 9, 11 2020, for each environmental impact evaluated in an EIR, CEQA requires that an accurate and complete 12 description of"baseline conditions" (sometime also referred to as the "existing environmental setting") 13 is provided. The presentation of an accurate and complete description of baseline conditions is required 14 because of the components and basic sequencing involved in environmental impact assessment, which 15 are as follows: (1)presentation of accurate and complete project description; (2) description of baseline 16 conditions/existing environmental setting for each of the resources/impacts evaluated in the EIR; (3) 17 quantification and analysis of anticipated impacts of the proposed project for each of the resources 18 evaluated in the EIR and comparison of these impacts against the baseline conditions/existing 19 environmental setting for these resources; (4)for each of the resources evaluated in the EIR, a 20 determination as to whether the anticipated effects of the project can be considered"insignificant" based 21 on reference to well-articulated significance criteria/thresholds; and (5) consideration and evaluation of 22 reasonable range of alternatives and feasible mitigation measures to avoid or reduce the adverse 23 environmental impacts of the proposed project. Without an accurate description of baseline conditions 24 (step 2 in CEQA's environmental impact analysis) as a starting point, it is impossible to properly 25 complete steps 3, 4 and 5 in CEQA's environmental impact assessment process. 26 30. In terms of fire risks and fire hazards, the "baseline conditions/existing environmental 27 setting" are the wildfire threat conditions on and in the vicinity of the landfill property at the time the 28 17 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3766 of 4 1 165 I EIR is being prepared (current wildfire threat conditions now). Appendix G of CEQA now contains 2 special provisions expressly requiring the analysis of wildfire related conditions and risks. These 3 baseline wildfire threat conditions are pertinent to an evaluation of the Landfill Closure Plan because (as 4 explained above) the synthetic landfill cover that the CITY has proposed is particularly flammable, and 5 because the materials that comprise this synthetic landfill cover will result in the release of toxic air 6 fumes and the release of toxic liquified material in the event they catch fire, which presents public health 7 risks to firefighters and nearby residents. As noted above, numerous wildfires have occurred in recent 8 years in the vicinity of the former Ukiah landfill and the area around Ukiah has been designated a high 9 fire hazard zone by the California Department of Fire (see Exhibit 1 to these comments). As also noted 10 above, in the opinion letter by Pangea Environmental Services attached as Exhibit 2 to these written 11 comments, the materials used in the proposed landfill cover are highly flammable and are likely to 12 produce dangerous toxic releases if ignited. By failing to describe baseline wildfire threat conditions on 13 and in the vicinity of the landfill site, the EIR then failed to conduct any analysis of the public health 14 risks and environmental risks that would result if the proposed synthetic landfill cover caught fire. 15 31. In terms of scenic/aesthetic/visual impacts and resources related to the Landfill Closure 16 Project, the "baseline conditions/existing environmental setting" is the scenic condition of the landfill 17 property at the time the EIR is being prepared (current scenic conditions now). As set forth in detail in 18 VICHY SPRINGS RESORT's written submission dated January 10, 2020, the Ukiah landfill stopped 19 accepting waste deliveries in 2002, nearly 20 years ago, and at that time a layer of clay and earthen fill 20 was placed over the open landfill until such time as a formal Landfill Closure Plan was developed and 21 implemented. In the nearly 20 years since the Ukiah landfill has been inactive, and the layers of clay 22 earthen fill were placed over the landfill, natural grasses and vegetation have returned and grown on the 23 site such that(currently) there is no clear visual indication that there was ever an open landfill at the site. 24 The natural grasses that have grown over the Ukiah landfill are the same as the grasses on the 25 surrounding hillsides, and these natural grasses change with the seasons (dry/brown in late spring, 26 summer and early fall; lush/green in the late fall, winter and early spring; and all the subtle transitions in 27 between). 28 18 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3767 of 4 165 1 32. In the DEIR, and then again in the FEIR, the CITY did not provide photographs or clear 2 accurate narrative information that clearly represented and indicated that that baseline scenic conditions 3 of the Ukiah landfill site are of natural grasses that blend in seamlessly with the surrounding grass- 4 covered hillside and that change color and texture throughout the seasons of the years. Instead, in the 5 DEIR, and the FEIR, the CITY omitted providing an accurate description of baseline scenic conditions, 6 and instead tried to bypass this critical environmental impact assessment step (Step 2) and go directly to 7 the reasons why the CITY thought that the 40-square acre mono-color plastic synthetic landfill cover 8 would not look that bad. But that is not how CEQA requires that environmental impact assessment be 9 done. Putting aside for the moment the credibility of its claims about how visually attractive the 10 "contrast" between the mono-color synthetic cover and natural grass hillsides will be (discussed more 11 below), under CEQA, an EIR does not just look at the conditions that will exist after the project is done 12 and ask whether these conditions are "that bad." Rather, CEQA requires that an EIR compare the 13 conditions that will exist after the project is completed to the baseline conditions that exist prior to 14 undertaking the project. It is this comparison, of baseline conditions with post-project conditions, that is 15 critical to how CEQA works. And when it comes to scenic/aesthetic impacts, this comparison is absent 16 from the both the DEIR and the FEIR because the DEIR and the FEIR failed to provide an accurate 17 description of current baseline scenic conditions— of the natural grasses that now currently cover the 18 Ukiah landfill site. 19 33. In fact, there is information in the April 2020 FEIR(and the response to comments included 20 in the FEIR)that is fundamentally misleading to decision-makers (Ukiah City Council) and the public in 21 terms of current baseline scenic conditions. In the FEIR, in its Response to Comment 5d, the CITY 22 states: "The existing landfill already is distinct from the existing natural landscape as it is a landfill with 23 waste underneath the existing vegetation and there are no trees on top of the landfill. As a result, the 40- 24 acre area of the closed landfill will always be in contrast to the surrounding natural environment(with 25 sparse or dense stands of trees) even with a clay/natural cover." As the photographs submitted by 26 VICHY SPRINGS RESORT make plain to any viewer, however, there are many hillsides nearby and 27 that surround the 40-square acre patch where the landfill is located that contain either no trees at all or 28 19 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3768 of 4 165 I few trees, and are therefore fairly barren As the photographs submitted by VICHY SPRINGS RESORT 2 also make plain to any viewer, because there are many relatively barren hills nearby with few trees in 3 the vicinity, the area of natural grasses where the Ukiah landfill was located is virtually indistinguishable 4 from many of the surrounding hillsides. In fact, the only way for VICHY SPRINGS RESORT to clearly 5 identify the former Ukiah landfill site in these photographs was to circle the site with blue marker— 6 because without the blue marker the location of the former Ukiah landfill simply looks like many of the 7 natural grass hillsides that surround it. The narrative response provided by the CITY in the FEIR in its 8 Response to Comment 5g— suggesting the former landfill site was somehow situated in a forest or an 9 area where all the surrounding hills were dense with trees—is profoundly inaccurate and misleading. 10 This misrepresentation of current baseline scenic conditions is evident to any person that looks at the 11 photographs submitted by VICHY SPRINGS RESORT. 12 34. In the FEIR, the CITY baldly claims "The Ukiah landfill is, has been, and will always be a 13 landfill site and is not, nor will ever be considered to be a scenic resource." VICHY SPRINGS 14 RESORT, RUSSIAN RIVERKEEPER and MATEEL ENVIRONMENTAL fundamentally disagree 15 with this claim, as any highly visibly part of the landscape and hills around Ukiah is in fact a scenic 16 resource, is in fact an important viewshed—regardless of whether portions of this vista were at one point 17 in time in the past may have been used as a landfill site. The falsity of the CITY's claim here is revealed 18 through the color photographs included as part of VICHY SPRINGS RESORT's January 9, 2020 19 written submission, which clearly show that(whether the CITY likes it or not)the landfill site is in fact 20 an undeniable part of the scenery and landscape of the hillsides in the vicinity, and that(in its 21 present/current condition covered with natural grass)the former Ukiah landfill site is in fact now an 22 integral scenic component of this beautiful natural landscape. What is particularly telling about the 23 CITY's claim (quoted above from the FEIR)is that it reveals the FEIR's strangely narrow view of the 24 former Ukiah landfill site—that it should somehow not be considered a scenic resource at all and that 25 therefore there cannot conceivably be any possible adverse scenic impacts resulting from what cover is 26 selected for the former landfill. This narrow view, contradicted by any person that views photographs of 27 the landfill site or that visits the actual site and surrounding areas, perhaps explains why the DEIR and 28 20 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3769 of 4 165 I the FEIR are so unwilling to acknowledge that there could possibly be any scenic/visual resources 2 involved or that there could possibly be any adverse scenic impacts associated with the cover selected 3 for landfill closure. 4 35. In terms of the functionality and viability of the proposed synthetic plastic landfill cover, the 5 FEIR and DEIR failed to provide accurate information about the prevalence of wild boars in the area 6 where the landfill is located. Such wild boars are likely to trample on and burrow and dig (root)into the 7 synthetic landfill cover thereby compromising its integrity. This concern was specifically raised in the 8 comment letter submitted by Gilbert Ashoff, owner of VICHY SPRINGS RESORT, on the DEIR 9 prepared for the Landfill Closure Plan. More specifically, in 2018, the CITY hired a trapper name Kyle 10 Seever to install a series of"pig traps" on the landfill property over a 3-month period to catch wild boars 11 as well as video-cameras to monitor wildlife on the site. During this 3-month period, approximately 20 12 wild boars were caught in "pig traps" on the landfill property and the video-cameras filmed wild boars 13 regularly roaming the landfill property. Kyle Seever's work in 2018 trapping wild boars was overseen 14 by Dan Hunt, who worked for the CITY at the landfill. All of the information regarding Kyle Seever's 15 activities is in the CITY's files and therefore are part of the administrative record in this case. 16 Additionally, there are professional hunting outfits in the area that routinely organize hunts for wild 17 boars. For example, Lockwood Hunting Services in Ukiah has a wild boar as its official company logo 18 (see Exhibit 4 to these written comments) and its website states "We specialize in guided hunts for wild 19 pigs on thousands of acres on private land in California's Mendocino County near Hopland, CA." (bold 20 added.)Moreover, it is well-known that many landowners in the area (including VICHY SPRINGS 21 RESORT) often maintain their own "pig traps" to capture the wild boars that roam throughout the 22 surrounding hills. For years, VICHY SPRINGS RESORT has had to deal with the problem of wild 23 boars on its property. 24 36. There is also well documented scientific literature indicating that wild boars routinely 25 engage in"rooting" behavior—that is they dig up and overturn ground covering (whatever that ground 26 covering might be). The "rooting" behavior of wild boars, which is separate and distinct from their 27 tendency to forage for food, is discussed in the 2015 Wild Pigs Report by the United States Department 28 21 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3770 of 4 165 I of Agriculture and the Feral,Swine Damages report prepared by the University of California(attached 2 respectively as Exhibit 5 and Exhibit 6 to these written comments). In the opinion letter from Pangea 3 Environmental Services attached as Exhibit 2 to these written comments, information is provided about 4 how"abrasion" activities (such as rooting by wild boars)result in the release of PFAS (perfluoroalkyl 5 and polyfluoroalkyl substances)that are part of synthetic artificial turf coverings like the ClosureTurf 6 landfill cover proposed by the CITY. Pangea Environmental Services' opinion letter notes how the 7 abrasion of the landfill cover by wild boar rooting is likely to cause the release of PFAS into nearby 8 streams and creeks, and notes that the presence of PFAS in waterways is now regulated under several 9 environmental laws and by many environmental agencies. As part of its description of baseline 10 conditions in the DEIR and FEIR for the Landfill Closure Plan, the CITY failed to present an accurate 11 description and evaluation of wild boar populations that have been found on and in the vicinity of the 12 Ukiah landfill and their well-documented "rooting" behavior, and based on this omission failed to 13 properly analyze the potential risks such wild boar populations present to the integrity of the proposed 14 synthetic landfill cover and the likelihood that wild boar rooting will result in the release of PFAS into 15 nearby streams and creeks and from there into the Russian River. In its response to comments on the 16 FEIR, the CITY stated that there had not been any "reported sightings" of wild boars on the former 17 landfill but this statement is in direct contraction to what is common knowledge throughout the area 18 (that wild boars roam the hills where the landfill is located) and is in direct contraction to the fact that 19 the CITY itself hired a trapper that caught many wild boars on the landfill property and that took video- 20 footage of wild boars on the landfill property. In light of the wild boars that Kyle Seever's caught on the 21 landfill property in 2018 (both in pig traps and on video-footage), work that was done on behalf of the 22 CITY and reported to the CITY two years ago, the FEIR's claims of no"reported sightings" of wild 23 boars is misleading in the extreme. The failure of the DEIR and FEIR to disclose and describe and 24 evaluate the presence of wild boars on the landfill site and in the landfill project area, and the risks such 25 wild boars present to the integrity of the propose synthetic landfill cover, is inconsistent with the 26 baseline condition requirements of CEQA. 27 37. In terms of historic resources, the CITY is aware that VICHY SPRINGS RESORT has been 28 22 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3771 of 4 165 I designated a California Historic Landmark. Information about this landmark designation has been 2 previously provided to the CITY, and is attached to these comments as Exhibit 7. The landmark 3 designation applies not only the buildings and mineral springs at VICHY SPRINGS RESORT but also 4 applies to outdoor grounds and, importantly, the "uses" as a resort for more than 150 years. More 5 specifically, the landmark designation for VICHY SPRINGS RESORT specifically identifies "outdoor 6 recreation" as a recognized "historic function" of the property, meaning that adverse impacts on such 7 "outdoor recreation" (such as adverse scenic and noise impacts associated with the Landfill Closure 8 Plan) can impair this "historic function." In Section 3.4 of the DEIR and FEIR on cultural resource the 9 CITY claims that it conducted a search of California State Historic State Landmarks and determined that 10 there were no such sites within a '/4 mile of Landfill Closure Plan project boundaries. This determination 11 is factually incorrect. The property boundary for VICHY SPRINGS RESORT is across the road from 12 the entrance to the landfill (a few hundred feet away), and the outdoor recreation grounds on the VICHY 13 SPRINGS RESORT property covered by the landmark designation are also well within '/4 mile of the 14 entrance to the landfill. The entrance to the landfill is within the Landfill Closure Plan project boundary. 15 As a result of this incorrect determination of baseline conditions in regard to historic and cultural 16 resources, the DEIR and FEIR failed to conduct any analysis of the impacts —including but not limited 17 to noise and scenic impacts—of the Landfill Closure Plan on the uses and features covered by the 18 landmark designation for VICHY SPRINGS RESORT. In failing to conduct a historical resource 19 impacts analysis related to the effects of the project on uses and functions protected by VICHY 20 SPRINGS RESORT's landmark designation, the CITY also violated provisions of the CITY's General 21 Plan concerning the protection of Historic and Archaeological ("HA")Resources. More specifically, in 22 failing conduct a historical resource impacts analysis in the DEIR and FEIR related to the effects of the 23 Landfill Closure Plan on uses and functions protected by VICHY SPRINGS RESORT's landmark 24 designation, the CITY violated Policies HA-2.2., HA-4.1 and HA-7.1 of the CITY's General Plan which 25 require that CITY land-use decisions avoid adverse environmental impacts on historic resources such as 26 those designated and protected by VICHY SPRINGS RESORT's landmark designation. 27 38. In terms of outdoor recreational resources (hiking trails)located on the VICHY SPRINGS 28 23 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3772 of 4 165 I RESORT property and the construction-related noise impacts of the Landfill Closure Project on such 2 outdoor recreational resources, the "baseline conditions/existing environmental setting" are the current 3 background ambient noise levels for these outdoor recreational resources/hiking trails at the time the 4 EIR is being prepared (current noise conditions now). There are no county noise ordinances that pertain 5 specially to impacts on outdoor recreation areas and hiking trails. Under basic CEQA environmental 6 impact assessment methodology, the EIR for the Landfill Closure Plan would then need to compare 7 these baseline/existing noise levels to the expected construction-related noise levels to determine 8 whether such increases in noise will have a significant adverse impact on the experience of"quiet and 9 enjoyment" now available to hikers/outdoor recreation users on these trails. For instance, under current 10 baseline conditions, people using nearby outdoor recreation trails are not subjected to the continuous 11 thud of compression equipment or the regular piercing sound of motor vehicle backup beepers. In the 12 DEIR and then again in the FEIR, however, the CITY never provided information on current/baseline 13 ambient noise levels on the hiking trails on the VICHY SPRINGS PROPERTY. VICHY SPRINGS 14 RESORT most certainly would have, and again here offers, to provide access to the CITY and/or the 15 CITY's consultants to undertake such baseline ambient noise level testing. In its Response to Comments 16 in the FEIR, the CITY states conclusively that the construction-related noise generated by the Landfill 17 Closure Plan would not represent an significant increase over ambient/baseline noise levels on such 18 outdoor recreational area/trails, but since there is no indication that the CITY ever determined such 19 ambient/baseline noise levels this statement lacks any evidentiary support. Without such testing and 20 baseline information, there is no basis to quantify the increase in noise levels on such outdoor hiking 21 trails that will result from construction-related noise associated with the Landfill Closure Plan, and 22 therefore no basis for the CITY's FEIR to find that the construction-related noise impacts on such 23 outdoor recreational resources are less-than-significant. Once again, as explained above, without an 24 accurate description of baseline conditions (step 2 in CEQA's environmental impact analysis) as a 25 starting point, it is impossible to complete steps 3, 4 and 5 in CEQA's environmental impact analysis. 26 The CITY's failure to acknowledge and properly analyze the construction-related noise impacts on 27 outdoor recreation areas, in turn, led to a cascade of further and subsequent CEQA violations —including 28 24 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3773 of 4 65 I the failure to consider a reasonable range of alternatives and feasible mitigation measures to reduce such 2 noise impacts on outdoor recreation areas. 3 39. In its FEIR and Response to Comments, the CITY attempts to gloss over these CEQA 4 omissions by focusing (as it did in the DEIR) exclusively on the sleeping cabins located on the portion 5 of the VICHY SPRING PROPERTY that is the farthest away from where the construction-related 6 activities will occur, and the effects of construction noise on these more remote sleeping cabins. But any 7 analysis of noise impacts on persons staying in these more remote sleeping cabins (which are located on 8 the other side of a hill that would dampen noise impacts) is unrelated to the question of the adequacy of 9 analysis of construction-related noise impacts on outdoor recreation areas/hiking trails in areas 10 considerably closer to where the construction noise would be generated (and on the side of hills facing 11 the former landfill site). 12 40. As set forth in its previous written comments submitted on the DEIR for the Landfill Closure 13 Plan on January 9, 2020, in 1994 the CITY installed a series of groundwater wells on land located just 14 off the VICHY SPRINGS RESORT property. The purpose of installing these groundwater wells was to 15 monitor potential releases and contamination coming from the Ukiah landfill. At the time such 16 groundwater well installation was taking place, the owner of VICHY SPRINGS RESORT raised 17 concerns with CITY about whether such wells might impact the nearby subsurface mineral springs but 18 such concerns were disregarded. Immediately following the installation of said groundwater wells, 19 VICHY SPRINGS RESORT experienced a 50% drop in the pressure and now of its mineral springs 20 water and a 20-degree Fahrenheit drop in mineral spring temperature. This drop in pressure and 21 temperature lasted for several months. Such a precipitous drop in pressure and temperature had never 22 been documented before and has never happened since, and this precipitous drop in pressure and 23 temperature occurred immediately after the CITY's groundwater wells were installed and 24 operationalized. Therefore, all indications are that there is a direct hydrological connection between the 25 CITY's groundwater wells and the subsurface source of the Vichy Springs, and that this previous drop 26 in pressure and temperature was caused by the CITY's installation and operation of the groundwater 27 wells. This hydrological connection is documented in the letter submitted to the CITY by Al Sevilla of 28 25 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3774 of 4 165 I Ali sto Engineering (included as part of VICHY SPRINGS RESORT's January 9, 2020 written 2 comments on the DEIR and part of the administrative record). In the DEIR, FEIR and Response to 3 Comments, the CITY has alleged that the contemporaneous drop in spring pressure/flow and 4 temperature with the installation of the groundwater wells was merely a"temporal coincidence" that can 5 be attributed to natural fluctuations in the springs' pressure/flow and temperature. The CITY's failure to 6 acknowledge and describe the documented hydrologic connection between the CITY's groundwater 7 wells (which will be used for monitoring as part of the Landfill Closure Plan) and the nearby subsurface 8 Vichy Springs in the DEIR and FEIR for the Landfill Closure Plan constitutes a failure under CEQA to 9 adequately describe baseline conditions. 10 11 Sixth CEQA Claim—Failure to Recirculate DEIR After Disclosing Significant New Information Regarding Scenic and Noise Impacts in FEIR 12 41. CEQA requires the recirculation of an EIR for public comment by other agencies and the public 13 whenever"significant new information" is disclosed in the FEIR that was not disclosed originally in the 14 DEIR. CEQA defines "significant new information" to include information that identifies additional 15 potential significant environmental impacts (such as scenic/visual impacts or noise impacts) or that 16 reveals potential increased severity of environmental impacts (such as scenic/visual impacts or noise 17 impacts). 18 42. As set forth above, in its January 9, 2020 comment letter to the CITY on the DEIR prepared 19 for the Landfill Closure Plan, the North Coast Regional Water Quality Control Board stated: "Lastly, 20 regarding the Proposed Project-turf-based design, Regional Water Board staff has reviewed and 21 expressed concerns unique to a turf-based system with the City of Ukiah representatives. Given the 22 State of California's recent experience with catastrophic wildland fires which resulted in 23 significant infrastructure loss and damage, the Proposed Project's synthetic turf design has an 24 inherent surface-based vulnerability in this regard." (bold added.) The comment letter from the 25 North Coast Regional Water Quality Control Board (included in the FEIR) disclosed to the public and 26 Ukiah City Council the issue of enhanced fire hazards and fire risks associated with the proposed 27 synthetic landfill cover, an issue that was not disclosed or analyzed in the previous DEIR for the Landfill 28 26 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3775 of 4 165 I Closure Plan. This information regarding fire hazards and fire risks associated with the proposed 2 synthetic landfill cover constitutes "significant new information" under CEQA that requires 3 recirculation of the EIR. 4 43. The DEIR prepared and circulated for comment by the CITY stated that the Ukiah landfill 5 site was not directly visible from VICHY SPRINGS RESORT or from any residences or public roads in 6 the area. In its January 9, 2020 written submission of comments on the DEIR, VICHY SPRINGS 7 RESORT included numerous photographs from the VICHY SPRINGS RESORT property and from 8 several nearby residences and public roads that clearly indicated that the location of the Ukiah landfill 9 (and therefore of the proposed mono-color synthetic plastic cover for the landfill)was directly and 10 prominently visible from these vantage points. The FEIR prepared by the CITY included these 11 photographs which made plain that the statements in the DEIR regarding the lack of visibility of the 12 Ukiah landfill site from VICHY SPRINGS RESORT and nearby residences and public roads were 13 fundamentally incorrect, and that the DEIR's analysis of scenic impacts in the DEIR based on these 14 incorrect statements was therefore also significantly flawed, inaccurate and incomplete. The FEIR 15 acknowledged this previous error in the FEIR when it conceded for the first time (in the last paragraph 16 on Page 3.2-10)that"there are some partial views of the Ukiah Landfill from some vantage points on 17 the Vichy Springs Resort's 700-ares, which include hiking trails for its guests." This new 18 acknowledgement in the FEIR is in direct contradiction to the information provided by the CITY in the 19 DEIR, in which it incorrectly claimed that the Ukiah landfill was not visible at all from the VICHY 20 SPRINGS RESORT property or other residences and public roads. As to whether these current views of 21 the landfill site from VICHY SPRINGS RESORT and nearby residences will be adversely impacted by 22 the 40-acre mono-color synthetic cover that is now proposed to replace the natural grass vistas on the 23 landfill site, this is "significant new information" which goes directly to the question of the severity of 24 the project's impact on scenic/visual resources. None of this information was previously disclosed in the 25 DEIR, and the DEIR in fact expressly (and incorrectly) denied such views of the project site even 26 existed. Moreover, in its response to comments in the FEIR, the CITY claimed (without any support 27 again)that the photographs provided showing numerous prominent views of the landfill site from the 28 27 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3776 of 4 165 I VICHY SPRINGS REORT were taken from locations on the resort property where resort guest don't 2 walk or hike. This claim by the CITY is incorrect, as all of the photographs submitted with views of the 3 landfill are taken from locations on VICHY SPRINGS PROPERTY that are frequented by guests. This 4 unsupported claim by the CITY was merely an effort to try to somehow explain away the incorrect and 5 misleading information the CITY had previously provided in the DEIR, that no such views of the 6 landfill existed. And even after the CITY was provided by VICHY SPRINGS RESORT with 7 photographs depicting prominent views of the landfill from public roads, in the FEIR(in Response to 8 Comment C-5g)the CITY nonetheless incorrectly and misleadingly continues to state that it"not did 9 find any public vantage points where the landfill could be readily seen." (emphasis added.) 10 44. In terms of the construction-related noise impacts on outdoor recreation areas and hiking 11 trails located on the VICHY SPRINGS RESORT property, the DEIR had failed to acknowledge that 12 such outdoor recreation areas and hiking trails existed. Because the DEIR failed to acknowledge that 13 such outdoor recreation areas and hiking trails existed, the DEIR similarly failed to provide any analysis 14 whatsoever regarding the impacts of construction-related noise on these outdoor recreation areas and 15 hiking trails. In the FEIR, for the first time, the CITY acknowledged the existence of outdoor recreation 16 areas and hiking trails on the VICHY SPRINGS RESORT property, but then (again without any 17 supporting data or analysis) made an unsupported finding that the construction-related noise would not 18 affect the quiet and enjoyment of persons using these outdoor recreation areas and hiking trails. In its 19 Response to Comments (included in the FEIR), the CITY justified this less-than-significant finding on 20 the basis that the construction-related noise would not prevent people from being able to"walk and talk" 21 in these outdoor recreation areas. For places that people value primarily for the quietude and tranquility 22 of their surroundings and the restorative effect of silent interaction with nature (like the hiking trails on 23 the VICHY SPRINGS RESORT property), the fact people might still be able to"walk and talk" amidst 24 the persistent roar of diesel trucks, the continuous pounding thud of compression equipment and the 25 jarring sounds of backup beepers tells us nothing about the ways that such noise would compromise and 26 degrade the quality of the recreational experience in such places. Then, based on this bald unsupported 27 finding that the construction-related noise would not affect the experience of persons using these 28 28 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3777 of 4 165 I outdoor recreation areas and hiking trails, and relying on its finding that construction-related noise 2 would constitute a less-than-significant impact on such recreational resources, the FEIR went on to 3 determine that this new disclosure did not amount to "significant new information" and therefore that 4 recirculation of the EIR with this new information was not required. The CITY's logic here is circular, 5 without any evidence to support it, and inconsistent with what CEQA requires. 6 45. CEQA does not permit the CITY to avoid its obligation to recirculate the EIR for public 7 comment by simply including an unsupported bald finding in the FEIR that the construction-related 8 noise impacts on such just-acknowledged outdoor recreation areas and hiking trails are less-than- 9 significant. To avoid circulation in this instance, the FEIR would need to provide data, evidence and 10 substantive analysis (substantial evidence)to support this finding of less-than-significant impacts. 11 Because the FEIR failed to provide any evidence (let alone substantial evidence)to support this finding, 12 recirculation is required. 13 14 Seventh CEQA Claim—Failure to Identify and Consider Feasible Mitigation Measures to Reduce Adverse Environmental Impacts 15 46. CEQA requires that an EIR identify and evaluate feasible mitigation measures to avoid or 16 reduce the severity of adverse environmental impacts for a proposed action. 17 47. As noted above, the FEIR prepared by the CITY disclosed (for the first time)that the 18 proposed synthetic landfill cover would create enhanced fire hazard and fire risks. Although the FEIR 19 conceded the enhanced fires hazard and fire risks associated with the proposed synthetic plastic landfill 20 cover, the DEIR and the FEIR did not contain analysis of feasible mitigation measures to avoid or 21 reduce such fire hazards and fire risks. More specifically, in terms of such fire hazards and fire risks, the 22 DEIR and FEIR prepared by the CITY did not evaluate the advantages of using a clay/earthen landfill 23 cover instead of the proposed synthetic landfill cover. This failure to provide such a comparative 24 evaluation constitutes a failure to comply with CEQA's obligation to consider feasible mitigation 25 measures to reduce adverse environmental impacts of a proposed project 26 48. As noted herein, there are large numbers of large wild boars (weighing as much as 200 27 pounds)that roam on and in the immediate vicinity of the landfill site, and such wild boars have a 28 29 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3778 of 4 165 I natural tendency to"root" —to force their hoofs and snouts into the ground and tear up any ground 2 covering. The presence of wild boar populations and their tendency to "root" poses a significant risk to 3 the integrity of the propose synthetic plastic offer, a risk that it is not posed by the use of a clay/earthen 4 landfill cover. The DEIR and FEIR prepared by the CITY did not evaluate the environmental and 5 performance advantages of using a clay/earthen landfill cover as a feasible means to avoid or mitigate 6 the threats posed by wild boar populations in the vicinity of the landfill site. 7 49. As noted herein, as a natural consequence of the anticipated degradation during the 30-year 8 period of the Landfill Closure Plan, the synthetic landfill cover proposed by the CITY is likely to release 9 microplastic into nearby streams and creeks, and into the Russian River and the ocean. As also noted 10 herein, as a result of abrasion caused by wild boar rooting, the synthetic landfill cover proposed by the 11 City is likely to release PFAS into nearby stream and creeks, and into the Russian River. The DEIR and 12 FEIR prepared by the CITY did not evaluate the use of a clay/earthen landfill cover as a feasible means 13 to avoid and mitigate the anticipated release of microplastics and PFAS into waterways and thereby 14 reduce adverse impacts on hydrological resources/water quality and biological resources. 15 50. As noted above and further detailed in VICHY SPRINGS RESORT's January 9, 2020 16 written submission, construction-related noise generated by the Landfill Closure Plan will have adverse 17 impacts on outdoor recreation resources and hikers both on VICHY SPRINGS RESORT and other 18 nearby properties. As detailed above, although the FEIR prepared by the CITY acknowledged (for the 19 first time)that such nearby outdoor recreation resources and hiking trails exist, the DEIR and the FEIR 20 in fact contained no data, evidence or substantive analysis to evaluate the severity of how construction- 21 related noise (e.g. compression equipment, backup beepers)will increase noise levels above 22 existing/baseline noise levels on such outdoor recreation areas and hiking trails. Without such 23 information and comparative analysis, there is no basis (no substantial evidence)to support the FEIR's 24 finding that the construction-related noise impacts on such outdoor recreation areas and outdoor 25 recreation users will be less-than-significant. This is because, as explained above, for these impacted 26 outdoor areas closer to the landfill site the DEIR and FEIR do not contain a comparison of ambient 27 noise levels prior to the project(which reflect the peaceful quietude that is an essential part of the 28 30 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3779 of 4 165 I hiking/outdoor experience for such areas)with noise levels while the construction-related activities are 2 taking place. Because the CITY lacks any basis to find that the construction-related noise impacts on 3 such outdoor recreation areas/hiking trails are less-than-significant, CEQA's requirements regarding 4 feasible mitigation measures apply. 5 51. In the written comments VICHY SPRINGS RESORT submitted to the City on January 9, 6 2020, several mitigation measures were presented to help reduce or otherwise minimize the 7 construction-related noise impacts of the Landfill Closure Plan on nearby outdoor recreation areas and 8 hiking trails. More specifically, in its January 9, 2020 written submission, VICHY SPRINGS RESORT 9 proposed that the construction work could forgo the use of loud jarring backup beepers on motor 10 vehicles used on the project site, and instead deploy additional construction personnel to help guide such 11 trucks/equipment so the use of such backup beepers would not be needed to ensure the safety of workers 12 (and alternative that, as noted above, is expressly allowed pursuant to OSHA Regulation 13 1926.601(b)(4)). More specifically, in its January 9, 2020 written submission, VICHY SPRINGS 14 RESORT proposed that instead of scheduling construction work weekdays from 7:00 am to 7:00 pm 15 (essentially all daylight hours when people would be hiking or otherwise using nearby outdoor 16 recreation areas), such construction work could be scheduled for either designated morning shifts or 17 designated after shifts. VICHY SPRING RESORT is open every weekday, and its weekday guests make 18 frequent use of the hiking trails over the hills from the resort buildings. For instance, if weekday 19 construction work was scheduled from 7:00 am to 2:00 pm on weekdays, then people enjoy the nearby 20 outdoor recreation areas/hiking trails from 2:00 pm until 7:00 pm without being subjected to adjacent 21 construction-related noise. Similarly, if weekday construction work was scheduled from 12:00 am to 22 7:00 pm, then people could enjoy the nearby outdoor recreation areas/hiking trails from 7:00 am to 23 12:00 am without being subjected to adjacent construction-related noise. As another potential mitigation 24 measure, weekday construction activities could be limited to 9:30 am to 4:30 pm, which would at least 25 provide limited hours in the early morning and late afternoon for nearby hiking and outdoor recreation 26 activities that would be undisturbed by construction-related noise impacts. VICHY SPRINGS RESORT 27 recognizes that, regardless of which landfill cover is selected, there will necessarily be some adverse 28 31 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3780 of 4 165 I noise impacts associated the construction-related aspects of the Landfill Closure Plan. What VICHY 2 SPRINGS RESORT requested was that the CITY, as part of its CEQA environmental impact assessment 3 process, identify and evaluate feasible mitigation measures (such as those noted above)to reduce and 4 minimize such construction-related noise impacts as they related particularly to persons using outdoor 5 recreation areas/hiking trails. 6 52. Aside from its purely conclusory statement(in its Response to Comments)that forgoing the 7 use of backup beepers would present unacceptable risks to workers on the site (a statement not 8 supported by any analysis of the OSHA-approved option of having additional construction staff on site 9 to address safety concerns related to vehicles backing up), the DIER and FEIR did not consider or 10 evaluate any further measures to reduce or minimize construction-related noise impacts on outdoor 11 recreations areas/hiking trails and on the people that use those recreational resources. As such, the DEIR 12 and the FEIR did not determine that the noise impact mitigation measures proposed by VICHY 13 SPRINGS RESORT were not feasible, but rather simply refused to consider or evaluate them at all. The 14 CITY attempted to justify this refusal on the basis that it did not need to consider and evaluate such 15 mitigation measures because the FEIR had made a finding that the construction-related noise impacts on 16 nearby outdoor recreation areas/hiking trails were less-than-significant. 17 53. However, as explained above, the CITY's reasoning here is completely circular because the 18 FEIR did not provide any data, evidence or substantive analysis (substantial evidence)to support its 19 finding that the construction-related noise impacts on nearby outdoor recreation areas/hiking trails 20 would be less-than-significant. As such, this finding in the FEIR will simply be disregarded by any 21 reviewing court on the basis that there is no substantial evidence to support it. Because this finding will 22 be disregarded, there is no justification under CEQA for the CITY's refusal to consider and evaluate 23 feasible mitigation measures to reduce and minimize construction-related noise impacts on nearby 24 outdoor recreation areas/hiking trails. 25 26 Ei2hth CEQA Claim —Absence of Substantial Evidence to Support FEIR Findings Regarding Environmental Impacts and True Proiect Costs 27 54. CEQA requires that all findings in an EIR be supported by substantial evidence. Under 28 32 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3781 of 4 65 I CEQA, findings in an EIR that are not supported by substantial evidence will be disregarded by a 2 reviewing court. 3 55. It its Response to Comments (included as part of the FEIR), the CITY claimed that the North 4 Coast Regional Water Quality Control Board, CalRecycle and Mendocino County Health Department 5 (the"LEA" under the California Health and Safety Code) had already "approved" the synthetic landfill 6 cover design in 2018. This is incorrect. Under CEQA, the North Coast Regional Water Quality Control 7 Board, CalRecycle and Mendocino County Environmental Health Department are legally prohibited 8 from making a final approval of the proposed synthetic landfill cover until such time as the CITY(as the 9 CEQA lead agency) first completes its environmental impact assessment for the Landfill Closure Plan. 10 In the case of the Landfill Closure Plan, this means that the North Coast Regional Water Quality 11 Control, CalRecycle and Mendocino County Environmental Health Department may not make a final 12 approval of the proposed synthetic landfill cover until the CITY first certifies a legally-adequate EIR 13 (which has not yet happened). The reason for this sequencing under CEQA is because, before the 14 making a final approval of the proposed synthetic landfill cover, the Regional Board, CalRecycle and 15 Mendocino need to review and consider all of the information and analysis contained in the certified 16 EIR regarding the environmental performance and risks associated with the proposed synthetic cover, 17 including but not limited to fire safety/fire hazard risks, risks to waterways and biological resources 18 associated with the release of microplastics and PFAS, risks to water quality associated with the rooting 19 behavior of wild boar populations that roam on and in the vicinity of the landfill site, and impacts 20 associated with removing, disposing of, and replacing the interim final cover(discussed herein). To the 21 extent the EIR prepared by the CITY for the Landfill Closure Plan is legally inadequate under CEQA, 22 this would preclude the North Coast Regional Water Quality Control Board, CalRecycle and Mendocino 23 County Environmental Health Department from issuing any permits or approvals for the Landfill 24 Closure Plan. Should the North Coast Regional Water Quality Control Board, CalRecycle and 25 Mendocino County Environmental Health Department issue approvals or permits for the Landfill 26 Closure Plan without first determining that a legally-adequate EIR has been prepared, VICHY 27 SPRINGS RESORT, RUSSIAN RIVERKEEPER and MATEEL ENVIRONMENTAL reserve the right 28 33 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3782 of 4 165 I to file administrative appeals and/or litigation to have such agency approvals/permits set aside. 2 56. The FEIR including the following finding regarding the proposed ClosureTurf synthetic landfill 3 cover on page 4-30: "The durable, high-strength system components ensure a long-life (100-year design 4 life) of protection against operational and natural forces." (bold added.) Yet, as noted above, the 5 ClosureTurf company product materials included in the DEIR and FEIR acknowledge (on the page titled 6 "Weathering")that by the end of a 30-year period customers should anticipate a 25%loss in the tensile 7 strength of the engineered turf fibers. If the engineered turf fibers that comprise the synthetic landfill 8 cover are expected (by the manufacturer ClosureTurf)to lose 25% of their strength/integrity in the first 9 30 years than presumably it can be expected that there would be additional and increasing losses in 10 strength/integrity of the engineered turf fibers during a 100-year period. In light of this 11 acknowledgement of anticipated turf fiber degradation by the manufacturer, there is not substantial 12 evidence to support the CITY's finding the FEIR that the proposed synthetic landfill cover has a"100- 13 year design life." 14 57. The DEIR and the FEIR for the Landfill Closure Plan found that there was a less-than-significant 15 impact on hydrologic resources/water quality and a less-than-significant impact on biological resources. 16 In making these findings, the DEIR and FEIR failed to acknowledge (as discussed herein)the likelihood 17 that the anticipated degradation of the engineered turf fibers in the proposed synthetic cover during the 18 minimum 30-year life of the Landfill Closure Plan would result in the release of microplastics into 19 nearby streams and creeks and into the Russian River and the ocean, and failed to acknowledge the 20 adverse impact of such microplastic releases on fisheries. As set forth above, the DEIR and FEIR also 21 failed to disclose and discuss how wild boar rooting is likely to cause to the release of PFAS from the 22 synthetic landfill cover into nearby streams and creek(see Exhibit 2 to these comments). The DEIR and 23 FEIR's disregard of the likelihood of microplastic releases and PFAS releases into waterways and the 24 resulting impacts of such microplastic and PFAS releases on fisheries indicates a lack of substantial 25 evidence to support the finding that the Landfill Closure Plan will have a less-than-significant impact on 26 hydrologic resources/water quality and biological resources. 27 58. The DEIR and FEIR for the Landfill Closure Plan contained a finding that the proposed 28 34 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3783 of 4 165 I synthetic cover was an "environmentally superior alternative" to the option of using a clay/earthen 2 landfill cover(the cover preferred by the Regional Board). In making its finding in the DEIR and the 3 FEIR that the synthetic landfill cover was an "environmentally superior alternative" the DEIR and FEIR 4 failed to acknowledge and evaluate that the proposed synthetic landfill cover presented enhanced fire 5 hazards and fire risks as compared with the option of a clay/earthen landfill cover(an enhanced fire 6 hazard and fire risks that would be avoided if the clay/earthen landfill cover were selected). In making 7 its finding in the DEIR and FEIR that the synthetic landfill cover was an "environmentally superior 8 alternative" the DEIR and FEIR also failed to: 9 • acknowledge and address the threats to waterways and biological resources from the release of 10 microplastics and PFAS associated with the use of the proposed synthetic landfill cover; 11 • acknowledge and address the presence of large numbers of wild boars on and in the vicinity of 12 the landfill site, and failed to recognize the threat such wild boars (and their"rooting" behavior) 13 presented to the integrity of the proposed synthetic landfill cover and the resulting risks of PFAS 14 releases into nearby streams and creeks; 15 • acknowledge and discuss that the use of a clay/earthen/natural grass landfill cover versus the 16 proposed mono-color synthetic plastic landfill cover would avoid adverse scenic impacts; and 17 • Acknowledge and address the fact that the interim final cover would ultimately need to be 18 removed, disposed of, and replaced, causing additional environmental impacts. 19 By failing to acknowledge and address these fire-related, water quality-related, wild boar-related risks 20 and increased adverse scenic and other impacts associated with the selection of the synthetic landfill 21 cover, the DEIR and the FEIR lacked substantial evidence to support the finding that the proposed 22 synthetic landfill cover was the `environmentally superior alternative." 23 59. As set forth above, although the DEIR and FEIR contained information that the CITY would 24 be required by the Regional Board to provide additional financial assurances if it selected the synthetic 25 landfill cover option, the DEIR and FEIR did not attempt to estimate the cost of such additional financial 26 assurances nor did it include the costs of a such additional financial assurances in its project budget for 27 the Landfill Closure Plan. As set forth above, due to the fire hazards and fire risks associated with the 28 35 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3784 of 4 1 165 I selection of the synthetic landfill cover option, the CITY will need to maintain fire-related insurance 2 throughout the entire 30-years of the Landfill Closure Plan (and beyond, until released from postclosure 3 maintenance responsibilities)to provide coverage for these fire-related hazards and risks. The DEIR and 4 the FEIR, however, did not attempt to monetarily quantify the costs of maintaining such fire-related 5 insurance nor did the DEIR or FEIR includes the costs of maintaining such fire-related insurance in its 6 project budget for the Landfill Closure Plan. As explained above, the proposed synthetic plastic landfill 7 cover is an "interim" measure. After these 30 years, the synthetic landfill cover will likely need to be 8 removed and disposed of, and replaced with a"permanent" clay/earthen landfill cover. The DEIR and 9 FEIR, however, did not provide an estimate of the costs of removing and disposing of the interim 10 synthetic landfill cover, or of replacing the interim synthetic landfill cover with a permanent 11 clay/earthen landfill cover. The failure to include and quantify the costs associated with these additional 12 financial guarantees, fire-related insurance premiums, and the failure to include the likely costs of 13 removing, disposing and replacing the interim synthetic landfill cover evidences that there is not 14 substantial evidence to support the findings in the DEIR or FEIR regarding the budget/anticipated costs 15 associated with selecting the synthetic landfill cover, nor is there substantial evidence in the DEIR or 16 FEIR to support the findings that the true budget/anticipated costs of the synthetic cover option will be 17 less expensive than the clay/earthen landfill cover option (which the CITY will need to install anyway 18 after 30 years). 19 60. As set forth above, the DEIR and FEIR for the Landfill Closure Plan do not contain substantial 20 evidence (or any evidence)to support the finding that the construction-related noise impacts of the 21 Landfill Closure Plan will have a less-than-significant on nearby outdoor recreation areas/hiking trails, 22 including impacts on those outdoor recreation areas/hiking trails located on the VICHY SPRINGS 23 RESORT property. As set forth above, the DEIR and FEIR for the Landfill Closure Plan do not contain 24 substantial evidence (or any evidence) to support the claim that foregoing the use of backup beepers for 25 trucks/equipment would present an unacceptable risk to workers (due to the failure to consider the 26 option, approved by the federal Occupational Safety and Health Administration, of having additional 27 construction staff on site to address the worker safety concerns that backup beepers are intended to 28 36 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3785 of 4 165 I address). 2 61. As set forth above, the FEIR found that forgoing the use of backup beepers for construction 3 vehicles operating at the landfill site would create an unacceptable safety risk. In making this finding the 4 FEIR failed to consider that OSHA Regulation 1926.601(b)(4) expressly provides that, in lieu of the use 5 of backup beepers, motor vehicles at construction sites may rely on an"observer that signals" it is safe 6 to back up. The availability of this OSHA-approved"observer" option makes clear that there is not 7 substantial evidence to support the FEIR's finding that forgoing the use of backup beepers creates an 8 unacceptable safety risk. 9 62. As set forth above, the CITY's DEIR, FEIR and Response to Comments determined that 10 there was no hydrological connection between the groundwater wells that will be operated as part of the 11 Landfill Closure Plan and the subsurface source of the Vichy Springs, and that the installation and 12 activation of the such groundwater wells in 1994 was unrelated to the precipitous drop in mineral spring 13 pressure and temperature that occurred immediately after the installation and operation of the wells. The 14 CITY determined that these contemporaneous events were just a temporal "coincidence." In support of 15 this finding, the CITY referred to a 1994 study showing that the chemical constituency of the water 16 found in the groundwater wells was different from the chemical constituency of the water in the 17 subsurface springs. This 1994 study, however, is completely off-point from a scientific standpoint 18 because the cause of the depressurization of the springs was not the ongoing co-mingling of waters, it 19 was that the groundwater wells provided a short-term conduit for CO2 to vacate the subsurface springs 20 thereby temporarily reducing pressure that maintained the springs' flow and temperature. A comparison 21 of chemical constituency samples, taken months after this CO2 depressurization had occurred and the 22 CO2 levels had later re-established, does not provide any evidence as to effect of the groundwater wells 23 on the pressure and temperature of the springs (which occurs because of the hydrologic connection 24 between the wells and the springs). For these reasons, there is no evidence (let alone substantial 25 evidence)to support the DEIR's and FEIR's finding that under current baseline conditions the operation 26 of the groundwater wells as part of the Landfill Closure Plan cannot impact the pressure and temperature 27 of subsurface mineral springs upon which VICHY SPRINGS RESORT relies. 28 37 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3786 of 4 165 1 63. Beyond the above-noted examples of the lack of substantial evidence to support key findings 2 in the DEIR and FEIR, it is particularly important to note the lack of substantial evidence to support the 3 finding in the DEIR and FEIR that the selection of the synthetic plastic landfill cover will have a less- 4 than-significant impact on scenic/visual resources. It is with this particular finding that the lack of 5 substantial evidence is perhaps the most glaring. In the DEIR, the CITY claimed that the synthetic 6 landfill cover would have a less-than-significant scenic impact because the mono-color synthetic landfill 7 cover would somehow blend naturally into the surrounding natural grass hillsides. Perhaps recognizing 8 the absurdity of this claim, in the FEIR the CITY took a different tack. For the FEIR, instead of sticking 9 with it previous claim that the mono-color synthetic landfill cover would somehow blend naturally into 10 the surrounding natural grass hillsides, the FEIR instead argued that the"contrast" between the 11 surrounding natural grass hillsides and the 40-acre mono-color swath of synthetic plastic might be 12 considered by some people to be visually "pleasing" because it might remind them of an irrigated field. 13 The FEIR then noted that there many irrigated fields throughout Mendocino County and that some 14 people find such irrigated fields picturesque. In support of this new"pleasing contrast" argument, the 15 FEIR then showed a picture of a baseball field with astroturf, and claimed that when seen from a 16 distance it was difficult for most viewers to be able to recognize that the baseball field was artificial 17 astroturf rather than natural grass. The FEIR also claimed that the concerns raised by VICHY SPRINGS 18 RESORT about the adverse scenic/visual impact of the proposed mono-color synthetic plastic cover 19 should be disregarded because they were not made by an appropriate "expert." While a comprehensive 20 refutation of all of the CITY's illogical and strained claims here is beyond the scope of what can be 21 covered herein, a few critical common-sense points can be highlighted. 22 64. In terms of the CITY's observation that there are many irrigated fields in Mendocino 23 County and that some people find these irrigated fields visually pleasing, this observation is completely 24 irrelevant from a CEQA standpoint. Pursuant to the environmental impact analysis required by CEQA, 25 the pertinent inquiry is not whether some people sometimes find irrigated fields pleasant to look at. The 26 pertinent question is whether, at the former landfill site, the change from the current natural grass 27 hillside to a mono-color synthetic plastic 40-acre swath would be considered an adverse scenic impact. I 28 38 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3787 of 4 65 I is this comparison of existing scenic conditions to post project scenic conditions at this particular 2 location that is relevant, not whether(in some general sense) some people find irrigated fields pretty. 3 Moreover, in the context the natural grass hillsides surrounding the landfill site (where there are no other 4 irrigated fields), it would be apparent to any viewer that the 40-acre mono-color swath is not an irrigated 5 field as it would make no sense to plant and maintain such an irrigated field in this setting. 6 65. In terms of the CITY's analogy to a baseball field covered in astroturf, for anyone that has 7 ever attended a professional or college baseball game and sat in the stands to watch the game (several 8 hundred feet away from the playing field), it is immediately visually apparent whether the field is 9 composed of natural grass or of astroturf. The uniformity of color and the texture of astroturf are 10 visually different from natural grass. The claim in the FEIR(in Response to Comment C-3a), in regard 11 to the suggested analogous situation with an astroturf baseball field, that"from over 500-feet away it 12 would be difficult if not impossible to tell the difference between artificial synthetic turf and real/natural 13 grass" is absurd and defies common experience. If one were attending a baseball game with an astroturf 14 field (instead of a real grass field) and asked 100 spectators sitting in the stands 500 feet away from the 15 field, "is that astroturf or natural grass?" it is likely that 100 out of 100 spectators would look at the field 16 and respond"That's astroturf." It is doubtful any spectator attending the baseball game would be 17 mistaken or confused about what it is they are looking at, that they are looking at synthetic artificial turf 18 rather than natural grass. Moreover, the photograph of the baseball field provided by the CITY in its 19 Response to Comments (as part of the FEIR), of a baseball field that has astroturf on the infield and 20 natural grass in the outfield (that both just coincidentally happen to be almost the exact same color), is 21 completely distinguishable from the scenic situation presented with the former Ukiah landfill. As 22 explained herein and as conceded by the CITY, during the drier/hotter portions of the year, the hillsides 23 surrounding the 40-acre mono-color synthetic plastic green cover will be brown (not the same color as 24 the synthetic plastic cover). In terms of the baseball field, if the CITY wanted to provide a photograph 25 that was visually analogous to the situation with the former Ukiah landfill, it should have provided a 26 photograph of a mono-color synthetic green infield set against an unirrigated brown dry outfield. Had 27 the CITY provided such a photograph, any viewer of the photograph (and any person actually looking at 28 39 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3788 of 4 165 I the real baseball field)would immediately recognize that the strangely uniform green infield is artificial 2 astroturf rather than natural grass (because the natural grass in the outfield would be dry and brown). 3 66. Finally, the CITY claims that VICHY SPRINGS RESORT's concerns regarding the scenic 4 impacts of the proposed mono-color plastic synthetic cover should be disregarded because such 5 concerns were not raised by an appropriately trained "expert." When it comes to assessing adverse 6 visual/scenic impacts, unlike with many other environmental impacts, there is no such thing as a 7 technically-trained"expert." There is no professional or academic degree of certification that qualifies 8 someone as an expert to determine whether a scenic change from a natural grass hillside to a mono-color 9 synthetic cover is considered adverse when set in the context of surrounding natural grass hillsides. To 10 determine such scenic impacts, in terms of whether they are adverse and to gauge the severity of any 11 such adverse impact, we are simply left with the preferences and reactions of a reasonable common 12 person. The CITY, and the environmental consultant hired by the CITY to prepare the FEIR and the 13 DEIR, do not have any particular"expertise" in determining or quantifying such adverse scenic impacts. 14 If the question is presented to a judge as to whether the proposed synthetic mono-color plastic landfill 15 cover constitutes a negative scenic impact as compared with the current natural grass condition of the 16 landfill site and in comparison with the surrounding natural grass hillsides, the judge will look to the 17 preferences and reactions of a reasonable common person. VICHY SPRINGS RESORT, RUSSIAN 18 RIVERKEEPER and MATEEL ENVIRONMENTAL are confident that under such an approach the 19 CITY's position and claims—that for some people the synthetic plastic mono-color landfill cover may 20 present a"pleasing contrast" with the natural grass hillsides, or that some people may somehow mistake 21 the synthetic plastic landfill cover for an irrigated field—will be given little if any credence. Those types 22 of claims may be offered up in the marketing materials by the company that manufactures the proposed 23 synthetic landfill clover(ClosureTurf)the CITY proposes to use, but such self-serving marketing claims 24 are inconsistent with the actual preferences and actual experiences of a reasonable common person. 25 IV. RELIEF SOUGHT 26 67. For the reasons set forth herein, and in the previous written submissions to the CITY by 27 28 40 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3789 of 4 65 I VICHY SPRINGS RESORT and other parties, VICHY SPRINGS RESORT, RUSSIAN 2 RIVERKEEPER and MATEEL ENVIRONMENTAL respectfully request that the CITY prepare a 3 revised EIR for recirculation that addresses the shortcomings and instances of CEQA-noncompliance 4 identified herein and in other previous submissions. The preparation and recirculation of such an EIR 5 will not only help ensure that the Landfill Closure Plan reduces adverse fire hazards, scenic impacts, 6 noise impacts, historic resource impacts, public safety impacts, hydrologic resource/water quality 7 impacts and biological resource impacts, but will also help to reduce the true project costs to Ukiah 8 taxpayers and as well as costs and liabilities that are likely to be incurred by the CITY and Ukiah 9 taxpayers if litigation is unfortunately required to ensure compliance with CEQA. 10 Respectfully submitted, f4h I,n�"1 11 PAd 5U4 12 Dated: May 15, 2020 By: 13 PAUL STANTON KIBEL 14 WATER AND POWER LAW GROUP Attorneys for VICHY SPRINGS RESORT 15 16 Dated: May 15, 2020 By: 17 Don McEnhill, President 18 RUSSIAN RIVERKEEPER 19 Dated: May 15, 2020 By: 20 William Verick, Executive Director 21 MATEEL ENVIRONMENTAL JUSTICE FOUNDATION 22 23 Exhibits Exhibit 1: Cal Fire's Fire Hazard Risk Map for Mendocino County 24 Exhibit 2: Opinion Letter from Pangea Environmental Services Exhibit 3: 2019 Stockholm University Report on Microplastics and Artificial Fields 25 Exhibit 4: Company Logo for Lockwood Hunting Services in Ukiah 26 Exhibit 5: Wild Pigs Report by United States Department of Agriculture Exhibit 6: Feral,Swine Damages Report by University of California 27 Exhibit 7: Vichy Springs Resort Landmark Designation 28 41 VICHY SPRINGS RESORT,RUSSIAN RIVERKEEPER AND MATEEL ENVIRONMENTAL COMMENTS ON FEIR Page 3790 of 4165 I 'V I("I I I Y, S P F(IN, and ot her pa rt ics, VIC1,1 Y S P'R I NCiS R L-,,S,()]R 1', R I f SS LA 2 and MATF111, F,11,S1 V!RO Nil NIUNT'ik L respectfully re1quest lbat t1m: ('-'1`TY preparil 3 reivised EIR tbr recirculation that addresses Elbe instariccs of" 4 idemitil"wid hereh,.i and hl OthC1' jVk!ViOUS SUbirdssions. The� preparation ,,uid an FIR 5 wiN not ono Y bell ensum that the Landfill Clostire, Plan reAuces adverse fire hazards, scenic impicts, 6 iwise in,,,pacl!i, historic resource linpacts, public saficty implacts, hYdrologic 7 impacts wIld biological resource iwawlaw,aets, bw willalscw help to reduce the true pn,, �act i to [Xiah, 8 tax pavers ancl as vivell as costs and liabilities diat are likely to be inctwred by the ('"ITY and U,(kiah 9 taxpayers it"lifigation is unfimitinately i-equired to ensure compliance with (7EQA. 10 Respectfully subnfitic4i, fill 12 Dated: N'lay 15, 20201 By, ....... .............. 13 PAUL S]"A1,14TON all. .. IB WATEIZ AN[") LAW (3,W)UP' 14 1 ,Attorrieys for 'VI(IIIN' SPRIN(1,15 RESOR,"T 15 16 Date& May '15, 2020 By, 17 Don McEnhill, President 18 RUSSIAN R,WFIRK 1"T[" R, 19 Is/William Verick Dateld: May, 15, 2020 By: ......... 20 21, William, Verica,p F"xecutive Director 22 MATEEL ENVIRONMENTAL JUS110E, F(1)UNDAT1W,,i 2 Exhiblits ("zil Fire's Fire Hazard Risk Mal) fim, livIendoc:,ino (e,,ount, Y 24 Exhibit 2: Clpinion Letter fro m Paji!�, ca Environmental Semices F xhibit 3: 2019 Stockhoina 11niversily Report on Nficrioplastics alld Artificial F"icids 25 4: ('oirnpany, Logo 11,n, Lockwood Hititifing Services in Ukiah 26 Exhibit 5: Wild lligs Rt,?,pi warn by United Suaws Departmern of Agriculture 6; F1'ral 1)unmrges Report by Universiq of Calif"birnia 27 Exhibit 7: Vichy, Sjn,ings Resort 11.,,,awdmark, Desi,gn,"ItIor) fiy:a 28 X)NI VICHY SPRINGS RESORT, RJ,JSSL',%N RIVERKU"EFIER AND VINTEEL ENV111OWFINTAL., ( ME, W 165 .................. Exhibit 1 Page 3792 of 4165 �y m b °®.1 ®�� _^. m IIIIIIIIIIIIIIIII I der P m + m 4t,rz , f m r+^ ,; �2 V IIVVVI rr k Fb �,^ ^, r ^^ U0 4 r ° m , , ° a � 4 0 4 f � I ............ Moderate Fire Hazard High Fire Hazard MENDOCINO COUNTY Very High Fire Hazard FIRE HAZARD AREAS Q Local Responsibility Area-Uncorporated LOCAL RESPONSIBILITY AREAS Q Local Responsibility Area-Incorporated Q Federal Responsibility ARea FEDERAL RESPONSIBILITY AREAS ® Cities&Towns Major Roads Source: This map was derived from the CAL FIRE,Fire Hazard Severity Zones in SRA,Adopted By AL FIRE on November 7,2007. - - -Major Rivers This map is provided as a visual display of County Information. Reasonable effort has been made to ensure the accuracy ofthe map and data provided:nevertheless,some information may not be accurate. The positional accuracy of the data is approximate and not intended to represent map accuracy from a published record of survey. THE MAPS AND ASSOCIATED DATA ARE PROVIDED WITHOUT WARRANT OF ANY KIND. N Either expressed or implied,including but not limited to,the impelled warranties of merchantability and fitness for a particular purpose. 2 1 0 2 n Do not make a business decision based on these data without first validating the information with appropriate County agency or other government entity. ®Miles N Exhibit 2 Page 3794 of 4165 PANGEA TRANSMITTAL To: Paul S. Kibel, Esquire Date: May 13,2020 Re: Opinions Vichy Springs Resort v. City of Ukiah Public Works and City of Ukiah City Council I, Bob Clark-Riddell, a registered Professional Engineer in California (C49629) and President/Principal Engineer of Pangea Environmental Services, Inc.. prepared the enclosed opinions regarding potential impacts to human health, animals, and water quality for the subject matter. If you have any questions, please contact me at briddell�pangeaenv.com or(510)435-8664. Sincerely, Pangea Environmental Services, Inc. Bob Clark-Riddell,P.E. President/Principal Engineer Enclosure: Opinions PANGEA Environmental Services, . 1250 Addison Street, Suite 213, Berkeley, CA 94702 Telephone 510.836.3700 www.pangeaenv.com Page 3795 of 4165 Expert Opinions — Bob Clark-Riddell, P.E. May 13, 2020 Vichy Springs Resort v. City of Ukiah Public Works and City of Ukiah City Council Opinion #1: In the event of a wildfire, the proposed synthetic landfill cover would likely represent a significant health risk to nearby residences via airborne emissions. This opinion is based on the following information: 1. A number of residences are located within 2,000 of the proposed synthetic landfill cover. 2. According to the limited product information readily available from Watershed Geo, ClosureTurf(the apparent proposed synthetic landfill cover material)is comprised of a) an artificial grass on top (polyethylene fibers),b) an infill material(likely a 3/4"thick coated sand layer supporting the artificial grass), and c)a MicroSpike plastic bottom layer(composed of high-density polyethylene [HDPE] and linear low-density polyethylene [LLDPE])(Exhibit A). 3. For the polyethylene fibers, according to a material safety data sheet(MSDS) as Exhibit B,the product polymer may decompose under fire conditions to give off hazardous products. The MSDS lists hazardous decomposition products of carbon monoxide, carbon dioxide,nitrogen oxides, and traces of hydrogen cyanide. 4. For HDPE, according to a material safety data sheet(MSDS) as Exhibit C,polyethylene is a combustible substance which in contact with flame ignites and burns until exhausting. The MSDS lists toxic combustion products of carbon monoxide, carbon dioxide, and other oxidizing organic compounds. Molten polymer presents thermal burns hazard in case of skin contact. Opinion #2: In the event of a wildfire, the proposed synthetic landfill cover would likely represent a significant health risk to fire fighters via airborne emissions. This opinion is based on This opinion is based on the following information: 1. Information presented in Opinion 41 regarding ClosureTurf components and hazardous decomposition and toxic combustion products (Exhibits A,B and Q. 2. For HDPE, according to a material safety data sheet(MSDS) as Exhibit C, fire fighting equipment should include self-contained breathing apparatus and complete fire fighting clothing. Molten polymer presents thermal burns hazard in case of skin contact. Page 3796 of 4165 Opinion #3: The proposed synthetic landfill likely represents m threat towater quality near the proposed synthetic cover location. This opinion iy based on the following information: |. Creeks and surface water are present in the area of the proposed synthetic landfill cover. 2. PFAS chemicals have been found in artificial turf(Exhibit D). 'PFAS' is short for purDuorooJkvomd polyfluoroalkyl substances and includes chemicals known uoPP0B, PP0A and GunX, sometimes called 'forever chundcu|o` These chemicals all share signature elemental bonds of fluonine and carbon,which are extremely strong and difficult to break down in the environment or in our bodies. PFAS chemicals have been used widely to help with the production of plastic polymers that are molded into the shape of grass blades when in molten form. Exhibit 0 references water inuwetlands near discarded turf contained PFAB when tested. Exhibit 0 references research that PFAS is released from turf when exposed to abrasion(maintenance equipment or feral rooting |d ntdhun�tonorfd degradation and releases). �zhihd0 suggests p/�yrooun� oouuzoon�n uu� onun ruuuyuy'� yu��u y that limited information is available about the presence of PFAS in artificial turf and the potential for releasing and affecting air, soil, and water where these products are used. 3. According to U.S. EPA,there is evidence that exposure to PFAS chemicals can lead to adverse human health outcomes for humans (including cancer)and for animals (Exhibit E). PFAS has been evaluated at numerous sites for potential releases into air, soil and water, and including sources of drinking water. ln May 20|6, lJ.B. EPA issued ulifetime health advisory PF()B and PFOAfor drinking water. Exhibit E documents that PFABcan affect people via contaminated air and that drinking water has been impacted by PFAS. 4. PumuunttolJ.B. EPA recommendations,the California State Water Resources Control Board(SWRCB)has issued notifications to sensitive receptors, is investigating PFAS, and has established guidelines for PFABtesting to assess the scope of the proh|unu (EzhihdF). Exhibit F cites that people are exposed toPFAB through dust and drinking water, and that PFABy tend to accumulate in groundwater. 5. ABWQCB map tracking PFAB testing ofdrinking water. Exhibit(}shows u portion of the PFAS map for northern California,where PFAS has been found in drinking water in the main well for the Btonugate Mobile Home Park of Santa Rosa, California. 6. The California Office of Environmental Health Hazard Assessment(()EHHA)has issued a notice that the agency intends to list PFOA and PFOS as known to cause reproductive toxicity under the Safe Drinking Water and Toxic Enforcement Act of|986 (Ezhihdll). Opinion #4: Due to F»FAS' the proposed synthetic landfill cover likely represents m threat to human health vim airborne emissions of wildfires or long-term deterioration of the cover. This opinion iy based on the following information: |. Information presented in Opinion#3rugmdino|Uku|vPFABpruyunouundduuyyooiated uzhihdy. 2. The U.S. EPA and CBWQB exhibits reference human health concerns from PFAB via air contamination,which could be exacerbated by wildfires, deteni oration overtime, and abrasion from mechanical equipment or wildlife (u.g.,pig roodng). Page 3797of4105 Exhibit A for Bob Clark-Riddell Opinion Page 3798 of 4165 GaS,L1!Ne,T1irf5 twit 40 niil MkmSplkerr I ner / /iiarr r r r f= T`KC:k;neszLrorerv"u,Jl,rnil(mmil 11a'TIMM599°T „ 11 ai40 11iG(i T,nuekn,ess(m!in,avl,.p,neiidi,nnrnll AS WD5994 38p.951p 311d,10.95� 1Thickn'Lss V Xrvwvnrzt u"crrv-�'ma Jw rm ASTTkt D599w4 34(G.85) 34 hn0 85q. 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AMA o5"T9�'� ^CrimLy near sp4rerrtcaV a E�orn�asrates for i0 wr�:wtir- iin"C.at..1 on:2 Stress Crack Resuetamca uSmgq a%int NwdCTL),hours;: XS'T A D5397„App,!,dx &:NII'A 50G o� aat^e um N Xar TvmMe,,!riir ASTTuNE D3995 2W°?T,1 at 0! 1140 11 ........, w Wygvwi°u'wmrvl.wuW'�"�vr°xa 4W w'm�oww"�'Mlr"�tl'2u.uTr�r w4Gu5w Uwrn„ Poo rbKf-°umeow.trN°.xk'YiD.iim Y.dd'ALy d'm711•mn r4eW)uveV° ���'w IkXF✓C6'hr we°w..r bW4 n411Ndw;tl J'"'k VYP tlPWI^,"Q EUG]IINEERED TURF COMPONENT KT)i ' riia/ rr r r rr rr ////r/%%/ /////rrrrrr oia r %r%///""' ///%///////%%%/ ,,,,,,,,,, %////%%%/ riri t"ar,n' .W �+,ernNNart�'7,epe� NN A p rye m mt eu e Yarn Cml mr N,A Q i v e G;een Play Greyenn Ta" 'f are%Yeght ITotau Pn aturt vi,ZN tI ASTM,D5I f2',51 jsaenpre anaa,Y�d'� 220 ooa dw w V'.Y,7i��32 om.i sq.ye.q Terzile Rm!q,Eti"Of'ya!rrro ,dyu'rTNu1 iD225i5.. 15 Xtrs irno,.frn.. CDR, :nxtanre "A 7N!pllDku2G.i 1,500ib7. ,ltkN,slRVr 7erziiepmaeluu&::Mn7nv;4D,Mi) d457NvkilDA595 2.100MD,F16 .lbftlN•irLA51V) Unterf' Froct on between Clostr�eTuurf"UT arch'NwT:...Saa!ilke' ASIM ID5;,321 .22°,.rr .IpealN. E;anyihaeredTwu!ffFiberl.V Sta,hffis,Nr ASTINn4^G147 °,W%mat2rtradtemisifescmrpg0ixYWr,s.i� ler+.;rrd',o 'Sackin r Systa:rm'UV Stab fik y f Ewpttzed'II ASTNrih!G'1.:54 120 hest y ft.retail ned te!nside streunEth as 65M S,?w!rz rAnd Ted Cyeia:1,,,'TI`1r1Ni3LD �Princ&zed) „q,emd'yra mnry GTTW,I Wind Tunne, 120mah with,mrzw,..ulsl+,.of0.1.2ltddsf Nkairetara 6ndrucedlErzermn N11N645..9 IfndE1 terns 0 YN1 an 6:'�no.1Nhra PaemrfaX 's`r..eady State,Hy:drarafic Ovcmoppirg A57M D7277dO7236 5 ft:amertopping resulting in 29ftj5 wuedrucuty and �C','omeure7ur�'+dw1"Hymd!roSnr er1) 5.S;vfx-mez,rztrL-ztlmrIMzrn!irwj'smvaXnxarfV.,92 Fullscade Wave�..CMurrreuppirz TeztC'uunnu'za.re uw^rkrurne CrwM�ara.do State 11,6erz�it.^y YE'S.r Th""}rft nrtC2orrur Tumt"",mrNtl;hv H` d^o�'fndes" Wave Srrmul or F'ull'Sczwa WaveOvertopphr.Te:t Di3Z.d 2111 C,6or-a do Rzte r_fwwivea^zforq+ �D�zN�Ny dr, yd Iunlll5, O pvii,rnir 23da attrsl; FN�voCiar!dar'°drtoTnNX Mufiru� tr! .r WST'FaM C357�,kSTtw7 CYLI9'... Sdu nm!... SUPPLY IiN ORIM>A ION'(Standard,RINII U m ensiunsp rnul MM ft., ml ft:.. mi 1ft,r' MI, tldz kg. MiCToSpike^!f 40 1.0 23 T 750 229 17,250, 1,603 '°'3-,,9W, "^1,770' Tuirf Col,nl[3onient NNfA 6«oJA IS •4,,5 MO D1. 4,S 415 -1, 454. C"dwuneTuurf°da!rnd Fi fdroTurF"dprodurCs 1U!i PaterA No TM2 105 S',5,55 322,9163,.375„and 9,199257'NCamadd'ian P temtN o 2.663,17Q and ether Patents pendirsi,,,,, and traadr!nnarz'ir:sarr the pro,isertrof atarznedGewywrthhetiitsLLC, ILNarrrtdrmat;on.recorrmerrd'26u rzandz GrsRNon!xapypeaTrenEiinthas!fitemkurrconcair6mE,the!usr ci'r rumour p..radY.uets are Imazed'upon tezis arad data believed to ralualbne 3rwzwmr,°e7.tNuws ur ormataaun shoalld not be!used or re4ed upon for aKny spewcufk apgpHcan:xsn wthrmnut rrndepen!tl'lemt prvFes::ror.aZ exarrunnabon and,.wer focattkn of st3 acrunary,auuiPl:31bi6Xt^fd and alppkcandifity.Si ra time:actuua0 um by rthers'iz itre�yommd our c�ortrot,ro uuara!rnee or oarranty of rwrKry kind,expressed or,inmpfed s.,rtmradc bre 7WkIatemhewd Gem^s.KK'mhhrekies Mr a,:tax ziree weffect:of zu lh;euze or the re:Mlkz t3¢lbe oxiss fined near deez.. Watisushued C3eo;Nrthetd=LL.1C azsuumme.;zmy lialbiNity den comrectien herein !,.A.ny stafacmnent made,h&reir,mwe nertbe comupM;ete s!ir"ce ai:6 6arrk a'wr ranat;Nercn may!denuareasarymadeska&e when p2rbcuula!roa vkoeptror,2tl Londtuorzordrruumrsaxrzescw3torlderauzeofapipfiera `k iauawsumrgruemmrteantrtg.ulatneenz. Nvtfemg herein z to be co.rztrued are pe riszmn oras;a to uunf,,r gie an,,v patent. Page 3799 of 4165 Exhibit B for Bob Clark-Riddell Opinion Page 3800 of 4165 ppo-;M n1il c ..Ii Fore llC II /DTI RIAII. SARETY DATA & NI I T FOREVERLAWN PRODUCTS L CONTAINING POLYETHYLENE AND NYLON FIBERS...................................................................................................................................................................................................................................................................................................................................................................................................III A. 17LIVI I Chemical name: Polyethylene fibers/Nylon fibers with polyurethane backing Distributor: ForeverLawn, Inc.,4500 Bogan Ave. NE,Albuquerque, NM 87109 Emergency Telephone Number: 505.217.0177 3. IAZAI iDOU S IIVG iI.. I)I f,;:IN I S This product is considered to be a non-hazardous chemical under the Federal Occupational Safety and Health Administration Hazard Communication Standard 29CFR1910.1200 :.;. PI-lYSICIAI WA Melting Point: Polyethylene yarn 221'—249°F/105°—115°, Nylon yarn 428'—436°F/220°—230°C Specific Gravity: (H20=1)0.94 turf Appearances: Solid Odor: None II'1. LIIA AI'0I:WA Unusual fire and explosion hazards: None Flashpoint: >600°F Extinguishing Method: Water, Foam, Carbon Dioxide .. . .... ......... ...... ....... . . ............................................................... ......... ........ . . . . ..... .._ . .. . . ...... . ......... ...........F1reF'ghting Equipment: wearprotectivepreSSureseifcontainedbreathing apparatus. This product is resistant to damage and spreading of ignition in typical exposures such as lighted cigarette dropped on the surface. A::IIVILY1WA Stability: s.e...u.nd.er..f.ire...cond.iti n.s...td........veoff............................. Y ( ) Y Y p g hazardous roduct§ Dissolution: Softening or discoloration may occur with yarn,phenol,formic acid,other acidic e4 ..�au"[.2.5...bo1.�.w...E. .5.................................................................................................................................................................................................................................................................. p Hazardous Decomposition Products: Carbon Dioxide, Carbon Monoxide, Nitrogen Oxides,Traces of Hydrogen Cyanide H.a.Z.a.r .o.u.S...P o.l..... .e.r'.Z a.t.'.o.n...................................................... '.LL..not..o.c.c.u.r.................................................................................................................................................................................................................................................................................................. Y 1 A ..IhII -IIAZAIiI) IIN1-0I1IMA L 10 1N No health hazards are evident from MSDS documentation of constituents of this product,in the form presented when installed and used for its intended application as a synthetic turf product. G IN V II10IN MI..IV..I..AI.. DID POSAI... IIV1-M MAI I IN Environmental Impact: This product is in compliance with the EPA RCRA backing standard TCLP in US Federal register to CRF261 for all heavy metals on that list. Disposal Procedures: Safe for landfills; Can be processed and used as a combustible fuel where proper recycling facilities are available. I GAI.. DIS(.;IAII IL.h While the information set forth herein is believed to be accurate and complete as of the date hereof. ForeverLawn Inc. makes no warranty with respect thereto and disclaims all liability and release thereon. I DAI fl: 01 IcxSl!I.:: April 2,2007 4500 PEA{,MI �v('nII(, I., VNI(If W I(If W, r IWI, I K'(tOtW 505.21 r.0I It 1 I I M ';66.212.1�1:2;'a Page 3801 of 4165 Exhibit C for Bob Clark-Riddell Opinion Page 3802 of 4165 A ROMPETROL PETROCHEMICALS S.R.L(COMPANY OF ROMPETROL GROUP) APPROVAL DATE: DRESS: DJ226, KM 23,cad 905700, DISTRICT OF CONSTANTA 07/05/2008 0 ROMPUR0 Tel: +(40)241 506 868 Fax: +(40) 241 506 909 HGLWLRQ2UHY=425 WEB: http://petrochemicals.rompetrol.com EMAIL:office.petrochemicals@rompetrol.com MSDS -04: HDPE -MATERIAL SAFETY DATA SHEET 1. Product and company identification Product identification HDPE Manufacturer Rompetrol Petrochemicals S.R.L., company of Rompetrol Group DJ226, KM23, COD 905700, CONSTANTA, ROMANIA Tel: +(40) 241 506 868 Fax: +(40) 241 506 909 2. Composition/information on ingredients Chemical name: high-density polyethylene Synonyms: HDPE Composition: CAS # 0/0 m/m Polyethylene 9002-88-4 > 99 Additives - <1 Physical appearance: Translucent white pellets ,cake and powder. Contains slight traces of titanium,chlorine,aluminium. Various organic and inorganic additives may be incorporated. Potential hazard: Spilled material may present a slipping hazard. Following handling and packing various procedures, polyethylene dust may occur. Molten polymer may cause thermal burns. When burning without sufficient oxygen, it starts to release fumes that can contain carbon mono and dioxide, other oxidizing organic compounds. To minimize exposures, adequate room and ventilation should be provided. 3. Hazard identification Polyethylene is not classified as toxic, harmful, irritant or corrosive product. Eye contact: The product may content small particles that may cause eyes irritation, due to the mechanical action. Gaseous emissions released while burning may cause eyes irritation/redness. Skin contact: The product may content small particles that may cause irritation. The contact with molten polymer cause thermal burns. Ingestion: The product presents minimal toxicity. No hazard anticipated from swallowing incidental small amounts. Inhalation: In normal concentrations, polymer dust induces no health effects. The product is not volatile at room temperature. Gaseous emissions released while burning may cause nose and breathing tract irritation. 4. First aid measures Eye contact: Flush with plenty of water for 15 minutes. Remove large particles. In case the irritation persists, get medical attention. Skin contact: Flush with water and soap for several minutes. In case the irritation persists, get medical attention. Molten polymer - if molten material comes in contact with the skin, cool under ice water or a running stream of cold water. Cover the affected area with clean cotton sheeting or gauze. Do not attempt to remove the product from skin; it could result severe tissue damage. Get medical attention. Ingestion: not applicable Inhalation: In case typical symptoms occur, remove the victim to fresh air. Get medical attention if symptoms persist. Management quality system is certified according to EN ISO 9001:2000 , ISO 14001:2004 , OHSAS: 1999 by Germanischer Lloyd Certification GmbH. ©ROMPETROL PETROCHEMICALS S.R.L. Unauthorized reproduction by any means partial or total is prohibited MSDS-04: HDPE - MATERIAL SAFETY DATA SHEET Page 3803 of 4165 A ROMPETROL PETROCHEMICALS S.R.L(COMPANY OF ROMPETROL GROUP) APPROVAL DATE: DRESS: D3226, KM 23,cad 905700, DISTRICT OF CONSTANTA 07/05/2008 0 ROMPUR0 Tel: +(40)241 506 868 Fax: +(40) 241 506 909 HGLWLRQ2UHY=425 WEB: http://petrochemicals.rompetrol.com EMAIL:office.petrochemicals@rompetrol.com 5. Fire fighting measures Flashpoint: > 3401C Ignition conditions: Polyethylene is a combustible substance but under normal housekeeping conditions there is no risk of ignition. It not easily ignites but in contact with a flame it becomes soft, flows, ignites and 6'urnsuntil"""""e"""'fi."austi"n"g""(if it isn't stabilized with a flame retardant agent). In foil form ignites easily. Static e""I"e"""c"'f""r"i"c"'i"t"V...""""""m"""""a"""y""'""""""accumulate during handling/storage, and in certain conditions may constitute an ignition source source in case a high dust concentration exists. T"o""""x""ic"".....c"""om b."u"""s"'Pion...........r""o"'d ucfs......�a.rbon.....mon.o.....a........ p n loxl e, o er oxl Izing organic corppoun s. n case o burning without sufficient oxygen, a black, dense smoke is released Exti.n.......u.i.s.h.i.n............med.is.............S.ma.l.l.....fire. d..............Gne.m..ca.1.s........a.nd......carbo.n.....d oxide.....extin......u.iseers.......La.r.....e.....f res.......l.a.r.....e.... 9 9 dry 9 9 9 quantities of water spray. F..Ce....fi.......ht.'.n.................roced.u.CeS...........Kee...............e o......1.e.....awa................Lso.I ate....fi.le.....a.rea..........a.n d.....den...........U.CI n eces sa.r..........a.....a.c c 9 9 P P pp Y Y Y the area with water to localize the fire. Soak with water to cool and to avoid re-i nition. Proteeti"ve e ui ment for fire fi „ters Com lete fire fi htln clothin self-contained breathin equipment 9 p fighting 9, 9 apparatus. In case these are not available, fire extinguishing has to be done from a safe distance or a rotected location. Explosion hazard: The product as delivered has no explosive character. In case of accumulation, polymer dust may form explosive mixtures with the air. 6. Accidental release measures ........................................................................................................................................................................................................................................................................................................................,..................................................................................................................................................... Personne I protection: Remove unnecessary personnel from area. Limit access to the area. Spilled pellets may induce slipping hazard. Molten polymer presents thermal burns hazard in case of skin contact. Env ronment.........rotectio.n.....T1e....released....materi.a.l....wil°1....n.ot...he...d.1.scha.r.....ed...to...the... ...... ............................................................................................ P 9sewerage. Clean up: The contaminated area shall be swept and cleaned, and the residual material collected in dried and labeled containers. For disposal, see section 13. 7. Handling and storage Store polyethylene in dark, dry and well-ventilated area, away from all heat and ignition sources (sparks, open flames or hot surfaces, welding operations), combustible materials or incompatible substances (strong oxidizing agents). Temperature in the storage area shall not exceed 40°C. Avoid dust accumulation by frequent cleaning and suitable warehouses structure. Local exhaust ventilation is recommended for control of airborne dust, fumes and vapors, in enclosed areas. During handling and processing, polymer may charge electrostatic. Use only machines fitted with earth. S. Exposure control /personal protection Eyes and hands protection: Safety glasses for handling at ambient temperature. Thermal resistant gloves, arm protection and goggles/face shield in case of possible contact with molten product. Skin and body protection: In case of polymer handling or processing at elevated temperatures or in a molten state, adequate protective equipment will be used over the skin, to prevent contact. Respiratory protection: For most conditions, no special respiratory protection is necessary. When polymer is heated, general and local ventilation systems will be provided. Hygienic measures: Inside work areas, eating is not allowed. Normal clothing will be kept separately from work and protective equipment. 9. Physical and chemical properties Physical state: Pellets, powder Color: White translucent Management quality system is certified according to EN ISO 9001:2000 , ISO 14001:2004 , OHSAS: 1999 by Germanischer Lloyd Certification GmbH. ©ROMPETROL PETROCHEMICALS S.R.L. Unauthorized reproduction by any means partial or total is prohibited MSDS-04: HDPE - MATERIAL SAFETY DATA SHEET Page 3804 of 4165 A ROMPETROL PETROCHEMICALS S.R.L(COMPANY OF ROMPETROL GROUP) APPROVAL DATE: DRESS: D3226, KM 23,cad 905700, DISTRICT OF CONSTANTA 07/05/2008 0 ROMPUR0 Tel: +(40)241 506 868 Fax: +(40) 241 506 909 HGLWLRQ2UHY=425 WEB: http://petrochemicals.rompetrol.com EMAIL:office.petrochemicals@rompetrol.com Odor: No odor Melting temperature: 190- 210 °C Flash point: > 340 °C Density: 0.94 - 0.97 g/Cm3 Water solubility: Negligible 10. Stability and reactivity Chemical stability: Polyethylene pellets and cakes are normally stable. The product is not corrosive. Hazardous polymerization: No Conditions to avoid: Excessive temperatures (over 250 IQ or open flames. Materials to avoid: Strong oxidizing agents (chlorates, nitrates, peroxides, free halogens), organic solvents. Hazardous decomposition products: carbon mono and dioxide, other oxidizing organic products. 11. Toxicological information Acute toxicity: Polyethylene is considered non-toxic for animals, in case of powder inhalation or solid swallowing. Local effects: Unknown Sensibility: Unknown Chronic toxicity: Unknown Cancer hazard: Not established Maximum concentration accepted: Not regulated. According to Governmental Regulations HG 1218/6.09.2006 related to establishment of minimal health and safety work conditions for personnel protection against chemical agents, for polyethylene there are not regulations regarding the exposal limits of personnel . If toxic impurities or decomposition products appear, it has to take into consideration the smallest limits stipulated in local or national legislation. 12. Ecological information Movement: Soil- the product will not migrate. Degradation: The product is inert and it is not biodegradable. Surface photo degradation is expected with exposure to sunlight. Due to the negligible water solubility, it produces no effects on aquatic environment. Bioaccumulation: Not expected Ecotoxicity: Minimal, due to the negligible water solubility. Pellets may be harmful for birds and fish if swallowed. 13. Disposal considerations Spilled material removal: Sweep and clean contaminated area, collect residual material into dried, labeled containers. Wash the area with water. Wastes disposal: Polyethylene wastes are recyclable materials. It is preferably that production rejects and conversion wastes be recycled instead of being disposed. Disposal of any wastes should observe all national and local valid regulations. In this case should be provided the information regarding the delivered polyethylene : the additives content ,the fillers or other components which can affect the disposal process. Polyethylene can be disposed by burial (after the elimination of risk of soil contaminations) or controlled incineration, respecting valid regulations regarding gaseous or solid particles discharges. Due to the high heat value, incineration has to be done only in units designed to handle high heats of combustion. In case it is landfilled: polyethylene is inert, does not degrade quickly and does not release gases or other compounds known to pollute water resources. Management quality system is certified according to EN ISO 9001:2000 , ISO 14001:2004 , OHSAS: 1999 by Germanischer Lloyd Certification GmbH. ©ROMPETROL PETROCHEMICALS S.R.L. Unauthorized reproduction by any means partial or total is prohibited MSDS-04: HDPE - MATERIAL SAFETY DATA SHEET Page 3805 of 4165 A ROMPETROL PETROCHEMICALS S.R.L(COMPANY OF ROMPETROL GROUP) APPROVAL DATE: DRESS: D3226, KM 23,cad 905700, DISTRICT OF CONSTANTA 07/05/2008 0 ROMPUR0 Tel: +(40)241 506 868 Fax: +(40) 241 506 909 HGLWLRQ2UHY=425 WEB: http://petrochemicals.rompetrol.com EMAIL:office.petrochemicals@rompetrol.com 14. Transport information International settlements: not regulated by RID, ADR, DOT, IATA, ICAO, IMDG rules. Polyethylene pellets transport: CP4 euro pallets (1375 kg HDPE/pallet, distributed in polyethylene bags, containing each one 25 kg of product), big-bags- in truck or rail silo, maritime transport containers Polyethylene powder transport: polyethylene bags, containing each one 25 kg of product, big-bags- in truck or rail silo. Polyethylene cake transport : Bulk and big-bags- in truck or rail silo. 15. Regulatory information According valid Romanian legislation: Label: Hazard symbol: Not regulated R- phrases: Not regulated S - phrases: Not regulated According international legislation: To the best of Rompetrol Petrochemicals knowledge, the product contains no chemical subject to SARA/Title III, OSHA or CERCLA requirements. 16. Other information Rompetrol Petrochemicals does not recommend any company product for applications that involve human tissues or internal fluids contacts (regardless of the contact length of time), for cardiac devices, for medical device components that support human life, as well as for applications that have connections with human reproduction. The information relates only to the specific product described above and not to use of the product in combination with other materials. The information contained in this material has been compiled from sources that Rompetrol Petrochemicals considers reliable and accurate. However, the information is provided without any warranty, expressed or implied, regarding its correctness and completeness. Because use conditions and valid regulations may differ from one location to another and may change in time, the customer is responsible for deciding whether the product and the information in this document are suitable for his use and for ensuring that his workplace or disposal practices are in compliance with valid legal regulations. To determine applicability or effects of any law or regulation with respect to the product, user should consult his legal advisor or the appropriate government agency. Rompetrol Petrochemicals does not undertake to furnish advice on such matters. Rompetrol Petrochemicals does not assume nor authorize anyone to assume on Rompetrol Petrochemicals behalf any liability with the use of the information in this MSDS. The conditions or methods of handling, storage, use and disposal of the product are beyond our control and may be beyond our knowledge. For this, we do not assume responsibility for loss, damage, or expense arising out or connected with handling, storage, use or disposal of this product. Management quality system is certified according to EN ISO 9001:2000 , ISO 14001:2004 , OHSAS: 1999 by Germanischer Lloyd Certification GmbH. ©ROMPETROL PETROCHEMICALS S.R.L. Unauthorized reproduction by any means partial or total is prohibited MSDS-04: HDPE - MATERIAL SAFETY DATA SHEET Page 3806 of 4165 Exhibit D for Bob Clark-Riddell Opinion Page 3807 of 4165 TOXIC PFAS CHEMICALS FOUND IN ARTIFICIAL TURF 01 PIFAS CHEIMI[CALS HAVE been adefltlflSd 211 SyMthi-fiC t-Urf,acciz:dLng to lab,tests perttirmed on.sieveral samples of the ardfr2a]grass t1lax were shared w,ith The lhtencept.T1te presence of the chamira]p,jmem:biarsof a claag flmt has been Essociated,vwirhmultiple health prohlems,including cancer"adds-to gn.-tiving,concerm about the grass nsplacement that covats flt)11112p d3.01,.1SA:M1s cxf.'axreo in parlizu,schmo1z,professional spores madjums, and pracurefields around the U.S. In one sat of tees.the FEAS citemu cats were detected in The PlMtJC ba)Zk- ing crf tkvo samples af the turf.Ln.an?Dther,m ,vhich rbs.'!'Kadsm"of the.ar. tfficLel grass 1 vere analyzed,scientists mess,used dgnifcanz levelz offluo- nne,wluch ia,,teen ss an imdicatjon afthe preopnee,rif the chemicals AWre seeing une.i.,,plaLned levels offlucrine-based.tnmpounde irA all of the,eightsarnpLers of turf grass blades vve"ve looked a E,"'says jeffGaarhaft of the Ecolog7 Center,a nonprofir group based iM. Michigan that resn-A the turf Kades.The samples of the Ka&as that tezte+3 plositil,e for nu.041n."a I've.oSMade I'VY Mvir,djffe.rent companies,Shata,,Indus. titep and Turf Facto.y.y Direat Neither Turf Fa ctn-rr D rect ricr S It a,,,;Lndutrme R re?,pondaed.to Te que,?,ts fbrr orrnmem foc rhJ,E,,Ptm7� IF'awnMXOuz ccnjjpl, e C:1'1r:"!Ot Bad Chemiist�ry FRAS Ltiprnir_aLs afe used widely to halp,vvith the molding and extrus-Lons of plastic,acclording to a ifu F r,,,xaluu r ftmm th.e journal al"Vinyl,and_-�ddi- tive Technjology.'The 1areE[VPVMOn0f the ff)nthEtjC t:Uff' Wludl is prised. for its dunabiltt- is made iv;tth PIAFEIC PO VfneFS 03,8t are MdldrP!ld Jnto the shape of grass Mades vi„;hen in molten.farm. ','%93en you extvade plasma,it's like a rookie cutter,"explemed Graham peaflee,a professol Of flucleer p1tN sous at ffi;'Uh179:rviry vf:Notze Dams vtn has spent the laatftve year�s stiadying:11FAL rompounds VOithout the �FFAS,the rigi d. used to snake the v.Lrf durable clogged up the uudingmachines that:make the ruff,"So tbEy adde.d.:fluorochem.Jrals an?d, U974 Ir MME E-hrou�gh the extruders juat ffne"'�V'Vhde rJr1MEr CILEMICEIS Can also ease,the "the fluorintaed rotas x�jflc the best," taidPeaslea,v,,,ho,hkened the FRAS in ruffto ''"chemical llitrhhlkers'that are left ore,arfarm the d3an used as ingre.d.izents. Thes Syntlietk Turf'Counri]did notresp ond,no speri-fl,queatban.z about the preseareofPE-�S:in,turf.In an em. afled.reaponse to quenicns f.vom'The In- teTcepr,:Dan Bond, prezidFnt and cinefexeruti7o�a o firer)ofthe Synthetic Turf Ccunml,wrora,that"STC members are ar the fbirefrioar of'tso1.,inrj1O',�7,, that continuiausly impfaves daedunibilirv,peftorma:nce and efld)of dfe us.. p!s of syntherif narf Eys,,tern..' Page 3808 of 4165 Blades an�d Backin1g Bennett was also extremely disappointed that the PA investigated only the crum -rubber from the fields and not: the,plastic grass blades and the backing to which they"re -attached So she decided to, test the herself., This summer, Bennett and a friend went to asports field near her home in Massachusetts while new turfwas be�i�ng installed. She secured two, sam- ples and sent one of the turf pieces to a lab to,be analyzed for the p`res- ence of specific PFAS, chemicals. The tests on the turf came back positive for a short-chain PEAS chemical (known as 276,19-97-2) that was the subject of risk rel:Iall.t.s sent to, the EPA belhveen 2007, , and. 20,11AVIlile there is little published about the health ef fects on this chemical, ari�.:.. of those reports, submitted by DuPoint in 20,09, noted that some rats died after being exposed to the compaund noted that the chemical induced chromosomal aberrations in hamsters, ovar3r cells. Nevertheless, the chemical was approved for use and is pro- duced in large quantities, according to EPA records Bennett sent t1ke other turf piece to the Ecolop7Center, ivhich found that PEAS were also in the blades of the turf. The center used a new method known as a. "total flulorine" analysis. Using this technique, researchers can get a total signal for all of the PFAS that are present in products as op- posed to just the 30 or so that they are now.able to identifF, and test for in- dividually. The Ecology Center's Gearhart used the total fluorine test to determine that about half of the hundreds of carnmercial and residential carpeting samples it tested at the beginning of this year contained PTAS. And Pea- slee of Notre Dame, rho pioneered the total fluorine method, has used it to identiR,PFAS in fixid lag, cos r and in the protective geaf worn by firefighters, at of times over the drinking water lim- Page 3809 of 4165 IMscardedMirf MeamvhRe Bannett found another soum.e of tuf.f khe oriuld test 11 moils of tine used field.copering that urere s:itfi:ng alongside some bap of crumb rubber a shaft-7,vaIk fram a fipid in Franklin,Massachusetts.New tort'had been installed on the Franklin!fiksld in 2017,and this c1d turf had Inem mt- tM3,9 therE ever,Sance.So Sennett cut off'a pipce discarded turf and sent thatfhr Leotuag too ThEt sarnpla came bardi positi.ve for FFOS,a chemicai that:is no hanger to use but:has been fecognized as both. a hpaUl-k threat:and iAdespread ivatef,contaminant Sennett also nollpr.ted wazerffom.a vvetland just:f2el:from the rolls urfolld turf and found that PIPOS*au as imths v7ater as Tvell,suggeatEng anotherpos- sable,mray,that this and.other FFAS che.mirals may been getting unto weter. Anked about the d�LECEOdEd tuxf&ad the pcpsence GE FFOS in bot.h,the varf and nearby ivater, Franklin town administrater Jamae He.1 len gmd that he mrasn't w wpare that turf contaLmed.any dangerous chlemicah.HeIlen also said that he hadn't knomm that the ralls of old tuff had been left near the mpatef.,-DsyB Eeter, he apnt a photo af the splor%vhere the dLacarded turf had been,shimving that the turf ura a mm longef,there.Bennelt noticed the turf :rolls stashed near some trees about amile awg:y from whese it had last been du:mped,thpugh the begs of inffll%vere no lluager neap.bj.r In,an,email Hellen also,wrote,"The Tmorn ofFranklin Litis e%cellent fields that the=munity is verb proud off and are veer safe.The Tovwn mvests :millions to tampk�PeT d,,DllHXS=0 M81KIng OUtfl"FLIds the best in the state,al- mrays try rig to stay on the oxttmg edge of whEt tachnology,offers and to kmve the sfffaot fields fcr the pubUc."' Franklin,MassachuzettE,is hardly the oni.'I place strugghng vith the prob- Ism of 1-uDw to discard turf once it's no Longer an use.Tuff eventusily mrearR out — typEcalEy within,about a decade oaf nnatsllfffion, — and when ft does,it needs to,be replaced Belaveen 1,200 and 1,500:rmew tuT.ffields afe being installed across the muntry each year,arcordinq to estimates fkam Clue Evatheric,'Turf CouncH The in8l]and turf for a singis5eld ca:n 1,ru,eigh 4915,000 paunds,according to an as-dimate in rsczychngphidrAimes found on the S.,jinthietir.Turf Couin. rfl'a rvebsnte.That domcnent ocp1mm that as with an�.q req cip—reuse and reempeov effbft,the divemity of componentmateris.19 snag repsasent eco- momir,or technical challienges."'It also notes that,"the industry continues b0fEsearch and identtf dip-mon econotmucal and fESPOMSiblE Way ED PTO- cess aU tu:ff components such as turf planicz,mffllu s)and.un defl,kerment pads ghat need to be:removed,recycled and faused" Failures to,dispose of used turf have TiEcently grabbed public at'ten.bon in Eu:rlDp,e.The Dutch public television dommentary pmgmm Zembla ran an iuveati dipe.mprm-t Rhom6ng that several complanies Neel- .�,,claimed tore. cycle turf and have matead stacked at in tovrerin*ples And in N&vw�WF,at:. ter virf%vaa found discarded in thevmods risavvman.vays iaJune,the mirtnter of the 12:11vummpnt said he conpidenng nex rules to contral and cipian up the dumping of turf. Page 3810 of 4165 Althpug,h asked repeatedly,the.5,.�nthet:Lc TuffCcurtril did not provide the :name of any facaht�l,currently able to recycle turf in the U.S.But:at least l cirm-pang hated ca the trade graufa t,vebskedolas claim to do sc.',Ioe- get TectwjWaEoiei�a lnlerwmfi:anal,lfla:!,%vhxh:Ls based in British Columbia, l "a one-of-a-hnd salixtion ito recycle'100,�of your used artiflrdal tuff and turn ftinto useffil poat-canHumerproducts keepingit fram en.ding up in l landflIls,,vacant pmperdes and%oarehousiss, according the copy fbund in the onLme buyers'gutde and mernbership directory Of the:317n- thatir Tuff"Council. ARRsd about the canipany's ability to,repurpase.turE,,Target Technoiagies Internalasi did nort prmide caninneing evidence.Although E 2ingreplo,ft Evom internatLansiSOCCET gGIFEl body F1 FIA an the eflViro=Ental it.n.- pact of turf ftelds noted that "a full'cillar.,Eld-Loop process is Yet t�o be dEVel- loped,"'Nadia Minato,urho ansvlered the ph.tine at t1i rarget'Technclogia's Internatianal,aaid thao t�he carnpang has recycled every bit of"maybe 75 fields"in the pact Ewe years byeanding,the tart"to Malayna,where it is :made into"fence penarn and dtffef.aut kmde of lumber."' Il,"llhen asked ftyr details about Avhere exactlY in MaLllyma the Compaf:.js l the tuff and what heppenp uo!Lt vdien it ppts there,Mmatcl:rl that that infOrcIRILM IN29"propniatat7;."she then supplied the email ad- draes and phone number of Tlvomas Lem,a,vho she said handles the:"leg vrork"fair Target Technologies m M,aLayaia In,an, l sent by a th=d parvy,LEM IPSPIMdEd to a questLon about haw,exact- 13,the:campany is able to,recyc2e 100 percent of turfulith the stalbernent, This is one ofour'Trade Secrets.""Askad f6r,tli.,e liolawti.ion of the commpaqs's fteiLty and.any evidence that it actuallyrecycLes had there, Lam IIESPOMA- led that the plannsnat!open to the public and that 'Cur recyc led,,market.. able and envirionmentally safe,end product ts a pla-ptic fence post and thee*are avaUEble in the USA. Join Ouir Newsletter Dir%oimal,imparding-Fearless imnsillam,Uffiviered,W pu_ 1� rim,in ll,Vhether on.a field,dumped in.the woocLs,or sitting in a fs,cilit"il swuuag the advent of effective reqwchn1g,raisthods,,turfalmast carl ult mateL?fp rete&oes its PFAS chemicals,acclording to Peaflee The question vs:Doee it:c=e DFFIAnd I'm pretty con vinced from rnlj Pre- vions Tawa:rch on nputfl@s that it dmpg."he said.,'INIhen,you expose this,it.- bees to mechanical abTasiori,some of these chermcaLe i from the,fi- bers."For Pewiel the disci scar: of PEAS in turf is a troubling indicatmin What the chil are likely" pell other pmdurts flbrvhich they TAIEM Used SR aproveosing aid.""Turf ui ll the tip of tha jrebef,&It's gG- in,�tyD happen wherever thWfe using FRAS as an extragion sgent,,"said Patsies,wto expifeamd concem that widesprEaddumptng o�fthe turf in landfills,and ather plateo m.ay razuk in%l contaminsAjon. Fop athletes and their parents,the pfleolenre of FEAS in MaLffmay wise moTe ji-nmedixte concems about:exponarls to yet anpth er group of trou- bling C.112i tie fla PlWj'mjg on the fields."I'Ve jun dion"t knovv yet:how this might effect people,"'seed PEER'F,Bennett Fo:r hier,the unansureved queotions about FIFAS Ln turf and in thp,%vatpr neav vv-hpr�it ill durnplad should be met:oith caudool., c turf isnovo causing a visk,to es i one rvwiiic d:rjnkp 7,vate2^,,"said Bennett,vvluo dunks an,- ,pone pLantung to in- stall.tuzffields shnuld:reoomidier."If there's a potentiaHbrnsk,"aliessid. "Jual don't do it Page 3811 of 4165 Exhibit E for Bob Clark-Riddell Opinion Page 3812 of 4165 An official website of the United States government. Uniiled;:`Whale s, :minvil a onu r enlaall 11Pii a:nlea,liia:on Agency Search EPA.gov C VI'AM' t.0 PFAS Herne Basic Information on Basic. Information on IPIF .S PFAS ....................................................................................................................................................................... EPA Actions ........................................................................................................................................................................... What are PFAS? P.. A ......I..nograic ................................................................................... Per® and polluoroall substances (PA ) are a group of man-made Data and Tools chemicals that includes P OA, P OS, GenX9 and many ether chemicals. .............................................................................................................................. . . PFAS have been manufactured and used in a variety of industries State Information around the globe, including in the United States since the 1940s. P OA and PFOS have been the most extensively produced and studied o these chemicals. Both chemicals are very persistent in the environment and in the human body ® meaning they don't break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects. PFAS can be found in: • Food packaged in PA -containing materials, processed with equipment that used P A 9 or grown in P A ®contaminated soil or water. • Commercial household products, including stain® and water- repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams (a major source o groundwater contamination at airports and military bases where firefighting training occurs). • Workplace, including production facilities or industries (e.g., chrome plating, electronics manufacturing or oil recovery) that use PFAS. Page 3813 of 4165 • Drinking ter, typically localized and associated with a specific facility (e.g., manufacturer, landfill, wastewater treatment plant, firefighter training facility)o • Living r i 9 including fish, animals and humans, where PFAS have the ability to build up and persist over time. Certain PFAS chemicals are no longer manufactured in the United States as a result of phase outs including the .P F. ... � ll �f` g� � C t..in which eight major chemical manufacturers agreed to eliminate the use of P OA and P OA-related chemicals in their products and as emissions from their facilities. Although P OA and PFOS are no longer manufactured in the United States, they are still produced internationally and can be imported into the United States in consumer goods such as carpet, leather and apparel, textiles, paper and packaging, coatings, rubber and plastics. Top of' Page Why are PFAS important? PFAS are found in a pride range of consumer products that people use daily such as cookware, pizza boxes and stain repellents. Most people have been exposed to PAo Certain PFAS can accumulate and stay in the human body for long periods of time. There is evidence that exposure to PFAS can lead to adverse health outcomes in humans. The most® studied PFAS chemicals are P OA and P OS. Studies indicate that P OA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects in laboratory animals. Both chemicals have caused tumors in animals. The most consistent findings are increased cholesterol levels among exposed populations, with more limited findings related to: • lour infant birth weights, • effects on the immune system, • cancer (for P OA), and • thyroid hormone disruption (for P OS). What is the difference between Page 3814 of 4165 PFOAPFOS and GenX and other y replacement PFAS? Per® and polluoroll substances (PA ) are a group of man-made chemicals that have been in use since the 1409 and are (or have been) found in many consumer products like cookware, food packaging, and stain repellnto PFAS manufacturing and processing facilities, airports, and military installations that use firefighting foams are some of the main sources of P A o PFAS may be released into the air, soil, and water, including sources of drinking water. P OA and PFOS are the most studied PFAS chemicals and have been voluntarily phased out b industry, though they are still persistent in the environment. There are many other PA9 including GenX chemicals and PFBS in use throughout our economy. GenX is a trade name for a technology that is used to make high performance fluoropolymers (e.g., some nonstick coatings) without the use of perfluorooct noic acid (P OA). H PO dimer acid and its ammonium salt are the major chemicals associated with the GenX technology. GenX chemicals have been found in surface water, groundwater, finished drinking water, rainwater, and air emissions in some areas. As part of EPA's draft toxicity assessment, the agency has developed draft oral reference doses (Rf s) for GenX chemicals and PF Sa . ����rri r.noiir��M�.3.1 � ��t...IE'_.II[ ws:n ( iir, .l...t..tox� �ii�:.��4.a.ins .s niirrie��iri t (Yr Top of' Page How are people exposed to PFAS9. There are a variety of gays that people can be exposed to these chemicals and at different levels of exposure. For example, people can be exposed to lour levels of PFAS through food, which can become contaminated through: • Contaminated soil and grater used to grog the food, • Food packaging containing PA9 and • Equipment that used PFAS during food processing. Page 3815 of 4165 People can also be exposed to PFAS chemicals if they are released during normal use, biodegradation, or disposal of consumer products that contain PFAS. People may be exposed to PFAS used in commercially® treated products to make them stain® and water-repellent or nonstick. These goods include carpets, leather and apparel, textiles, paper and packaging materials, and non-stick cookware. People who work at PFAS production facilities, or facilities that manufacture goods made with PFAS, may be exposed in certain occupational settings or through contaminated air. Drinking water can be a source of exposure in communities where these chemicals have contaminated water supplies. Such contamination is typically localized and associated with a specific facility, for example, • an industrial facility where PFAS were produced or used to manufacture other products, or • an oil refinery, airfield or other location at which PFAS were used for firefighting. PFOA, PFOS, and GenX have been found in a number of drinking water systems due to localized contamination. You can view more information about exposures to PFAS through drinking water on our.Ijtitg � : Illyiil���� �llftli � rlii��n�.�iiii���s �����iir�Ili �IIF ��� iir��� .�IIi �IIF�. � ).t � e Top of' Page Axe there health effects from PFAS9. There is evidence that exposure to PFAS can lead to adverse health outcomes in humans. If humans, or animals, ingest PFAS (by eating or drinking food or water than contain PFAS), the PFAS are absorbed, and can accumulate in the body. PFAS stay in the human body for long periods of time. As a result, as people get exposed to PFAS from different sources over time, the level of PFAS in their bodies may increase to the point where they suffer from adverse health effects. Studies indicate that PFOA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects in laboratory animals. Both chemicals have caused tumors in animal studies. The most consistent findings from human epidemiology studies are increased Page 3816 of 4165 cholesterol levels among exposed populations, with more limited findings related to: • infant birth weights, • effects on the immune system, • cancer (for P OA), and • thyroid hormone disruption (for P OS). Top of' Page Q�.�iir���;aLl...L!s to ask a question, provide feedback, or report a problem. r r • EMISSIONS ROOM- . . . Mi ' Page 3817 of 4165 Exhibit F for Bob Clark-Riddell Opinion Page 3818 of 4165 Perfluorooctanoic acid(PFOA)and Perfluorooctanesulfonic acid(PFOS)I California State Water Resources Control Board _ COVID-19 and Water Boards Meetings -As a result of the COVID-19 emergency and the Governor's Executive Order N-33-20 non-essential file reviews are postponed and essential file reviews are by appointment only. - The COVID-19 emergency has resulted in the cancellation or postponement of some recent meetings of the Water Boards. The Water Boards are continuing day-to-day Work protecting public health, safety, and the environment. The Water Boards are conducting Board Meetings solely via remote;presence by video and teleconference. Members of the public Will be able to listen to and watch the meeting and comment if desired. Please follow our website or subscribe to an applicable Lyris list for your area of interest for further updates. IIIIIIIII � � IIIIIIIII IIIIIIIII IIIIIIIII �mli� IIIIIIIII III IIIIIIII 3oa"uui..r II a ul�lu uuaus II ii,iiu�lkdiigVVa teii,. Witeu.�'„ ' ��Ihits Il'Joflces VVa"uteii. Il�.�c w � � Vuualllr\ \\Va2\emu II"��.V�. Home e Dfinl<,ingWater t."eftlic I l finl<ungwaute PFt.A PFO II " iirooc"taiinoIIic acidIII �����������)eiir" iirooc"taii iinIIicIII III IIII I�I III IIII III�II III IIII�IIII III�I IIIIII IIII IIIIIIII II1P11I1 ! 1\/edia Release: Response Levels l.uuvaered 1lQ:r Water Systems Statewide as I)FA Investigation Continues es (02/06/20) „... )„ . d ... . , „. :: yIIII r �.1a. . ii�d.11y A I a. : d:iiu. ii� \J\l� d: Ill:: a \III..I r u III : �.I�. liu„ : III u. a III : a„fla.�u iroam�Illl�yll am�in(°:l u Ilyllla. a u„u a Illl yll SuIt)staincE III: III:: (02/06/20) Illyllll III u�.,�a.�lld.� III (.�Ik..ulliid., WatE.1ir, Systk,iiru III E.,u an(J &.AIk..)sd.and.,E.,s n(,.J Quaid:E:�u„, (a.�(.�Ily....SE:�1��d:E:�ii°�°ulkuE:�u„, ��"l�� .. u„�a°:l�:�u„��3) (02/06r20) News Release: State Water Board Updates Guidelines lour "I"es\ung and R.epoft ng I)FOA and I)FO As It f\.ariari4.sses Scope o l-)r:1b14:':1C1Cll (08/2,3/19) FactSheet: (.Tpdaute on Spfing 201O State Water Board Directives lot, Soil and Water Samples at l,ll<,ely 1)e .. and I)olV...Fluuoroa Ryl Substance (I)FAS) I lout pout" Locations (08/23/19) FactSheet: Frequently Asl<:ed Questions: Dfinl<:lnl Waiter Guidelines lot, I)FOA and I)>l O S (08/23/19) PFt:A and PFOS are fluorinated organic chemicals that are part of a larger group of chemicals referred to as per.. and poly llluuoroallkyl substances (PFA s). PFOS and PFt.A have been extensively produced and studied in the t.Inited Mates. These mamnade substances have been synthesized for water and lipid resistance. They have Page 3819 of 4165 https://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/PFOA PF0S.html[5/l3/2020 4:00:30 PM] Perfluorooctanoic acid(PFOA)and Perfluorooctanesulfonic acid(PFOS)I California State Water Resources Control Board been used extensively in consaurner products such as carpets, clothing, fabrics for furniture, paper packaging for food, and ether materials (e.g., cookware) designed to be waterproof, stain resistant or,non stick. In addition, they have been used in Fire retarding foarn and various industrial processes. People are exposed to PFOS and PFOA through food, food packaging, consuunrer products, house dust, and drinking water. Exposure through drinking water has become an increasing concern due to the tendency of PFASs to accumulate in groundwater. Such contamination is typically localized and associated with a specific facility, for example, an industrial facility where these chemicals were manufacture or used in other products, or airfield which used the chemicals for firefighting. Between 2000 Q and 2002,2, PFOS was voluntarily phased out of production in the tJ.S. by its primary manuufactuurer. Beginning in 2006 other manufacturers began to voluntarily linrit the number of ongoing uses. Since these chemicals have been used in an array of consaurner products, scientists have found PFOA and PFOS in the blood of nearly all people tested. According to the Center for Disease Control (CDC), blood levels of both PFOS and PFOA have steadily decreased in tJ.S. residents since l999 2000. In May 2016, the United States Environmental Protection Agency (U.S. EPA)issued a lifetime health advisory for PFOS and PFOA for drinking water, advising municipalities that they should notify their cuustorners of the presence of levels ever'70 parts per trillion (PPT) in community water supplies. tJ. S. llaPA recommended that the notification of cuustorners include information on the increased risk to health, especially for. susceptible populations. Based on the current available peer reviewed studies on laboratory aninrals and epidemiological evidence in huurnan populations, the tJ J.S. EPA released the following staternent: "These studies indicate that exposure to IFTOA airnd IFTOS oveir ceirla iirl levels may ireS 111 iiirn adverse health effects, iiirndl..idiiirng devellu"pirn eirnla.-aill effects to fetuses dL11Fii1rng piregirna.-aiirncy oir to Ibirea.-aistfed iiirnfa.-aiirts (e.g,, Ilu<w (birth weight, accelerated PLIbeirty, slkellela.-III erairiia tiioirs)p cairnceir (e.g,, testiiCUllairp Ikiidirney), Iliiveir enacts (e.g,p flSSUe dairnrua. ge), iimirmirne effects (e.g,p airntiilbu",dy piroc"UCtii0irn air d iimirnr UlFliity), tllhyiroiid effects airnd otherr effects (e.g,, cIlhu", lesteircfl cIIhairnges)." IIII..........evdIII Notification levels are nomeguulatory, health based advisory levels established for contaminants in drinking water for which maximum contarninant levels have not been established. Notification levels are established as precautionary measures for contaminants that may be considered candidates for establisN'nent ormaximuum contarninant levels but have not yet undergone or completed the regulatory standard setting process prescribed or the development of maxnunuum contaminant levels and are not drinking water standards. l lealth and Safety Code section l l 6271 delegates to the Division of Drinking ater's (DD ) Deputy Director the authority "to take action pursuant to Article ll," including the power,to issue a notification level (NL) pursuant t� .lt��tldal trul Safety (:Mu)(lt�. section 116455. Assembly 3r 756 (codr red as lt a H . an(:`l SafE)d:y ("Oo(JEl11 SEN"'ti(Dirl 1163178)provides for new reporting and notification requirements for detections of perfluuoroalkyl substances and poly Auuoroalkyl substances (collectively, PFA.S). In August 20l9, after further review, ll['iim Offu ce of IIII il,uflvliiilurroiniir nllfllufl l,iIIII Assess uimrleiiun't Page 3820 of 4165 https://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/PFOA PFOS.html[5/13/2020 4:00:30 PM] Perfluorooctanoic acid(PFOA)and Perfluorooctanesulfonic acid(PFOS)I California State Water Resources Control Board IIII llllp°IIII° �irrec urnurneiunclec IIMI S for PFOA and for PFOS be set at the lowest levels at whichthey can be reliably detected in drinking water using currently available and appropriate technologies. This recommendation is based on OEIItIA's development of reference levels intended to protect against cancer and ruoncancer effects, including effects on the liver and immune systerni. "ll"hese recommendations supersede the recommended interim NLs that OEI II IA provided to SWRCB in July 20 l 8. After-independent review of the available information on the risks, DDW established NLs at 6 5Illlnllll°n°°'i i" iur Illf°°null" and 5 1 Illlnllll"n°°'i°°Barr Illlnllll ' ll"���� levels are consistent whin O:ia,>[..It..>[A's recornnme ndatio ns. A. response level (RL) is set higher than a notification level and represents a rec<nrnnrnmruded the nnicai concentration level at which water, systernns consider taking a water, source out of service or provide treatment if that option is available to the nn. Starting in January 2020, water systernns that receive an order and detect levels of HAS substances that exceed their response level, shall take a water, source out of use, treat the water delivered, or provide public inotificatio n. Certain requirements and ruuu:,uurrurruuurudations apply to a water systernn if it serves customers drinking water containing a co ntarnniinaint greater, than its notification level. In addition to notification levels and pursuant to Health and Safety Code section l ll6455, DDW has lowered the response levels for PFOA and PFO Iltroinn '70 PPT cornnbined to 10 "i cur' Illlnllll�' arnd based on a running four quarter average. At the request of the Division of Drinking Water, 011aHHA is initiating the development of Public Health (:.meals (PIR:irs) for periiu orOurru:,kuinoic acid (I)F .) and periiuuoru:rrOu:,kurrne suull'onate (I)FOS) in dfinl<Jng water. PM is are concentrations oi`co ntainniinaints in drinking water, that pose no significant acute or chronic health risks. 011a:HH A establishes Ptt(::.ms, which are used as the health basis for the development of California's primary drinking water standards (Maximuurnn Contaminant Levels or CLs). Through the State Water Board's investigation, seven additional HAS chernnicais have been detected in multiple wells in California. The State Water Board has requested 01°]11 i .'s recommendation in developing notification levels for the following chernnicais: • perfiuuor-o exams suuilfonic acid (PFttx ) • perfiuuorobuutaine suuffonic acid (PUBS) • perfiuuorohexainoic acid (PFt..:.txA) • perfiuuor-o eptainoic acid (PFtt A) • perfiuuor-o no nainoic acid (PF A.) • perfiuuorodecainoic acid (PFDA.) • 4,8....dioxia....3t..:.t....perflouuroruonanoic acid (A.DONA) As additional HAS data become available, DDW may request front OEH HA to include additional HAS chernnicais. The State Water Board also requested that OEH -A include an evaluation of whether sornne of tine HAS chernnicais should be grouped together when being considered in a regulatory manor and if it is possible to consider the nn in subclasses leased on specific characteristics or features of the chernnicais. For more information regarding the impact of Assembly Bill '756 (as codified as i iuuuuiklirr and SaQtyr Code section i i 6378) on public water systerns, please refer to the skE)Ic�i QuE)1;tIiolr11; AI[� 756 Ill���irill�.�u��r`u���llll� 11 ail cl SuIt)staim lel II III:: AinaIllytilicall 111VIethods aindIIII ,,,, IIII III I IIII Page 3821 of 4165 https://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/PFOA PFOS.html[5/13/2020 4:00:30 PM] Perfluorooctanoic acid(PFOA)and Perfluorooctanesulfonic acid(PFOS)I California State Water Resources Control Board During the tNrd t..JnrreguuUated C"ontauninant Monntoring Ride (tJC' R3), t..JSEPA. required laboratories to use A..'.PAMethod 537 to analyze for- six per-fluorinated compounds. At that drite, the unnn rnu:urn reporfl.n.g levels established by t JSEPA. for PFOS and PFOA were 0.04 pg/L and 0.02 p g/L, respeedvely. The unnn rnuurn reporflng level is similar to the detecdon lirnrr t for purposes ofrepor-drig, (DLL), v✓Nch is established in re uuUadon for chernicals with rnaxnrnuurn contauninant levels. The DLL is the level at wUrr ch the DDW is confident about q uandficadon being reported. DD has ndendfied F1'P N4etho(1 7.0 as a validated anaUyficaU method fo deteedng pe fluuorinated compounds in drinking water. ,..1.hk method is capable of deteedrig the following l 8 pe fluuorinated compounds: STORET Code CHEMICAL Abbreviation C2801 If IEIIRII=1L.0 IIROIB U'T II IL aUILIFOI IC ACID f 11=11 a C23 2 If IE IIR II=1L.U II II- IE If T 11 11 C ACID f 11=11H Ip C2803 If IEIIRII=1L.0 II II- IEXAII IE aUILIFOI 11C ACID f 11=11-Ix a C23 4 If IEIIRII=1L.0 11 11 11 11 11C ACID F'IF C2805IPEIRIFLUOIROOCTYL SULIFOINIC ACID IPIFOS C2806IPEIRIFLUOIROOCTAINOIC ACID IPIFOA C23 7 III-IL THYL If IEIIRII=1L.0 II C'T II IL aUIL.11= 11 II IIII CIE'TIIC ACID INIE-LIFOSAA C23 3 III-II ILTHYL If IEIIRII=1L.0 II C'T II IL aUIL.11= 11 II IIII CIE'TIIC ININAell-OSAA C11ID C23 If IEIIRII=1L.0 II II IEC 11 llC ACID F'IFI C281 0 ll::'IEIIRII-ILUOIIROIDOIDIECAII IIC ACID IF1 IF ID o C2811 If IEIIRII=1L.0 II II- IL II IIC ACID f 11=1Hx C2812 If IEIIRII=ILU II 'TIE'TII II IEC 11 llC ACID F'IFT C2813 If IE IIRII=ILU II 'TII II ID IE C II II C ACID F11FTr1DA C2814 ll::'IEIIRII-ILUOIIROUII IDIECAII IIC ACID F11FUnA C 281 11- IL 11=IL U II If II If IL.IE II IE OXIDE D1111NABIR ACID1H IF -II C281 ._C IVY IL II IVY IL II IE CAII-IL U II -3- II II IE-1 a U IL IF II 11 C C II-If 11=3 11 a ACID Page 3822 of 4165 https://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/PFOA PFOS.html[5/13/2020 4:00:30 PM] Perfluorooctanoic acid(PFOA)and Perfluorooctanesulfonic acid(PFOS)I California State Water Resources Control Board C2317 11-CII-- IL. II IEIIC a 11-IL.0 II -3- UII II IEC II IE-1 -aU1L11- II IIC 11 CII- C ID If 11=3 U a C2313 4,3-IDII -311- -11::'IEIIRII-ILUOIIROII ll ll IIC ACID AIDONA IIII""'°IIII 111 iiii 1ngs 11in CaI11111-fainnilla1111 lihilin1killing Water Front 2013 to 2015j.JCMR3 required all large water systems (i.e., water, systems serving over l 0,000 people)to collect and analyze more than l2,000 drinking water samples for PFOS and PFOA. In addndon, some water systems serving less than l 0,000 people reported approx� rnately 400 drinking water results for PFOS and PFOA. ,ll hk occurrence data ndendfied 36 sources with PFOS detecdons and 32 sources with PFOA detecdons. Drinking water, systems are not CUTT'cntly required by stag; re uuUadons to rnontor for PFOA and/or PFO . Nevertheless, because of concerns about possible contaunu nation, some water systems have voluntarily chosen to sample their supplies for PFOA and PFOS. The OCCUTT'cnec data for tJ " 3 can Use accessed at: hiip�://www.uupug.gov/u:Uv✓uuu:,m f`/ou:;u:;u ff,(, (,(, data... u i ,I. ,, eunregulated uu rra C lluC llu 4 � , m, III � : r I r u � r IIII' a lllre Fact Sheet: �.1 u:U,��uu Oyu wing 2019 date� ate Board Directives for Soil and Water Samples a Lu�uUg ��u���... ,��uu:U pu:uly...I°Vuuu:umuuuuKyr] Substance (PEAS) .,.I lot Spot" Locations (08/23/19) FactSheet: Frequently sl<, 'd Questions: Dmunl<,in,; Water Guidelines for PFOA and PFO (08/23/19) Frequently sl<,ed Questions: Per and Poly fluuu:uruu,uKyr] Substances (PFAS) ',uter Monitofi g Labuuratomies Accredited to nalyr,uu for PFAs in Dfinl<,ing Waterby E'P Method 537 Revision I.I of E'PA Method 537.u Dfinl<,ing WaterSample Collection For P]�,R.and POL'Yj" f,[jrOlRIN I"l " VLI °'u1, [1]13 S]'A N 0." (P]1 ) uuurvwlrvupVing Guuuu:U,:uuuce Pmum afly Changes in the Revised Apfil 2019 PFAS Sampling Guidance P]]'A S Wat('fly„t(,M , f:uu,uVers ... A u,u1 30, 2019 PFAS Phased Investigation Approach I)mu,„(,n ,,tiio a "I'f,aining for Public at(ml y„tuuM , (Recording) ... mil u, 2019 PFAS Phased Investigation Approach Presentation For Public Water Syr��,t(,M , (Slides) Apfil u, 2019 IIII' ' hire 111 Californna Environmental Contaminant coring Prognant, 20 l 5, Potential Designated Chemicals: Perfluuauu"a:u,Kyr] and l olyrfluuauu"au,:Kyr] Substances (PFASs) (PDT'), State of CaUnfornu a, arch. Page 3823 of 4165 https://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/PFOA PFOS.html[5/13/2020 4:00:30 PM] Perfluorooctanoic acid(PFOA)and Perfluorooctanesulfonic acid(PFOS)I California State Water Resources Control Board Centers for Disease Q:"ontrof and Prevend on (CDC, 2009). Funuu th National Repomt on Huuurvwlrvuan E'Xposuure to J°Avironurvwlrvnu'untal Chuuurvwlrvniu:a]s. U.S. Du'upunnturvwlrvue nt of']Iowa lth and Huurruan Services, (PDF) tT EPA, 2014. f urvwlry erging (:"unurvutunrninunnts I)uunilujof':nunu:,tunurvuu'u uill'nnuni,uu (I)]+'() ) a n(I )uun lujof'oo(,tnurvuuniu:, f .t:,i( (PF A) (PDT'), t JS Environmental Protecdon Agency, arch. t JS EPA, 2016. DfinlJng WaterIlu'ualth Advisory Finn Perfluuuumuuuuu:,tane uulf'o uate (PllFOS), May, (PDF) t JS EPA, 2016. DfinlJng WaterI lealth Advisory Finn Perflunoroou:ta nOuc Acid (PFOA), May. (PDF) t JS EPA, 2016. FACT I & PFOS Drinl�Jng Water health Advisofies (PDF), t JS Environmental Protecdo n Agency, November. t JS Federal Rego ste , 20�6. LiFetim e I lu'ualth Advisories and I lealth Effects Suppoft Documents For PerfluuOnu:nunu:,tanoic Acid and Pu�rfluuu:uruuuuu,tuune uulf'onate, 81 Feu:L lll eg� 101, May 25, 2016, (PDF) (Page last updated 04/23/2020 � IDidinlMing Water Resources "alul'uuruuia I:_,akuoratory Drinking Water Supply I.-,'uuuu ing For Public Public Water System Intake Portal (C",I:_11)), Service Area I-ookuup W ater Sy stern,u Monitoring Schedules Clo ntamruiunannts in 11"001 InFormruatiu.uun For Public Regulations and L)ri nkinng Water Drinking Water Watch W ater Sy stern,u Statutes Clonn,uu.lidationn and Database I-ab I'o-State Portal _ Residential Water [auu�.ununuuuu.uun u.0 ` unuvuu,un f_a,lluuc�.mu.uun c Annual [a, unu,�.muu a u,a lly I:_,unau and ,D'reatm e nt L evnces CIOV I D-19 L)ri nki ng Reports (F a, R) C"u.upper Submittal SaFe L)riunki ng Water Water F_I nvuro nine mall Operator Clerd.i11catiu.uun _ Plan Igor Clalul'u.r nia �:."yanuuu nau,�.uuuua �:."yanuu.u�.u.uuuunu,u Laboratory L)ri nki ng Water I_I�' . L)ri nki ng Water in L)riunki ng Water Accreditation Program Permits Water Quality L ata Clo n,uuumner Clo nfideunce (F:'I AP) Perfluuu.uru.octannoic acid Water Recycling Reports (C"CIRs) F_'Ix nured L)ri nki ng Water (1)1_110A) annul LAUI]" CI Portal Laboratory Pcrfluuu.umu.uoc annesuull l'onnic L)ri nkinng Water Branch Accreditation actin (1)110S) L)u,utmu cts VUII Qfl fl Page 3824 of 4165 https://www.waterboards.ca.gov/drinking water/certlic/drinkingwater/PFOA PFOS.html[5/13/2020 4:00:30 PM] Exhibit G for Bob Clark-Riddell Opinion Page 3825 of 4165 r/ a I JU I II���//I�tll(�� ( III I�III✓ 1 I 1 // %�', l•/, I I/Ufir lf�ll fll/4l(� �1 Plfj II .I II I �1��J,"�/ 3 J 1f II II i;l I ;f1 '��(/1/"�'1r�i(II 1!! I ar r/i!/ I I 1 fl I�{ IIY�QI 1 ,� - // /i, J/ ///r// I+ �r/ ell�M 15,1,�`I'llII I 1 1 JA//; r" Ilk IIYI�jI/l/it j f� %I 1 jf IJ�(fl����i rl�llj'J'�III�II �al�,�y jy �J 01 ff I S TO ATE 1400fLE HOW.'PARK FAIN WELL Online N WL u II ii 49,007,95-001 �h�pr�kr�'d�r�amnurr���Nu�>I»if�I�WaY�' alrrl I,Ir /, „r �ovri E, I Page 3826 of 4165 Exhibit H for Bob Clark-Riddell Opinion Page 3827 of 4165 Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA MEMIMEMEMEMEMEME= E,H,,H,AC'.mVii 0 forinia Offce of rnviirinimrr mtat Hm*aVt7rn h9aaairetl tRssessdmein t L.II!Ill Viii°'D Ill°�i Illtall ..IFgol ics AbOLA II�Ii°oIposa oil 65 Il'Jews aid If...veilta II bilaily eai°`dl ll l G o osit � bps o ice o nnent to List PerN_�uu�.�r�.��.�c tan�.�ic Acid... iii iii ii 't "to 1 ...Jist ��� ii " iir " iii iii Acid iii ii " iir " ii iiiat Se The C'alifornna Environ nental Proteedon Agency's Office oflanviron nental Health Hazard Assessment (01:;l.. ..1A) intends to list pe luorooc tanoic acid (PFOA) and petfluorooctane sulfbnate (PFOS) as known to the state to cause reproduuedve toxicity under the Safe Drinking Water and 'Foxnc Enforcement Act of l98610l 1"hns action is being proposed under the aauthoritadve bodies lisdrig rnechannsnr� �. Chemical References Chemical Use Endpoints [CAS No.] Perfluorooctanoic US EPA PFOA and PFOS are Developmental acid (2016a,b) surfactants that have been toxicity [335-67-1] used in a variety of consumer products, including carpets, textiles, leather, non-stick Perfluorooctane US EPA cookware, and paper coatings sulfonate (2016c,d) used in food packaging, to confer stain, grease and water [1763-23-1] resistance. PFOA is used in the production of fluoropolymers. PFOA and PFOS are generated as degradation products of other Page 3828 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA perfluorinated compounds. Ilf;; ackground oin 1111stiling viliathe uth iir t tiii lbodilies m h iniii im: A_chenical must be listed under the Proposition 65 reguuladons when two condidons are met: 1. An authoritative body formally idendfies the chemical as causing reproductive toxicity pursuant to Title 27, Cal. Code of begs., secdon 25306(d)ll l 2 The evidence considered by the authoritative body meets the sufficiency criteria contained in secdon 25306(g). However, the chemical is not listed if scientifically valid data wNch were not considered by the authoritative body clearly establish that the sufficiency of evidence criteria were not niet( ecdon The t JS Environ nental Protecdon Agency (t JS EPA) is one of several instituudons designated as authoritative for the identificadon of chemicals as causing reproductive toxicity ( ecdon 25:. 06(l)). t bl[111lA_is the lead agency for Proposidon 65 implementadon. After an authoritative body has made a determinadon about a chemical, t::bE1111A_evaluates whether lusting under Proposidon 65 is required using the criteria contained in the regulations. Ilf;;;;;III°°IIIIII°°IAA's t iirmiiiinatiii in Pay /uu rooc tanoic acid (PFOA) and pay /uu rooc cane sulfbnate (PFOS) each nneet the criteria for listing as known to the state to cause reproduuctuve toxucIlty under.Proposidon 65, leased on findings of the t JS llaPA (20l6a,b,c,d), as outlined below. Ilf°°' iirm 111 Identil-ficatiloin and suffiii iii in f evidence -f air In 20 l6, t JS EPA released the docuunnents: rinking Water ea/t 7 A viso�y ( A) f6r Peffluu rooc tanoice Acid (PFOA)(LJS EPA, 20 1 bra) and ea/t 7 ffects Supportoceurr ent f6r Pay /uu rooc tanoice Acid(t JS EPA, 20 l 6b). In the for iter docuunnent, t JS ll::aPA developed a lifedrite drinking water HA for Ppt:A (l JS llaPA, 20 l bra)leased on a reference dose (RfD) derived front a developmental toxicity study in mice in which developmental toxicity was nnanifested as reduced ossiffcadon in proxinnal phalanges and accelerated puberty in males (t JS llaPA, 20 brie). Both documents contain conclusions about the developmental toxicity ofiPFt:A, referencing studies in which developmental toxicity results entirely or predominantly front prenatal exposure to the chemi cal. ecdon 25306(d)(l) provides three separate criteria, of which at least one must be niet in carder for the chemical to be formally identif"red. These reports and documents meet two of the formal identif"rcadon criteria in Section 25:.06(d)(l)because Ppt:A "is the subject of a report which is published by the authoritative body and which concludes that the chemical causes...reproduuctive toxicity" andbecause PFt:A "has otherwise been identified as causing ... reproductive toxicity by the authoritative body in a document that indicates that such idend fication is a Final action". ,..1."he latter criterion is met lay the developnrent by t JS EPA PA of a li fedrite drinking water HA for PFt:A leased on a reference dose (RfD) derived front developmental toxicity in mice. Further, Secdon 25306(d)O provides six addidonal criteria, of which at least one muust lee niet in carder for the chemical to be formally identified. In this case three criteria are niet because the report or docuunnent has been "published by the authoritative body in a Page 3829 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA puu licadon, such as, but not iintited to, the federal regseer..." (t..I EPA, 20 l 6a,b)l- and"reviewed by an advisory committee in a public rr eedrug, if a public meedng is required" (tI S EPA, 20 l bra); and"rnade subject to public review and comment prior to its issuance" (t JS EPA, 20l 6a). These reports and documents also meet the sufficiency of evidence criteria in Secdon 25306(g). Perfiruerut statenteiits in the t JS EPA reports docuurrrendrug the Agency's conclusions abouur developmental tox� city include the following: In rinking Water ea/tI7 ,advisory f6r Pay /uu rooc tanoic Acid(t JS EPA, 20 l bra): • "The t JS Environmental meal Protecdon Agency (EPA) is issuing a iilfedme drinking water Health Advisory (HA) for PFOA of 0.07 micrograms per liter(pg/L)based on a reference dose (R ) derived front a developmental tox� city study in mice- the crideai effects included reduced ossi:ficadon in proxx rnai phalanges and accelerated puberty in male pups following exposure during gestadon and iactadon." (p. 9) • "For PFOA, ...studies report developmental effects (survival, body weight changes, reduced ossification, delays in eye open ng, altered puberty, and retarded marnmary gland development) ... Overall, the tox� city studies available for PFOA demonstrate that the developing fetus is pardcuuiarly sensidve to PFOA induced tox�city." (p. 9) • "The effects that serve as the basis for the RfDs for both PFOA and PFOS are developmental endpoints (reduced ossificadon and accelerated puberty in males for PFOA and deer—eased pup • "The an rnai tox� eoiogy studies were used in the dose response assessment for PFOA. "ll"hese studies derrionstrated dose related effects on systernic and developmental endpoints in rriuuidpie species (monkeys, rats, mice) ..." (p. :.3) • ",..11..here are extensive human data front epidernioiO&ai data front the general popuuiadon as well as worker-cohorts. The epidentiolo y data provide strong support for the ideiid icadon of hazards observed following exposure to PFOA in the laboratory an rnai studies and human relevance." (p. 5i) • "Based on the consistency of the responses across the chronr c studies and those for reproductive and developmental endpoints, and with recogni don of the use of developmental toxx ;ity as the most sensidve endpoint, 0.00002 mg/Ike/day was selected as the RfD for PFOA. Tills value is based on the IIED d n7an quivalent ose for developmental effects (reduced ossi:ficadon in male and Ifernaie pups and accelerated puberty in male pups) front the Lau et al. (2006) study." (p. 54) • "The ii:Ifedme HA for PFOA is based on effects (reduced ossi:ficadon in male and Ifernaie pups and accelerated puberty in male pups) on the developing fetus resuldrig front exposures that occuur during gestation and iactadon. These developmental endpoints are the most proteedve for the population at large and are; effects that can carry ii:Ifedme consequences for a less than iilfcdme exposure." (p. 55) • "EPA's risk assessment guidelines reflect that, as a general matter, a single exposure to a developmental toxin at a crideai deers in development can produce an adverse effect (t.I EPA i 99l). In addidon, short term exposure to PFASs petfluoroalkYl substances can result in a body burden that persists for years and can increase with addidonai exposures. Thus, EPA recorrrrrrends that the iilfcdme t to for PFOA of 0.07 �tg/L apply to both short...:term (i.e., weeks to months) scenarios during pregnancy and iactadon, as well as to iii`cdirue....exposuure scenarios." (p. i 0) Page 3830 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA In ea/t 7 ffects Support ocurr ent f6r Perfluorooctanoic ACi (t..T S EPA, 20 l 6b): • "Developmental effects observed in aiinuiials include deer—eased survival, delayed eye opening and reduced ossification, skeletal defects, ..." (p. ES....2) • "Overall, the developmental and reproductive toxicity studies available for PFi:A derrionstrate that the developing fctuus is particularly sensitive to PFOA.....induuced toxicity." (p. ES....3) iblla,HHA has reviewed the studies or study descriptions cited by t JS llaPA (20l6a,b) in support of its formal identification of PFi.A as causing reproductive toxicity (developmental endpoint) relative to the criteria in Section 25: 06(g). Based on the PFOA HA (t JS llaPA, 20 l bra) and the supporting document(t JS llaPA, 20 l orb), and the studies cited in these documents, Of HHA Finds the criteria for listing PFOA through the authoritative bodies mechanism as causing reproductive toxicity (developmental endpoint) have been met. Ilf,,,° iirm 1 Identil-ficatiloin and suffiii iii in f evidence fair ; In 20l6, t JS EPA released the documents: rinking Water eatt7 ,advisory f6r Peffluu rooc cane Su fbnate (PFOS) (l.I EPA,PA, 20 l 6c) and ea/t 7 ffects Support oceurr ent f6r Perfluorooc cane Suffbnate (t JS EPA,PA, 20 l 6d). In the forriter document t JS llaPA developed a lifetime drinking water HA for PFOS (t JS llaPA, 20 l6c)based on a reference dose (RfD) derived front a developmental toxicity study in rats in which developmental toxicity was manifested as reduced body weight of pups on lactation day l (t JS EPA,PA, 20 l 6d). Both documents make conclusions abouur the developmental toxicity of PFOS, referencing studies in which prenatal exposure to the chernical results in developmental toxicity. Section 25306(d)(l) provides three separate criteria, of which at least one must be met in order for the chernical to be formally identifiied. These reports and documents meet two of the formal identifiication criteria in Section 25306(d)(l)because PFOS, "is the subject of a report which is published by the authoritative body and which concludes es that the chernical causes...reproduuctive toxicity" andbecause PFOS "has other-wise been identified as causing ... reproductive toxicity by the authoritative body in a document that indicates that such identification is a final action". ,..1."lie latter criterion is neat by the developrrient by t JS EPA of a lifetime drinking water HA for PFOS based on a reference dose (R ) derived front developmental toxicity in rats. Further, Section 25306(d)( ) provides six additional criteria, of which at least one must be met in order for the chernical to be formally identified. In this case three criteria are met because the report or document has been "published by the authoritative body in a publication, such as, but not lirnited to, the federal register..." (t JS llaPA, 20l6c,d)l- and"reviewed by an advisory committee in a public meeting, if public meeting is required" (t JS llaPA, 20l6c)l- and"made subject to public review and comment prior to its issuance" (t JS llaPA, 20 l6c). These reports and documents also meet the sufficiency of evidence criteria in Section 25306(g). Pertinent staternents in the t JS ll:iaPA reports documenting the Agency's conclusions abouur developmental toxicity include the following: In rinking Water ea/t 7 ,advisory f6r Peffluorooc cane Suffbnate (PFOS) (l.I EPA,PA, 20 l 6c): "The t JS Environmental Protection Agency (EPA) is issuing a lifetime drinking water Health advisory (HA) for PFOS of 0.07 micrograms per liter(lug/L)based on a reference dose (R1fD) derived front a developmental toxicity study in rats; the critical effect was deer—eased pup body weight Page 3831 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA following exposure during gestadon and iactadon." (p. l0) • "For PFOS, ... studies report developmental effects (deer—eased body weight, survival, and increased seruunt glucose levels and insulin resistance in adult offspring) ... Overall, the tox� city studies available for PFOS derrronstrate that the developing fctuus is parficuuiariy sensidve to PFOS induced tox� city." (P. ]l 0) • "Adverse effects observed following exposures to PFOA and PFOS are the sarne or similar, and include effects on lipids, birth weight, and arudbodies in huurnans...The effects serving as the basis for true f fDs for both PFOA and PFOS are developmental endpoints (e.g., reduced ossificadon and accelerated puberty in males for PFOA and deer-eased birth weight for PFOS...)" (p 5i) • "EPA believes the uncertainty in the chosen POD point of departure and the reliance on studies with seruunt data is rninu rnized because of the large and extensive database exarninng hazard, and the seiecdon of pup body weight as the crificai effect with lifetime implicadons at a NOA.lL L (0.i mg/kg/day) front the low end of the range of values evaluated." (p. 5i) • "The RfD is based on the HED derived front seruunt levels at the N bAEL front a developmental study in rats (Luuebker et al. 2005b). ...,.11 he selected RfD is based on the most sensidve endpoint, developmental effects (e.g., deer-eased pup body weight), to provide protecdon to the general popuuiadon and sensidve life stages." (p. 52) • "EPA's risk assess ent guuidelines reflect that, as a general smatter, a single exposure to a developmental toxin, at a crideai dme in development can produce an adverse effect(t JS EPA 1991). In addid on, short...:term exposure to PFASs pe luoro lkyl substances can result in a body burden that persists for years and can increase with addidonai exposures. Thus, EPA recorrrrrrends that the iilfedme t..:.tA for- PFOS of 0.07 �tg/L apply to both short turn (i.e., weeks to months) scenarios during pregnancy and iactadon, as well as to iifedme exposure scenarios." (p. l l) In ea/t/7 ffects Supportocurr ent for Pe ldjorooc cane Sulfbnate (PFOS) (t JS EPA, 20 l 6d): • "EPA derived a reference dose (RfD) for PFOS...base i on deer—eased neonatal rat body weight front the two gmeradon study by Luuebker et al. (2005b). ...Thc HED for effects on pup body weight in the two generadon study is supported by comparable values derived front the lowest observed adverse effect level for the sarne effect in the one generadon study and the NOAEL for effects seen in a developmental neuurotox� city study." (p. ES....2) • "At 3.2 mg/kg/day PFOS, oral dose in rats , goers were sign icant deer-eases in gestadon length and number ofimplantadon sites, and reduue;dons in litter size." (p. 3 63) "For pups only exposed prenatally, rr ortaiity was 91YO compared to 1. l IYO for those exposed during iactadon only. Reduucdons in pup body weights on LD i were observed in groups exposed both gestationaiiy and iactadonaiiy and in those with ,gestadonai exposure only." (p. 3.64) "Based on the consistency of the response and of the use of the most sensidve endpoint, developmental toxicity, as the crideai effect, the RID of0.00002 mg/Ike/day front Luuebker et al. (2005a) is selected as the RfD for PFOS. "l"leis RfD is derived front reduced pup body weight in the two....gcncradon study in rats." (p. gip....l 6) OEI It 1A. has reviewed the studies or study descriptions cited by the t JS EPA PA (20 l 6c,d) in support of its formal idendfication oi`PFOS as causing reproduuedve tox� city (developmental endpoint) relative to the Page 3832 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA criteria in Secdon 25306(g). Based on the PFOS HA (t JS EPA, 20 l 6c) and the suuppor-firng docuurnne nt(t..I EPA, 20 l 6d), and the studies cited in those docuurnne nts, OEI It 1A. Ernes the criteria for insdrng PFOS through the auuthoritadve bodies rnnecharnk nn as causing reproduuedve tox� city (developmental endpoint) have been rnnet. Ilf ,uuu t 'f iir o mmoi ts: O ;1..111A is requuesdrng comments as to whether PFOA and PFOS rrneet the criteria set forth in the Proposido n 65 re uuiado ns for authoritative bodies insdrngs. In order to be considered, IIf;;;.:111I°III III 11IA imuu st recelive commentsIby 6:00 Ip im oin Octolbeir 17, 2016 We encourage you. to submit comments via.e....mail, rather than in paper for t. Q:"onnnne nts transmitted by e....mail should be addressed to P65P ub ic.Comments((i),oeh ua.ca.gov with "NOIL PFOA and PFO " in the subject lime. Comments suuiarnnitted in paper form may be mailed, faxed, or delivered in person to the addresses below: : IMaI11111ing Addiress: Michelle Ramirez Office of E nvirornnrne ntai Health Hazard Assessment Sacramento, Caiiforrnia 95812....40 10 Ilf,,,° , ( i fir) 323....2265 Sacramento, Caiiforrnna 95814 Comments received during the public comment period will be posted on the OE111..:.1A.web site after the close of the comment period. Electronic Fries submitted should not have any form of erncrypdo n. If you.have any ui uesdo ns, please contact Michelle Ramirez at Michell .R imir :r(ir)oehha.ca.g v or, at (9 i fir) 445....6900. Comment II�I Irii 11 Extension ofthe Public Comment Petiod for the Notice of I me nt o L,ist: P rfl uorooctanoie Acid (P➢ (.)A) and P rfluuorooctarn Suuif°rnrnato (P➢ (.)S) ri Crnmme nt P rio Notice of]. utorut to t..,ist➢P rfluuorooctanoie Acid (P➢ () ) and P rfluuorooctarn Sunif°rnruat (P➢ (.)S) Ill,,,,,,.ii n III -to II�Iulbllic Comments PuIbIllic Comments on the IIIotli of IIint nt -to Il,,,,,.list IP11::::::'OA/IPjj::::::-OS Wednesday, Decernnber 7, 20 l 6 I1:::)o nlload Page 3833 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA 011,F1:.:.11lA'Is R.eslnonnse to Coninie'lits Nov 10, 2017 Connnien is by the Annierncan f liennisti f;,ouuriu;,nl uni he NO u;,�; of Intent to List]PF�.:5� and H. Dee 7, 20�15 oirnirneirnl Il.)y IKevlirn I1'.' Ii)(orn orn llhe Ilrnlernl to II.....li l II::::)II::::: erne II::::'II::::: S I1:::)eo T 2016 J°q ornments by Green Science p:::'0Hoy lu'I lulUle on the Intent to List F:)F::OA aril J.:::)p::::: 5 Ilea T 21 Cornirneints by Grimaldi II.....aw Officesfor III\4 Cornpainy orn llhe Ilrnlernl to Il.....li l II::::1II::::: I1:::)eo T 2016 Clornments by Grimaldi Law Officesfor 3M Company on the Intent to List F:11.:::: 5 Ilea T 21 oirnirneirnl Il.)y IN lliorn ll Council of ILextille Oirgainizatioins orn llhe Ilrnlernl to Il.....li l II::::1II:::: erne f:::)II:::::0 S I1:::)eo T 2016 °q ornments by National F e OUrce Defense ('10LIncil on the Intent to List F:)F::OA aril J.:::)p::::: 5 Ilea T 21 11I'..)owinlloads l.d Notice of Intent toList Perflulorooctannoic Acid (PFOA) annul Perflulorooctanne Suulfonnate (PFOS) Sep 15, 2015 Chemical 111::Refeireince ri Perlluuorooctanolc Acid (P () ) Perlluuorooctane mull°onato (P (.)S) 1::Rellated Notices ri Chemicals Listed Effective November 10, 2017 as Known to the Mato of Califor nla to Cause Reproductive Toxicity: Perlluuorooctanolc Acid (P (.)A) and Perlluuorooctane Suull°onato (P1 (.)S) oV , III,,,,,,, -tin etas and 111::Refeireinces Page 3834 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Notice of Intent to List Pertluorooctanoic Acid(PFOA)and Pertluorooctane Sulfonate(PFOS)I OEHHA lRefeireinces t JS Environmental Protcedo n Agency (t..I ll::PA, 2(.)l6a). Drinking Water Health Advisory for Per-fluuorooctarpoic Acid (PFOA). EPA Document Number: 822 R....l 6 005. May, DA fir. Available at: https://www.epa.gov/sites/production/files/2016 05/do uuments/pfoa health advisory final....plairu.pdf' t JS E nvnromine ntal Protecdo n Agency (t JS EPA, 20 l 6b). Health Effects Support Document for Per-fluuorooctarnoic Acid (PFOA). EPA Document Number: 822 R....l 6 003. May, 20l fir. Available at: https://www.epa.gov/sites/production/files/2016 05/do uume nts/pf a h sub firnal...plairn.pff t JS E nvnromine ntal Protecdo n Agency (t..T ll::PA, 2(.)l6c). Drinking Water Health Advisory for Perfluuorooctarne Suffonate (PFOS). EPA Document Number: 822...:R l 6....004. May, 20l fir. Available at: https://www.epa.gov/sites/production/files/2016 .05/do uume nts/pf° s health advisory final plain.pff t JS E nvnromine ntal Protecdo n Agency (t JS EPA, 20 l 6d). Health Effects Support Document for Perfluuorooctarne Suffonate (PFOS). EPA Document Number: 822...:R l 6....002. May, 20l fir. Available at: https://www.epa.gov/sites/production/files/2016 .05/do uume nts/h sub pf° s final plain.pff 11:::::ootinotes t [11 Commonly known as Proposido n 65, the Safe Drinking Water arnd 'Foxnc Enforcement Act of l986 is codified in I leaf th and Safety Code secdo on 25249.5 et seq. [2 See Health and Safety gods section 25249. (b) and Title 27, Cal. gods of Re s., section 25306. [3 All Further references are to secdo ns ofTitle 27 of the Cal. Code of Re uulado ns, unless otherwise stated. r a g rd s i� s g Page 3835 of 4165 https://oehha.ca.gov/proposition-65/crnr/notice-intent-list-pertluorooctanoic-acid-pfoa-and-pertluorooctane-sulfonate[5/13/2020 3:56:21 PM] Exhibit 3 Page 3836 of 4165 TRACKING MICROPLASTICS FROM ARTIFICIALFoOTBALLFIELDS TO STORMWATER SYSTEMS RAN L s thesis ntal Management and Physical Planning M20t9 30 tredi[se Page 3838 of 4165 ,art ent of Physical Geography Stockholm Department '� 1� University Preface This Master's thesis is Ran Li's degree project in Environmental Management and Physical Planning at the Department of Physical Geography, Stockholm University. The Master's thesis comprises 30 credits (one term of full-time studies). Cooperation with WSP Sverige AB. Supervisors have been Stefano Manzom at the Department of Physical Geography, Stockholm University, Lea Levi and Hjordis Steen at WSP Sverige AB. Examiner has been Salim Belyazid at the Department of Physical Geography, Stockholm University. The author is responsible for the contents of this thesis. Stockholm, 17 June 2019 Bjorn Gunnarson Vice Director of studies Page 3839 of 4165 Page 3840 of 4165 Abstract Microplastic pollution as a global environment problem in marine systems has substantially raised public concern in recent years. In 2016, the Swedish Environmental Protection Agency performed a study about potential sources and pathways of microplastics spreading to the marine environment. Microplastics from artificial turfs have been recognized as the second most important source of microplastic emission in Sweden. Between 1640 to 2460 tons per year of microplastics are estimated to be lost from artificial turfs. The lost microplastics are potentially transported to stormwater wells by runoff during rainfall events, eventually reaching marine environments. This study aims to track microplastics from artificial turfs to stormwater wells. Since the research of microplastic in stormwater has so far shown to be limited, field work and laboratory analysis have been developed in this study. Four artificial football fields located in Stockholm municipality were taken as sampling sites. First, pathways for microplastics from artificial turfs to stormwater were investigated. Second, the characteristics of microplastic granulates infill used in the football fields have been analyzed. Finally, stereo microscopy was used to visually identify microplastics in stormwater. The results showed that rainfall as a driving force of runoff process contributes to microplastics transport from artificial turfs to stormwater. During this transport process, a fraction of microplastics is captured by the soil. The size of microplastic granulates identified not only in stormwater but also in stormwater sediments is typically between 1 min to 3 mm. Due to its limitations, stereo microscopy is quite a subjective method for identifying microplastics and thus not suitable for quantitative analysis, since microplastic particles are comparable in size to and visually difficult to differentiate from organic particles co-occurring in stormwater. In order to accurately quantify the amounts of microplastics transported to stormwater systems from artificial turfs, it is necessary to develop new methods for microplastics identification. This study presented an attempt in this direction, highlights its limitations, and discusses more suitable alternatives. Key words: microplastics, artificial turfs, stormwater, runoff, rainfall, Sweden. Page 3841 of 4165 Acknowledgements First and foremost, I would like to thank my internal supervisor Stefano Manzom at the Department of Physical Geography for his professional guidance and creative suggestions. Thank you for encouraging me to overcome difficulties with your patience and efficient support. I would also like to give big thanks to my external supervisors Lea Levi and Hjordis Steen at WSP Sverige AB, for providing me with this interesting project and putting so much efforts in this research procedure. A special thank you to Veronika Kohler from Extrakta Strauss GmbH for analyzing samples and providing photos under microscopy in Germany. Deeply warm thank you to Lennart Nylund, it was a great pleasure to do field works with you no matter weekends or rainy days. Thank you Martina Hdttestran , for the possibility to use the laboratory and equipment support at the Department of Physical Geography. This master thesis would not be completed without support from companies and municipalities. I would like to thank WSP Sverige AB as a company for providing me with this master thesis possibility as well as financial and professional support, place and tools for executing the field work and my thesis. Thank you Stockholm Vatten och Avfall, Stockholm Stad, Stockholms Stad fastighetskontor, and Stockholms stad idrottsforyaltning, for giving me permission to take stormwater samples. Thank you ALS Scandinavia AB, for providing me 20 dark glass bottles for free and inviting me to laboratory visit. Last but not least, I would like to thank my family and dear friends. Thank you for supporting me to study abroad and always being there to listen my stress and calm me down. Without your support, I would not be so brave to do my master at Stockholm University. Thank you! Page 3842 of 4165 Table of Contents 1 Introduction...........................................................................................................I 1.1 Microplastics............................................................................................................ 2 1.1.1 Definition of microplastic................................................................................. 2 1.1.2 Sources of microplastics in Sweden................................................................. 2 1.1.3 Environmental impacts of microplastics........................................................... 3 1.2 Microplastics from artificial turfs............................................................................. 4 1.2.1 Characteristics and use of artificial turfs.......................................................... 4 1.2.2 Characteristics of microplastic granulates........................................................ 5 1.2.3 Loss of microplastics from artificial turfs......................................................... 6 1.3 Microplastics in stormwater..................................................................................... 7 1.4 Aim of the study....................................................................................................... 8 2 Materials and methods.........................................................................................8 2.1 Literature review...................................................................................................... 8 2.2 Sites description....................................................................................................... 9 2.2.1 Akeshovs IP...................................................................................................... 9 2.2.2 Bromstens IP....................................................................................................11 2.2.3 Spanga IP........................................................................................................ 12 2.2.4 Grimsta IP....................................................................................................... 14 2.3 Sample collection................................................................................................... 15 2.3.1 Granulate sampling......................................................................................... 15 2.3.2 Water sampling............................................................................................... 15 2.4 Sample preparation................................................................................................. 17 2.4.1 Filtration......................................................................................................... 17 2.4.2 Centrifugation................................................................................................. 18 2.5 Microplastic identification..................................................................................... 18 2.5.1 Visual analysis with stereo microscopy.......................................................... 18 2.5.2 Particle size analysis with Camsizer............................................................... 19 Page 3843 of 4165 3 Results..................................................................................................................20 3.1 Pathways for microplastics from artificial turfs to stormwater..............................20 3.2 Properties of microplastics from artificial football fields.......................................22 3.2.1 Size distribution of the granulates ..................................................................22 3.2.2 Shape properties of the granulates..................................................................26 3.2.3 Distribution of microplastic granulates in stormwater....................................26 3.3 Identification of microplastics in stormwater samples...........................................28 3.3.1 Water samples under stereo microscopy.........................................................28 3.3.2 Occurrence of microplastics in stormwater samples ......................................30 4 Discussion.............................................................................................................31 4.1 Uncertainties,knowledge gaps, and outlook for future work................................31 4.2 Methods for microplastics identification................................................................32 4.3 Mitigation measures of microplastics in stormwater..............................................33 5 Conclusions..........................................................................................................36 6 References............................................................................................................37 Page 3844 of 4165 Introduction Over the past half century, the production and application of plastics has exponentially increased, which has resulted in large amounts of plastic litter directly discharged in water bodies, particularly into sea(IVL, 2017). Plastic production in the world increased from 1.5 million tons in the 1950s to 335 million tons in 2016. Approximately 10% of the plastic produced annually ends discharged into the marine environment (Alimba & Faggio, 2019). Large pieces of plastic litter can further be degraded into very small pieces (less than 5 mm) of plastic, which are abundant in aquatic ecosystems. Small plastic particles in aquatic environments were first taken into consideration in the 1970s after quantities of small particles were discovered on the surface of the Sargasso Sea (Carpenter & Smith, 1972). The term microplastic was first introduced by Thompson et al. (2004)to describe small plastic particles collected from sediments around Plymouth, UK. Microplastics are now becoming recognized worldwide, with occurrence on the surface of open oceans, lakes, shorelines and sediments, often at exceptionally high concentrations. For instance, microplastics concentration in the main stream of the Yangtze River in China was reported to be up to 1.36 X 107 items per square kilometer and that so far is the highest value noted in the available literature (Zhang et al., 2015). In 2014, the accumulation of microplastics in world's ocean was estimated to 15 to 51 trillion particles, with a weight between 93 to 236 thousand metric tons (Sebille et al., 2015). Microplastic in the aquatic environment has attracted attention in recent years as a major global environmental concern. In an attempt to raise awareness, National Geographic magazine has published a series of articles on the microplastics crisis, including an eye-catching photo of a green-glowing plastic fragment ingested by a water flea (Royte, 2018). Land-based debris and human activities on the sea and ocean are considered as the main sources of plastic debris. In 2015, the Swedish Environmental Protection Agency has been assigned to identify Swedish sources of microplastics in the sea and propose measures for their reduction and handling. According to the study done by Swedish Environmental Institute IVL (2017), the largest emissions of microplastics in Sweden are released from road wear and abrasion of tires. The same study has reported artificial turfs as the second largest source of microplastics, and drew attention to further investigations of spreading of microplastics from artificial turfs. The use of artificial turfs as substitutes for nature-grass playgrounds has become more and more popular in the recent years. Loss of microplastics from artificial turfs was estimated to be around 1640-2460 tons per year, however the data about loads reaching the marine environment are scarce (IVL, 2017). Microplastics from artificial turfs are discharged to stormwater during precipitation events which can be then recognized as a pathway of transporting microplastics to marine environment, but the i Page 3845 of 4165 volumes are still estimated with high uncertainty (IVL, 2017). Stormwater as a pathway transfers microplastics further to aquatic environments having an influence on its organisms, ecosystems as well as human health. In order to better understand environmental impacts of microplastics from artificial turfs it is necessary to improve knowledge about pathways of their spreading and loss that occurs on their way to stormwater. This master thesis aims to investigate possible methods for tracking microplastics from artificial turfs to stormwater networks. 1.1 Microplastics 1.1.1 Definition of microplastic In general, microplastic is defined as any piece of plastic smaller than 5 mm to 1 µm in size along its longest dimension (Crawford & Quinn, 2017). The majority of materials in microplastics include polyethylene (PE), polypropylene (PP), Polyvinylchloride (PVC), polyethylene terephthalate (PET), polystyrene (PS), and polyamide (PA) (Bannick et al., 2019). Microplastics can be divided into two categories according to their origins. Primary microplastics are intentionally produced as raw materials which are used as abrasives in applications such as cosmetics, personal caring and cleaning products (Crawford & Quinn, 2017). Many primary microplastics are released directly into the aquatic environment. Secondary microplastics are unintentionally produced by deriving from large pieces of plastic debris (Crawford & Quinn, 2017). An important group of secondary microplastics can be formed through fragmentation of plastic items as a result of solar ultraviolet light and mechanical means such as tidal waves. They may also be produced during washing of synthetic clothes, construction works or maintenance of plastic items. Several studies on microplastic sources from Sweden and Norway have defined microplastics as a broad and general term without reference to a specific term (Sundt, et al., 2014 & IVL, 2017). Sundt et al. (2014) use term microplastic when referring to a wide range of particles including solid polymer particles and synthetic organic particles. In this study, `microplastic' is used as the broad definition including `microplastic products' that follows the same practice as in Sundt et al. (2014) and Magnusson et al. (2017). `Microplastics' in this study includes petroleum by-products, man-made polymers, as well as synthetic rubbers e.g. EPDM (Ethylene Propylene Diene Monomer), silicone and polyurethane (Sundt, et al., 2014). 1,1,2 Sources of microplastics in Sweden In order to reduce microplastics in the marine environment, in 2015 the Swedish Environmental Protection Agency was assigned to identify the sources and pathways of microplastics release in Swedish marine environments (IVL, 2017). Microplastics present in the sea come from various land and sea sources, and reach the sea through 2 Page 3846 of 4165 different pathways such as transport in natural water bodies, stormwater effluents, or as fragments from plastic litter. Microplastic derives from land-based sources contributes about 80% of the total microplastic emission, which is higher than that from sea-based sources (Andrady, 2011). According to the research from IVL Swedish Environmental Research Institute, the primary source of microplastics in Sweden derives from roads and tires, and the second from artificial turfs (IVL, 2017). Other sources of emission include industrial production and handling of plastic pellets, synthetics washing, boat hulls and littering. However, the contribution of the microplastic load in the sea is not only depending on the sources of emission but also on their pathways towards the sea. Microplastics can be retained in the pathways, for example microplastics produced by laundry will be retained by water treatment plants. Pathways of microplastics reaching Swedish coastal waters are via wind transport, stormwater, and water treatment plants as well as those that are directly discharged from ships (IVL, 2017). However, it is difficult to identify the percentage of microplastics transported to marine environment from different sources due to scarcity of quantitative data. Hence, currently the total microplastic discharged by Sweden to the sea cannot be estimated. 1®1®3 Environmental impacts of microplastics Considering the small size of microplastics,the risk of it being ingested by wild-life is high. Microplastics in the marine environment can be ingested passively or actively by a wide range of organisms from small invertebrates to large mammals. Schmid et al. (2018) found that 13.7% of 14 fish species from Amazon River estuary carries microplastics. Ingestion of microplastics affects life activities such as feeding, digestion and reproduction, and even leads to mortality directly by entanglement and choking, especially in fish in larval stage (ibis). Microplastics ingested by primary consumers can be accumulated through marine food webs and thus ingested by secondary consumers (do Sul & Costa, 2014) including humans. In addition, microplastics have the ability to concentrate a considerable amount of waterborne toxic pollutants, which exacerbates toxicological hazards to marine organisms along ingestions (Wang&Wang, 2018). Microplastics not only have an impact on organisms individually, but also effect ecosystems negatively at various levels. Microplastics accumulate in the sediments, where small organisms such as lugworm have non-selective feeding. Sediments with microplastics ingested by these small organisms could reduce the primary productivity and energetic reserves and thus have influence on benthic habitat structure (Guzzetti et al., 2018). Moreover, microplastics in marine environment have potential impact on nutrient cycling and ecosystem functioning. Zooplankton as a pivotal role in nutrient cycling is vulnerable to microplastics ingestion. Microplastics ingested by zooplanktons could decrease the density and velocity of their faecal pellets (Cole et al., 2016). The vertical movement of these faecal pellets is important 3 Page 3847 of 4165 for transportation of carbon, nutrients and organic matter, which are an important part of food production chain and carbon storage in oceans (Turner, 2015). It is now well-known that microplastics can be accumulated in different ecosystems and transferred within food webs (Carbery et al., 2018). With everything mentioned above it is indicative that high concentrations of microplastics pose risks for human food security. Animals of commercial interest such as fish and shrimp containing microplastics could be consumed by human as seafood, which is a potential route for human exposure to these particles (Earboza et al., 2018). Even though microplastics have been observed in several seafood products, the adverse effects of microplastics on human following ingestions are still not well understood (Wright & Kelly, 2017). Thus, subsequent long-term effects of microplastic on human health should be researched further. 1.2 Microplastics from artificial turfs 1.2.1 Characteristics and use of artificial turfs Artificial turfs are surfaces made of synthetic fibers with the characteristic of natural grass fields, and the technology has developed in four generations (Figure 1). In the late 1960's the first-generation artificial turfs with polyamide (nylon)began to be used as playing surfaces. The second-generation brought polypropylene straw and sand as a replacement applied from 1977 to 1995. With the development of artificial turfs, the third-generation artificial turfs with polyethylene and different fillings used today are more similar to natural grass (Twomey et al., 2018). The fourth-generation was introduced in 2006, which are made by polyethylene complex, sand and pad. Artificial turfs have the advantages of stability, safety and weather resistance. Hence artificial turfs are more and more popular to be used in football arenas, playgrounds and sports fields in recent years. /ffl %I' roirilil/l 0 11 4� , . 4 rf l (nylon)sewn Orr straw,different I mat fillings r Figure 1 The development of artificial turfs.(source: NTNU,2018) 4 Page 3848 of 4165 During the last ten years, the construction of artificial turf fields has increased in Sweden. According to IVL Swedish Environmental Research Institute there are approximately 1336 artificial turf fields in Sweden in 2016, in which 50% are artificial football fields with 7140 m2 for 11 players (IVL, 2017). The total area of artificial turf fields in Sweden is estimated to around 6,056,580 m2 (ibid). However, the number of new large artificial football fields in Sweden has recently been declining after the rapid development in last decades, while construction of small sports fields made of artificial turfs, with size of around 800 m2, is increasing rapidly in recent years (ibis). The life span of artificial turf is within a range of 8 to 15 years depending on the using frequency and maintenance (IVL, 2017). Components of artificial turfs could be degraded due to sunlight, water and wind, so artificial turfs reaching their life span should be disposed of. Landfilling as the default disposition for scrap rubbers has been banned in EU countries since 2006 (Cheng et al, 2014). At present, in some cases the spent rubber is used as fuel supplement for heating, although toxic emissions would be released during burning. However, a potential solution is to move life spanned artificial turfs to smaller football areas or recycle them for new artificial turfs. 1.2.2 Characteristics of microplastic granulates Artificial turfs generally consist of different layers of straws, rubber granulates and crushed stones as shown in Figure 2 (Fleming et al., 2015). The top layer of an artificial turf is made of straws with a mixture material of polypropylene (PP), polyamide 6, polyolefiner, and polyurethane (PUR) (Wredh, 2014). Straws with the length of 3-6 cm are typically filled with sands and rubber granulates, in order to make the straws stand up (IVL, 2017). Materials of rubber granulates vary depending on the design of the surface, and the size of granulates varies from 0.8 min to 3 mm (Bujak, 2018). There is a rubber pad layer below the straws, which promotes shock absorption and reduces the risk of injuries. The bottom layer is made of crushed stones which are underlain by soil. Prep Poe At>OVO illf oil � /� a fllb �� IIllI NGa �p //�i�/M 75 ubMr iI�ifik WleIr 91mi �k p'tm ar l; end I �Mr,�27% M. Asphalte fn c lam Wise i Figure 2 Structure of the third-generation artificial football field. (Fleming et al.,2015) 5 Page 3849 of 4165 Rubber is an important filling material for artificial turfs, and its main function is to provide shock absorption and desirable playing characteristics. The amount of rubber infill for an artificial turf depends on the size and function of the field, as well as the type of rubber. An 11-player artificial football field of 7881 m2 can contain 51 to 87 tons of rubber granulates (Magnusson, 2015). Traditional rubber fillers consist of three types of granulates, which are styrene butadiene rubber (SBR), thermoplastic elastomer (TPE) and ethylene propylene diene (EPDM). In recent years some other organic fillers such as cork and coconut have been used as alternatives (Fjordefalk, 2018). However, the applicability of these organic fillers is still in the investigating stage. SBR granulates are rubber from recycled tires, and they in the past they were the most popular filling material previously due to the low price and good properties (Buj ak, 2018). SBR granulates with the size of 0.5 to 2 mm are resistant to acid, alkali and alcohol. However, SBR has been found containing black carbon and zinc oxide which can cause environmental hazards as well as negative influences on human's health (Magnusson, 2015). Hence, other granulate materials such as EPDM and TPE are becoming more popular in recent years. EPDM is a kind of new manufactured industrial rubber with high resistance to sunlight and heat, which is particularly suitable for outdoor environments (Wredh, 2014). TPE is made of a mixture of plastic and rubber with the size of 0.5 to 4 mm. TPE is an environmentally friendly alternative as it can be recycled with melting and reforming(Gustafsson, 2017). 1,2,3 Lass of microplastics from artificial turfs Environmental risks associated with artificial turfs have been recognized in recent years. Wear and tear of the artificial turfs result in the loss of rubber infill. IVL estimated that artificial turfs in Sweden lose between 0.28 and 0.42 kg of rubber per in per year on average, amounting to a total of 1640-2460 tons of infilled granulates lost per year, which has therefore become the second source of microplastics after tire wear (IVL, 2017). Loss of infilled granulates can be removed via people's shoes and clothes, melting of snow cleared from the field, drainage, as well as through runoff Microplastics taken away by shoes and clothes may end up in the water treatment plants after washing the clothes. During snow melting, microplastics can spread outside the artificial turfs. In addition, microplastics lost from artificial turfs through the mentioned pathways are reaching stormwater, which is further reaching marine environments. However, it is uncertain how much of the lost microplastics are transported eventually by stormwater since data on microplastic content in stormwater are scarce. Filtration methods are now being applied, in order to capture microplastics lost from the artificial turfs and reaching the stormwater. Setting filter bags into stormwater wells is an effective way to capture granulates from artificial turfs. Filter bags are fixed with granulate traps, and held in the well by means of clamping rings and guide plates (Figure 3). Filter bags with 0.4 mm pores can capture particles larger than 0.4 6 Page 3850 of 4165 mm and at the same time water can flow through the filter bag to the well. Granulates captured by filter bags can be collected and returned to artificial turfs as reused infill, which could therefore reduce spread of most microplastics. Microplastics that are smaller than 0.4 mm cannot be captured by filter bags, and can still flow through pores into stormwater. M y I p 1 1 I f ti Figure 3 Granulate Trap with Filter Bag.(source: Unisport,2018) 1.3 Microplastics in stormwater Due to the different ways of microplastics loss including the loss from artificial turf fields, stormwater may accumulate numerous microplastic particles. The amount of microplastics present in stormwater depends on the design of artificial turfs and the availability of filtration appliances (Fjordefalk, 2018). Although some filtration systems have been introduced in several municipalities of Sweden, their effectiveness is still uncertain as the information of microplastics in stormwater is lacking. Therefore, increasing research on microplastic fate in stormwater is necessary to assess the spread of microplastics from artificial turfs as well as designing reasonable mitigation measures. In order to better understand environmental impacts of microplastics, a number of studies have focused on monitoring quantity and quality of microplastics in freshwater systems and aquatic environments during the last few years (Wang & Wang, 2018). However, studies on microplastics in stormwater are fewer than those in freshwater systems and aquatic environments. Recently, a few theoretical studies have assessed methods for microplastic identification in stormwater from artificial turfs. Methods of quantitative analysis of microplastics from artificial turfs are at the beginning stage of development, and applied projects are quite limited. IVL Swedish Environmental Agency has researched microplastics in stormwater sediments from artificial turfs in 2019. Stereo microscopy has been used as technique to quantify microplastics. Research Institutes of Sweden(RISE) started sampling stormwater with Page 3851 of 4165 pumps to identify microplastics from artificial turfs in 2019. ICP-MS, FT-IR and electron microscopy were used as techniques in their quantitative analysis. Practical research is less and quantitative estimation is still scarce. Hence, in this study, some practical measurements have been used to assess the occurrence of microplastics from artificial turfs reaching stormwater, in order to attain a better understanding of the spread of microplastics from artificial turfs and be able to adapt the filtration methods accordingly. 1.4 Aim of the study The aim of this study is to investigate the spread of microplastics generated by artificial football fields through stormwater systems. Lacking established protocols for microplastic identification and quantification, a research method to identify microplastics from artificial football fields to stormwater has been designed. Properties of microplastic granulates have been assessed and quantities of microplastic contents in different stormwater wells have been estimated. The research questions guiding this work were: 1) What are the characteristics of microplastic particles from artificial turfs? 2) How are microplastics transported from artificial turfs to stormwater? 3) Is it possible to identify microplastics in stormwater with inexpensive methods? Materials and methods In order to quantify microplastics that are spread from artificial football fields through stormwater systems, four 11-people artificial football fields in Stockholm municipality (Stockholm kommun, Sweden) were taken as sampling fields. Sampling wells were selected according to topology and distribution of stormwater pipes. Microplastics analysis method was developed with information obtained through literature review. Samples were first filtrated in laboratory at the department of Physical Geography at Stockholm University. Subsequently, the samples were sent to Retch Technology in Germany to identify microplastics under stereo microscopy and Camsizer P4. 2.1 Literature review In this study, the first step was to research reports published by different environmental organizations and institutions in order to evaluate the current level of understanding of microplastic pollutions caused by artificial turfs. The second step was to read through literature that focuses on analytical methods to identify microplastics. Literature review was performed using databases such as Science Direct, Google Scholar and Web of Science. The search keywords used were: `microplastics', `water', `marine environment', `artificial turfs', `environmental impact', `stormwater'. s Page 3852 of 4165 ®2 Sites description In this study, four artificial football fields in Stockholm municipality were taken as site fields for taking the samples and in order to study the loss of microplastics that reach stormwater network. All four measurement sites are 11-people football fields with an area of 7881 m2 and located in west of the capital Stockholm. Their names are: Akeshovs IP, Bromstens IP, Spanaga IP and Grimsta IP (Figure 4). Water samples were taken from downstream stormwater main holes. MIN y �n IR„ Figure 4 Location of four football fields equipped with artificial turf. (source: Google map) 2.2.1 Akeshovs IP Akeshovs artificial football field is located in the west of Stockholm, 9.3km far from Stockholm centre. Water samples were taken from stormwater wells which are located in the south-east of artificial football field with the lowest elevation 8.14 in(Figure 5). The two stormwater wells shown in (Figure 5, blue points) are connected to each other. Elevation and flooded areas of Akeshovs IP is shown in Figure 6. Runoff flows along with the terrain from north (8.62 m) to south (8.14 m). Microplastics from artificial football turf can be transported into stormwater wells by rainfall with the longest route extending over 193 in and the shortest route over 153 in(Figure 6). 9 Page 3853 of 4165 Ir y ' I I,Illlllllli� II,III lI ICI Ib `i'����y lull 11 III III I 6 VVV y p f Stormwater well t 11 rj 1 r r c, I. n, I Na, W tiI ,.,,,, , Figure 5 Satellite map of Akeshovs IP and location of stormwater wells. (source: Google map) l II Flow route �r III: 5 i ri�,i/ i;�� `�� ',� +m, �,.o,;,`•'tea � f����� RYrt�rcxtl�w[6 ar mae .. u �� N�n�na s4nx ua umouYnre awaro S �I wr t r Stormwater well Figure 6 Elevation and flooded areas of Akeshovs IP. (source: Scalgo Live) io Page 3854 of 4165 .2.2 Bromstens I Bromstens artificial football field was constructed in 2014, and is located in the north of Sundbyberg, south of Spanga IP. Next to the artificial football field is an 11-people natural grass field (Figure 7). The terrain descends from northeast (4.81 m) to southwest (3.65 m). Water samples were taken from two stormwater wells located in the southwest of the area. Microplastics from Bromstens IP could be transported to the stormwater wells downstream by runoff, over a grass-covered football field (Figure 7). The longest flow distance is 180 in and the shortest flow distance is I I I in. Elevation of the area and rainfall flow directions are shown in Figure 8. The presence of the grass field might lower microplastic impact at this site by capturing particles in runoff water. (Iq + I d�J f � f l 1�a r f Grass field u 1 W i Stormwater Figure 7 Satellite map of Bromsten IP and location of stormwater wells. (source: Google map) 11 Page 3855 of 4165 f gofN a Flow route � r ' [dnmatiarr i,, iM F uo+ancw�Y,�. ara i i rmwate Stowell ui r wel I 54M@CIE PTl9 RA✓f FircF"�"'adn Pe kt r]53 �fcwOn A firY � .,,. fir„✓ ��w;, p ` .,:. � Figure 8 Elevation and flooded areas of Bromsten IP. (source: Scalgo Live) 2,2,3 SpAnga IP Spanga artificial football turf was inaugurated in 1977 with TPE infilled ranging from 0.5 min to 2.7 mm. It is located in the north of Sundbyberg, and is a regional facility for football, bandy and athletics. The terrain of Spanga area descends from southwest to northeast. Water samples were taken from two stormwater wells located in the northeast of the area (Figure 9). One stormwater well is located in the northeast corner of artificial football field, and microplastic granulates could be observed flowing into this stormwater well directly (personal observation from the site visit). The other stormwater well is 60 in away from the well located in the northeast corner, which is the main well for the whole area. Microplastics from Spanga artificial football field is assumed to be accumulated into the stormwater well located in the corner, and then spread to the main stormwater well. Elevation map and the flow routes of microplastics from Spanga IP are shown in Figure 10. 12 Page 3856 of 4165 1 i f r ium uruuuuu�I;,r,up Figure 9 Satellite map of Spanga IP and location of stormwater wells. (source: Google map) hii Stormwater well 9 J Fk�dld Ale., rw,dvn 4e O iM rc. ,Tarr 9 , � ,real Flow route FA..Ac I t fl fT a�'�' t' M1���y(� 5YVGPoLi9§if tl�ll tn�Y P,krn,G47J AY 7 Figure 10 Elevation and flooded areas of Spanga IP. (source: Scalgo live) 13 Page 3857 of 4165 2.2.4 Grimsta IP Grimsta artificial football field is the home stadium of IF Brommapoikama located in Vallingby. The latest expansion took place between 2015 and 2017 with a total capacity of 5,000 people. The terrain of the area is high in the south and low in the north, with elevation of 19.89 in and 18.02 in respectively. Water samples were taken from one drainage water well located in the northeast corner of the football field, and two stormwater wells located further north with lower elevation 18.02 in (Figure 11). The northeast stormwater well is the well that collects water from the basin area. Microplastics from Grimsta artificial football field transport partially to the drainage well through underground pipes. Another part of microplastics transport is carried to stormwater wells by surface runoff. Elevation map and the flow routes of microplastics of Grimsta IP are shown in Figure 12. Stormwater well Drainage well g i �r r Figure 11 Satellite map of Grimsta IP and location of stormwater wells. (source: Google map) 14 Page 3858 of 4165 Stormwater well Drainage well ✓� � �, a� � l✓1i� ,f/, ay°�" /"PR °tip /M 0 y�� K+rmrlx lr 8 T Fkmd I A"ai "'A a m 1 ��� ..,� r'.ti✓� F I—Ac o I.Cd ra ti�a ry F QW Flow route ... i ern Figure 12 Elevation and flooded areas of Grimsta IP. (source: Scalgo live) 2.3 Sample collection 2,3,1 Granulate sampling To understand the physical properties of microplastic granulate in artificial turf fields, granulates were randomly collected from the four artificial turf fields. It is important to have in mind that granulates can be damaged by wear and tear of long-term use before entering a stormwater system, or can be degraded into smaller pieces in stormwater itself due to transport. Granulate samples from four sites were artificially fragmented by mortar for five minutes respectively in the laboratory to simulate the wear and tear process, in order to have a better understand of the properties between raw granulates and old granulates. In this study, eight granulate samples are analyzed in total (two for each field; one of raw material and one fragmented). 2,3,2 Water sampling Distribution of microplastics in water depends on their properties such as shape, size and densities, and environmental conditions such as water density and wind (Prata et al., 2019). The density of microplastic granulates varies between 0.9-1.53 g/cm3 (Bujak, 2018). Microplastics tend to float on the water surface even though particles have higher density, which happens because air bubbles attached to the particle surfaces can lift the particles to water surface (ibis). In this study, samples were taken from surface water with water dispenser, using 500 ml dark glass bottles as containers. 15 Page 3859 of 4165 Water samples were taken on the March 13th, March 25th and March 3I't respectively from all four sites and under different weather conditions between measuring dates. Each main hole was opened by removing the metal cover lid and expected for the pipe connections within it in order to detect the direction of the flow. Then the water sample was taken from the upstream flow directly from the pipe opening. For collecting water samples, a plastic bottle installed on a telescope stick (Figure 13) was used. Samples were stored in 500 ml dark glass bottles and transported to the laboratory. y, � � � 9 �° k Ire w• �l�i�Y, ° Figure 13 Lea Levi collecting stormwater. (photo by: Ran Li) Meteorological data was obtained from Swedish Meteorological and Hydrological Institute(SMHI). Weather conditions are reported in Table 1 (temperature data from Stockholm-Bromma station and precipitation data from Stockholm station). Precipitation data on March 31't was collected from WSP station located in Gullmarsplan, Stockholm due to data bias from SMHI. Table 1 Sampling date and time,and meteorological conditions Sample Time Temperature (°C) Precipitation(mm) Number of bottles 2019-03-1317:00 2.7 5.3 9 2019-03-25 7:00 1.8 0 12 2019-03-319:00 3.9 0.2 17 Water samples were taken from stormwater wells that are connected with the artificial turf fields. Two stormwater wells were selected in each of the artificial turf field. One sample per stormwater well were taken on March 13th, and two samples per well were 16 Page 3860 of 4165 taken on March 25th and 31't to avoid contingency. In addition, 100 ml drainage sample was taken in Grimsta on March 13th, and one sediment in the well was taken in Akeshov on March 30. No sample was taken from Akeshov on March 25th because the stormwater wells were dry. 2.4 Sample preparation 2.4.1 Filtration Filtration is an effective approach applied to separate microplastic particles from water samples by use of a filter medium through which only liquid can pass. The medium utilized for filtration includes a funnel, a filter paper and a vacuum system (Figure 14), where microplastic particles can be retained in the filter paper (Crawford & Quinn, 2017). The pore size of the filter paper used in this study is 10 µm, which means in this research microplastic particles with a range from 10 µm to 5 mm could detected. Any particles smaller than the lower limit of the mentioned range could not be detected and thus taken into consideration for analysis. Complications can happen during the filtration process since stormwater samples are contaminated with debris and soils that can clog the filter paper. However, because the volume of water sample is small in this study, risks of blockage is assumed to be avoided. After the filtration, curved mouth washing bottle was used to wash out particles from filter papers into 50 ml glass bottles. The samples were then dried in a dry-cabinet at 50°C to evaporate water. Here it is important to note that the main decomposition temperature of microplastic polymers is between 375 and 500°C (Dumichen et al., 2017). Under condition of 30 to 100°C, water can be evaporated while the polymers would not be degraded(ibis). Filter, per NOW* aIr her fn nnel 1111/,i/ Stopper AW Wator Figure 14 A vacuum filtration system. (source: Crawford&Quinn,2017) 17 Page 3861 of 4165 ® ®2 Centrifugation Sediments have been suggested as a long-term sink for microplastics (Van Cauwenberghe et al., 2015). Density separation is a common method to isolate microplastics from sediment samples. Centrifugation was applied in this study to separate microplastics from the sediment sample and in order to research distribution of microplastics in stormwater. Stormwater samples were filled into centrifuge tubes to do centrifugation with 4000 r/min rotating speed for 4 minutes. In addition, clean water with plastic granulates was centrifuged as blank control. After the centrifugation was done, the supernatant was extracted and dried in the dry-cabinet to obtain microplastic particles. 2.5 Microplastic identification 2,5,1 Visual analysis with stereo microscopy Stereo microscopy is a variant of optical microscopy designed for sample observation with low magnification. Stereo microscopy can provide three-dimensional erect and laterally-correct image, typically light reflect from the surface of object rather than transmit through it. A stereo microscopy produced by WILD Company with an enlargement up to 40x was used in study to evaluate type and appearance of microplastic particles from water samples (Figure 15). Veronika Kohler from Extrakta Strauss GmbH analyzed and took photos dried water samples with stereo microscopy at laboratory Extrakta Strauss GmbH in Germany. Samples were observed with 6.4x, 16x, and 40x magnification respectively. According to the scale ruler, particles with a size range between lmm to 5 mm were considered as microplastics. Symbols `o', `+', `++', `+++', `++++' were used to record the quantity estimation of microplastics in different samples. `o' represented zero microplastic were found. `+' represented that several scattered particles of microplastics can be identified in a photo. `++' represented that an amount of microplastics was concentrated in only one part of the photo. `+++' represented an amount of microplastics that was spread in several concentrated areas of the photo. `++++' represented a larger amount of microplastics that almost covered the whole photo. The same indexing was used to analyze the impurity contents of the samples. `o' represented the sample was clean. `+' represented that a few sand and soil were found, and the filter paper was grey (after filtration). `++' represented that an amount of black particles were mixing with microplastics, and the filter paper was black (after filtration). `+++'represented an amount of black particles and some fibers were found, and filter paper was black (after filtration). `++++' represented an amount of black particles and fibers were found, and filter paper was black (after filtration). is Page 3862 of 4165 Figure 15 Wild M3C Microscopy at Extrakta Strauss GmbH. (photo by:Veronika Kohler) 2,5,2 Particle size analysis with Camsizer In this study, Camsizer P4 was used to analyze the characteristic of microplastic granulates from different artificial turf fields. Camsizer P4 as one shown in the Figure 16 produced by Retsch GmbH is a particle sizer for analysis of particle size and particle size distribution in a defined sample. The principles of measurement are laser diffraction and dynamic image analysis. Camsizer P4 works with two cameras and makes 3D pictures for each particle while the sample falls through the case funnel. Eight granulate samples were analyzed with Camsizer P4 by Veronika Kohler at the laboratory Extrakta Strauss GmbH in Germany. Each sample was tested by three times in order to avoid bias and the data used for analysis was the median data. Now J l ; Figure 16 The Camsizer P4 dynamic image analyzer. (source: Retsch GmbH) 19 Page 3863 of 4165 Results 3.1 Pathwaysr microplastics fromartificial turfs to stor aer At the selected field sites, runoff due to rainfall is a main pathway transporting microplastics to stormwater wells during the summer and autumn, while in the spring microplastic accumulated in cleared snow can be transported by meltwater. Microplastics from artificial football fields spread following the terrain slope to stormwater wells during rainfall. Figure 17 shows the observation of microplastics spread from Akeshovs IP after rainfall. It can be seen that large amount of microplastics are spread on the road and soils surrounding Akeshovs IP due to rainfall-runoff process. These microplastics could be transported further downstream by runoff and stormwater system to stormwater wells. �, o / //%/JI�ii14N1JN✓� �/ f 'N. a iiiu IIIIII i i iVl�,`QYI i �I'�Ii I +'^"yFp^fir i B Figure 17 Microplastics spreading route from Akeshovs IP. In the photographs,microplastic is easily identified as the bright green fragments (photo by: Ran Li). Microplastics granulates were observed in close surroundings of stormwater wells, which also indicates that stormwater wells are one of the destinations to which microplastics are transported by runoff and where lost part of microplastics from artificial football fields can be found. The stormwater well located in the northeast of the Spanga artificial football field has the shortest straight distance to artificial football field among the four investigated sites, with a straight distance of 7 in (Figure 9). Figure 18 shows microplastics from Spanga IP transported to the nearest stormwater well. More microplastic granulates and plastic straws had been collected 20 Page 3864 of 4165 in this stormwater well compared to the farther one located 50 in away. Stormwater wells located close to the artificial football fields have higher likelihood of trapping and concentrate microplastics if the topography allows for the runoff to flow through that path. N, 2 I i 0 8 � Figure 18 Stormwater well located in Spanga IP collecting microplastics. (photo by: Ran Li) Snow clearance removes a large amount of microplastic granulates, which can be an indirect pathway of transporting microplastics to the stormwater system. The cleared snow is gathered around the artificial football field as shown in Figure 19. Microplastic granulates are left as snow melts. This `microplastic-rich snow'has been observed in Bromsten IP and Spanga IP during field work. Some of these microplastic granulates can spread to stormwater via snow melting and wind transport, but the quantity is uncertain. The remaining microplastic granulates are either recycled as waste or refilled into the artificial football field. Wind spreading is also one of pathway through which microplastics are transported to stormwater. The amount and exact paths of microplastics transported this way are challenging to observe and quantify. The movement distance and direction of microplastics depend on wind speed and direction. Wind can not only spread microplastics from artificial football fields to stormwater, but also move microplastics from surrounding soils to stormwater. In contrast, grass-covered surfaces trap microplastics as shown in Figure 17. 21 Page 3865 of 4165 o�f��11�w"Bll fl � f ��" ✓ � N���l)f Ir���"'/ �� y�� ,��'; 1"�;; d f r' p @ B i, Figure 19 The `microplastic-rich snow'located in Bromsten IP. (photo by: Ran Li) 3.2 Properties of microplastics from artificial football fields ®2®1 Size distribution of the granulates Table 2 shows the median size of granulates from four artificial sites. Median size of fragmented granulates is larger than raw granulates. Akeshov IP has the largest median size of granulates infill, and Spdnga IP has the smallest granulates infill. The size of raw granulates is similar comparing between Bromsten IP and Grimsta IR However, median size difference between raw granulates and fragmented granulates are largest in Grimsta IR The size difference is 792.3µm. Table 2 Median size of granulates of the each sample. Site Median size of raw granulates Median size of fragmented granulates (M) (M) Ake shov 215 5.3 8 2684.82 Bromsten 1702.92 1896.25 Spanga 1638.71 1659.86 Grimsta 1722.92 2515.22 22 Page 3866 of 4165 Figure 20 shows the size distribution of the granulates (G) from the four artificial football fields. Value P3 represents the percentage of granulates in different size intervals (blue bars), and value Q3 represents the cumulative sum in percentage (orange lines). All the detected granulates have diameters smaller than 5000 µm (5 mm), and can thus be defined as microplastics. Approximately 90% of the detected granulates are between 1 mm to 3 mm in size, and 1.3% are larger than 3 mm. Granulates with a size of 1 mm to 2 mm account for the highest proportion, especially in Spanga IP and Grimsta IP, where more than 60% of granulates are within that range. The size of granulates from Akeshovs IP is different compared to the other sites, with 32.4% granulates between 1 mm to 2 mm and 39.5% between 2.3 mm to 3 mm. All granulates from Spanga IP and Grimsta IP are less than 3 mm. Figure 21 shows the size distribution of the fragmented granulates (FG) that simulate wear under field conditions. The proportion of large granulates in the fragmented samples is higher than that of raw granulates, although all the granulates are less than 5 mm as well. Approximately 81% of the destroyed granulates are concentrated between 1 mm to 3 mm, and 14 % are between 3 mm to 5 mm. In Akeshovs IP, size of granulates between intervals of 1 mm to 2 mm, 2.5 mm to 3 mm, and 3.1 mm to 5 mm are account for more than 20% respectively. In the other three artificial turfs, granulates between 1 mm to 2 mm in size are dominant; however, the proportion of this size class is smaller compared to raw granulates. It should be noted that fragmented granulates between 3.1 mm to 5 mm are 28% more frequent than raw granulates from Grimsta IP. 23 Page 3867 of 4165 35% 100 30% 25% 20% CIO% rM 15% 40% mwAwAkeshov G P3 10% 20% Akeshov G Q3 0% 0% C5 b C66 ............... 100% 50% 4 0'/. 30% 40% 2 0% fflaunrl Rr omste n 6 P3 - .—BromstenG Q3 10% 201A Ov. . . . . . . 0% VM ............. ........................................................................................................................................................................................ Efti 60% 80% 50% 0% 40% 6 rM CL 3011. 4D% VMAIM Spa np G P3 20% 20% Sp6nga G Q3 10% 0% +,,,, v-r 0% ILM 70% I(K)% 60% 50% 40% 60% 30% 4 W. MINWIGOrnsta G P3 20 Grdnlwta G CV, 0% O.X tim Figure 20 Size distribution of granulates from four artificial turf sites. 24 Page 3868 of 4165 30% 100% fi 25% 80% 20% 60% 413% 10% wass Akeshov FG,P3 5% 2 OVo - --AkeshovFGQ3 0% -r 7, 7—T I—I I 1 0% ZZ ' po ZZ pm �$p 4§9 1 p�b 50% 100% 40% 80% 30% 610% en 20% 40% InevaBromster FIG P3 10% 20% Bromsten FIG Q3 0% 0% pm Rf ...............—....................................................................... 7 01X 100% yd 60% 80% 50% 40 60% cs en CL 30% - 40% gfiaw Spanga FG P3 20% ff - 20% Sp nga FIG Q3 10% 0% - 0% vm .................................. ..................................................................... VK 80% 25% 20% 60% 15% 40% 1 CrInista FIG P3 10% 20 ,----Grjmstj FIG Q3 5% 0% 1,F11. M 0% 'p & pm N N b L�b Q� p Figure 21 Size distribution of fragmented granulates from four artificial turf sites. 25 Page 3869 of 4165 .2.2 Shape properties aft e granulates Shape of the granulates from artificial football fields is between rectangular and spherical. Figure 22 shows the average spherical index of the granulates, and b/13 is the shape parameter of the granulates. If b/13 equals to one it means that the granulates in one size range are perfectly spherical. On the other hand, if b/13 equals zero it means that the granulates look different from different angles, for example cubic or triangle shape The median spherical index of granulates from four artificial football fields is between 0.586 to 0.655, which means the shape of granulates is comparable to a sphere, but it also shows some edges. Granulates from Spanga IP are more spherical than those from the other sites. The spherical index of fragmented granulates is higher than that of raw granulates, except from Akeshov IP. Granulates from Akeshov IP became more angular after wear, unlike granulates from the other three artificial turfs that became more spherical. Spkgo F �� �� ���� i IN� 0.642 sp5nga �i1 � ��� 4� iC � �U11 0.640 Grimsta F �dt��Vl ��n 595 cr msta o� UD1 Si 0.586 0rotpsten FG f� 2 it iWN1 � 1R 0.62 6 x b/13 Broriste�u �f�4iil kUiC0�1 Pgl "'21� 'kl U.6p Akeshov FG 0.597 eshow f5 UN 655 0,540 0,560 0.560 0.600 0,620 0.640 0,660 0.680 Figure 22 Median spherical index of granulates from different sites and subjected to either no treatment(F)or simulated tear and wear(FG). 3.2.3 Distribution of microplastic granulates in stormwater In this study, although water samples were taken directly from the flow from a pipe opening into the body of a main hole, there could still be some sediment mixed with stormwater caught within a sample. In order to investigate distribution of microplastics in stormwater, experiments were simulated in the lab. Distribution of microplastic granulates in stormwater under different conditions shows in Figure 23. Microplastic granulates are floating on the surface of water when they flow into the water as the Figure 23a shows. In Figure 23b illustrates how using centrifugation to simulate the shaking process, microplastic granulates accumulated on the bottom. However, if microplastic granulates were added into the stormwater 26 Page 3870 of 4165 with sediment, mixed sediments and microplastic granulates can be distributed both on the surface as well as in the bottom, as the Figure 23c shows. The simulation experiments illustrate that these microplastic granulates can exist both on the surface of stormwater and in the sediment of stormwater wells. These microplastics could be transported into surface of stormwater by rainfall, and during the heavy rain and wind these microplastics would be mixed into sediments. Hence, once microplastic granulates reach the stormwater wells, they are distributed between the stormwater surface and in the sediments. Since the density of microplastics is similar to organic materials as well as water, separation of microplastics from stormwater is difficult. / t4;,1�r x.y ;' llyJ�yME IF) 7 Figure 23 Distribution of granulates in stormwater under different conditions. a) Microplastics granulates concentrated on the top of stormwater(without centrifugation). b) Microplastics granulates concentrated at the bottom of stormwater(after centrifugation). c) Micriplastics granulates present both on the top and at the bottom in stormwater sediments (after centrifugation). 27 Page 3871 of 4165 3.3 Identification of miero las °es in stormwater samples 3.3.1 Water samples under stereo microscopy Figure 24 shows dried stormwater samples under naked eyes. After filtration, particles with size larger than 10 µm remain in samples including microplastics, sands, soils, plastic straws and other unknown organic materials. However, the amount of microplastic, sediments and other materials in samples from different sites is different. For instance, microplastic granulates and artificial grass straws can be seen by naked eyes in Spanga samples, but Grimsta samples are clean and nothing can be seen. if r I + it % b) , Figure 24 Dried stormwater samples under naked eyes.(photo by:Veronika Kohler) a)Spanga sample (3-31); b) Grimsta sample (3-31) Figure 25 shows the pictures of a water sample under stereo microscopy with different magnification. Greenish particles are found under microscopy, which could be identified as microplastics subjectively. However, stereo microscopy cannot identify microplastics quantitatively since large amount of fibrous material (possibly roots) and soil are mixed and intertwined with microplastics. Soil and sand with microplastic dimensions could be easily be mistaken as microplastics. Fibrous materials are found in all analysed water samples, though their origin is unknown. The presence of these fibres has influenced the identification of microplastics. 2s Page 3872 of 4165 Nd Lr� I�a a)6AX t V � r �;� pl � I � ➢ ;J, 4 b)16X ti / r rr c140X Figure 25 Spanga sample(3-31) under stereo microscopy with different magnification(6.4x,16x and 40x). (photo by:Veronika Kohler) 29 Page 3873 of 4165 3.3.2 Occurrence of microplastics in stormwater samples According to the pictures of water samples under microscopy, Table 3 and Table 4 indicate microplastic content and impurity in different stormwater samples respectively. `SW1' is the stormwater well closer to the artificial turf and `SW2'is the stormwater well further away. `+' is used to indicate the microplastic and impurity content in samples (additional `+' allow a qualitative ranking of the samples); `o' means zero microplastic or zero impurity in samples. Microplastic content is similar to impurity content. Stormwater wells with high impurity content have also higher likelihood to have more microplastics. In the study of eight stormwater wells, stormwater well 1 from Spanga IP (located in the northeast) has the highest microplastic content, as well as stormwater with highest impurity based on my visual identification approach. Stormwater wells located close to the artificial football fields are more likely to contain high microplastic content, as found in samples from Spanga IP and Grimsta IP (Table 3). Microplastic contents are similar for the two stormwater wells in Akeshovs IP and Bromsten IP, possibly because the two stormwater wells are located close to each other (distances are 5 in and 30 in respectively). In addition, microplastic content and impurity content could be influenced by precipitation. It has rained on March the 13th with 5.2 min (Table 1) and stormwater wells in Bromsten IP contained more microplastics on that day compared with the other days (Table 3). On March 25th there was no water in stormwater wells from Akeshovs IP. On March the 31't there was a small rain event (0.2 mm); hence, the results are almost the same as on March 25th Compared to stormwater wells, the content of microplastics is higher in drainage wells. Drainage wells located in Grimsta IP shows greenish particles mixed with sediments, which are more frequent than in the stormwater wells. Furthermore, in the case of the same stormwater well sediments contain more microplastics than surface water. Table 3 Microplastic Content Index in Stormwater Samples Table 4 Impurity Content Index in Stormwater Samples / 10 ++ ++ ++ + 0 m�.,v v v v 30 Page 3874 of 4165 Discussion 4.1 Uncertainties, knowledge gaps, and outlookr future work In this study, the evaluation of microplastics in stormwater was quite limited and was done under several assumptions due to difficulties in extracting microplastics from stormwater and separation from suspended materials (mineral or organic). The size of microplastic granulates from artificial football fields are mainly between 1 min to 3 mm. However, there are soil particles in the same size range as microplastics (e.g., sand grains), which could be visually identified as microplastics by mistake. During filtration, filter paper with 10 µm mesh could extract all the particles larger than 10 µm, including organic and mineral fragments of various origin, which makes identification of microplastics with microscopy even more challenging and demanding. Nowadays, filtration and density separation are commonly used as separation method, but it is challenging to operate them in practice due to the fact that the density of microplastics is similar to the density of stormwater and that there are organic particles similar to microplastics that can be found in the samples. Moreover, microplastics can be easily stuck within sediments in stormwater. Therefore, new techniques of separating microplastics from stormwater based on the unique characteristics of microplastics need to be developed. The source of microplastics in stormwater added uncertainty in this study. Although stormwater wells were selected based on the location, topography and data about water system around artificial football fields, these fields are not the only potential source of microplastics. Microplastics could also originate from other sources such as road wear and abrasion of tires. Microplastics found in stormwater samples have possibility to be transported by runoff also from nearby roads. Therefore, unless microplastics in the artificial turfs are marked or unambiguously identified, microplastics collected in stormwater could have originated from other sources. Transportation of the samples from the field to a laboratory can also increase the uncertainties of the results. A part of microplastics might be lost during the filtration process, because microplastics could be absorbed by filter paper. Apart from filtration, long-distance transportation to a laboratory in another country (in this case Germany) is another risk for microplastics loss. Small microplastic fragments can be easily attached to sample bottles or other surfaces and for this reason the identification of microplastics should avoid long distance transportation. Due to time and weather limitations, stormwater samples were only taken on three different weather conditions in this study. Even though the small number of samples might not be sufficient enough to draw conclusions about the relationship between microplastic content and weather conditions, they could still be indicative and represent an important step towards assessing microplastics content and behavior in stormwater. In future studies, stormwater samples are suggested to be taken 31 Page 3875 of 4165 continuously during the whole year, always following the same protocol to ensure homogenous sample quality. Since there are interference factors in field measurements, lab simulation experiments could support future studies. For example, it would be interesting to test how turf responds to various types of artificial conditions. Preparing a square surface of artificial football turf and simulating runoff with clean water would help identifying how many microplastic fragments would be lost from artificial football turf. In this way, not only precipitation amounts and intensity could be controlled, but also interference from other particles would be effectively avoided. 4.2 Methods for inicroplastics identification In recent years, with the increasing attention on microplastics, the discussion on the identification of microplastics has also increased. Based on experience gained in this work (Section 3.2.3) combined with a literature review (Section 2.1), in this section advantages and disadvantages of available methods for microplastics identification are discussed. In this study, stereo microscopy was used to identify microplastics, which is an economic and simple method to assess morphological characteristics of microplastics. However, the stereo microscopy has shown to be neither suitable for quantitative analysis nor identification of microplastics from stormwater samples, and the assessment was conducted using an approach that is quite subjective. The challenging and difficult part of this study was to visually distinguish microplastics from other particles of similar size and shape, especially for the samples that contain organic particles (root fragments, plant detritus) as in this study. Hence, spectroscopic approaches are required for microplastic quantitative analysis. Spectroscopic methods for microplastic identification include scanning electron microscopy (SEM), Fourier-transform infrared (FT-IR) spectroscopy and Raman spectroscopy. SEM is a technique that characterizes surface morphology of microplastics by the interaction of an electrons beam with the sample in order to measure the secondary ions (Rocha-Santos & Duarte, 2015). X-ray radiation can also be detected by scanning electron microscopy. This radiation can be analyzed with a specially designed spectrometer, so-called scanning electronmicroscopy-energy dispersive X-ray spectrometer (SEM-EDS), which measures the x-ray radiation emitted from the sample. Plastic particles can be separated from organic particles because of the specific,high carbon concentration contained in plastics (Buj ak, 2018). SEM-EDS can be used to analyze SBR, EPDM, TPE and plastic straws, providing granulates with light color(ibid). FT-IR microscopy is often used to identify the polymeric composition of the microplastics. FT-IR has the low requirement for sample preparation, and clean-up sample is enough. Microplastic analyses with FT-IR are well established and the results are reliable. However, the equipment and sample processing are expensive and 32 Page 3876 of 4165 professional persons are rmnoirmJ with data processing. As for microplastic in artificial turfs, FT-DR can only be used for analyzing TP]B eruuoUo1ea as well as plastic straws, which ia not suitable for SBR and EPDMeranulates due io their black and rubber materials U0 ok, 2Ul0\ The technique of Raman spectroscopy (RS) resembles the F7`-Bl and involves u sample being irradiated with u monochromatic |oacr that creates vibrations in u molecule. Ruznuu spectra provide b,Dnrmo1on about bonding within the material and about networking airuoiorea (Rochu-Santos & Duarte, 2015). Small particles, including even dark particles between l to 20 [Lm can be analyzed hwRS with high spatial resolution. Furthermore, RS can [bai perform chemical mapping with mdorno1io data collection (Li et al., 2010). However, the analysis by RS is time consuming and although RS can detect type o[particles theoretically, the method has not been applied inndorop|uaiio identifications yet. According to the |dnoAurn review, in recent years FT-8R and 8BM are common quantitative methods of microplastic identification in oceans. Since microplastics has been one of the most discussed environmental problems in recent years, and more and more applied studies have been conducted, quantitative identification of microplastics is improving in terms of accuracy, simplicity and economy. However, relatively fewer ak/dina present methods and results onndcron|uatica in ak>rnnwa1nc motivating further research inthis area. 4.3 Mitigation measures of microplastics in stormwater As udiOciu| turfs have been studied as an important source of ndCxop|uatica, municipalities and research institutes in 8v/ndnn have hncocnn aware of the environmental impacts of udiOciu| turfs and some ndtiggion rnnuaurna have been proposed to dncrnuan the nndaaion or transport o[ndcrop|uatica. On one hand, |oaa of microplastics can be reduced from the source by regular maintenance of artificial turfs. On the other hand, they can also be captured during their transport along di[Drnni pathways. Nowadays the most commonly used udiOciu| turfs are the third-generation turfs with rubber infill granulates, which results in a large amount of loss of microplastics. Loss o[ndcrop|uatica has been observed spreading to the environment through mechanical snow removal, aionnwa1nc and when ndznd or trapped in sand. Reducing the snow removal in winter is u simple and effective measure to avoid spreading of ndcron|uatica. Matches undhruininga can be coordinated between several udiOciu| football fields in winter with an overall booking arrangement in order to reduce snow removal in total. Regular maintenance of artificial football fields can not only increase their life span, but also can be used as a measure to prevent spreading of microplastic 8Tunu|a1na. During maintenance, deep-cleaning can help io remove unwanted pudic|na from the udiOciu| turfs and increase uvui|uh|n store depth for ndCxop|uatic urunu|u1na. @naidna maintenance, reducing the quantities o[ndcrop|uatic 8Tunu|a1na used for inOU a» Page 3877of41O5 is a direct way to mitigate loss of microplastics. Lidingo municipality has positive experience of using granulates made of natural materials such as coconut and cork. Some manufacturers have proposed the fourth-generation artificial turf without granulates, which prevents the spread of microplastics from the source. However, the application effect of the fourth-generation products is still under test. In Germany and the Netherlands, eight fourth-generation artificial turfs were replaced after several years due to fiber release (Krang et al., 2019). Recently, a fourth-generation artificial turf has been built in Stockholm with only sand infill, and it has met the expectations of environmentally-friendly requirements (ibis). Choice of infill granulates of artificial turfs should be considered based on site conditions, function requirements, price, as well as environment and sustainability. Technical installations are effective ways to reduce the spread of microplastics through several different pathways. Installation of underlying sealing layers can be proposed to reduce spreading of microplastics. Most artificial football fields are well drained and are opened at the bottom, allowing part of the water to be transported through the drainage pipes while the rest flows directly to the groundwater and from tehre eventually to surface recipient (Krang et al., 2019). Underlying sealing layers should ensure water purification before it flows to drainage pipes. Filtration installations surrounding stormwater wells are also effective measures to capture microplastics. Some municipalities have installed filter bags in stormwater wells to avoid microplastics reaching stormwater. In general, the pore size of a filter bag is 0.4 mm which can capture ca 99% microplastics from artificial turfs according to the properties of granulates. The filter bags need to be emptied regularly to avoid clogging the trap. Since filter bags are effective and inexpensive installations, they can be widely used in stormwater wells and drainage wells surrounding artificial turfs. However, the capacity of the filter bags and the installed locations should be considered in practice. Besides filtration bags, a filtration well installation is proposed in order to capture smaller microplastics. All the stormwater and drainage water are led to the filtration well (Figure 26) with filter materials such as sand, and during filtration not only microplastics but also metals or other particles can be settled before flowing out of the well. In order to avoid clogging, the filtration well should be installed in a bigger well with a balancing function that allows bigger particles to be deposited. However, the filtration well is difficult and expensive to be installed especially for the existing pipe system. 34 Page 3878 of 4165 Concrete plate as o AA A Sand Infill Drainage Pipe > & Macadam" Figure 26 Filtration well installation. (Reference: Skiss inspired by drawing by Skelleftea kommun) Microplastics from artificial turfs are generally small and low-density particles, and they are difficult to be separated from sediments once mixed. Hence it is better to capture microplastics before they get transported from artificial turfs. When compared with other existing techniques for preventing microplastics loss, filter bags are the most economical and effective method at present. Based on the available literature data, filter bags are worth promoting as measures to mitigate microplastics entering stormwater. At the same time, the development of alternative material for microplastic granulates is essential as well, since microplastics from artificial turfs could be settled in surrounding soils, which are difficult to be degraded and have persistent negative impact on environment. 35 Page 3879 of 4165 5 Conclusions Microplastics from artificial turfs, as the second source of microplastics in Sweden, have attracted much attention in recent years. Stormwater is considered as one of the most important pathways transporting microplastics to environment and in particular ecologically-sensitive surface water bodies. However, because of challenges in the quantitative analysis of microplastics in stormwater, how much microplastic from artificial turfs reaches the stormwater is still unknown. Approximately 90% of microplastic granulates from artificial turfs analyzed in this study from the four sites in Stockholm is between I min to 3 mm. The density of microplastics is similar to stormwater and organic materials, and they can exist both on surface and in sediments of stormwater. Thus, microplastics are difficult to be separated from stormwater samples. Further development of method for separation of microplastics is necessary for quantitative studies in the future, because the approach developed here includes subjective evaluations that should be avoided. Microplastics from artificial turfs flow with runoff along with the terrain slope to stormwater wells by. Stormwater wells located closer to an artificial turf capture more microplastics compared with stormwater wells further away. It has been detected that a certain amount of microplastics get stuck in soils during their spreading through rainfall-runoff process. Stereo microscopy has shown as limited and rather subjective method for microplastic identification in stormwater samples as quantifying microplastics by naked eyes due to presence of other particles with characteristics similar to microplastics is very challenging process. Thus, the obtained results are more indicative than they could be used for conclusive purposes. In order to quantify microplastics transported from artificial turfs to stormwater, marking microplastic granulates and analyzing stormwater samples with electron microscopy are suggested. At present, although spread of microplastics from artificial turfs has been on the agenda in various municipalities and institutes, research perspectives and practical quantitative investigations of microplastics in stormwater are still scarce or in their initial phases. 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