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. ,_ Memo to Berhan Keffelew Response to "QA/QC Oversight" Problem Noted page 2 In my opinion table should be amended to indicate that the "Drain Rock" component will receive 100% visual scrutiny. Like most other critical components, it will be impossible to affect any repair once covered. The particular drainage in question has not evidenced significant flow during the excavation this summer. However, the past winter and spring were relatively dry. I would disagree slightly with Mr. Hardaway's characterization of the specific drainage Swale involved. During my visit to the site several weeks ago there was minimal standing water evident in the trench excavation immediately above the "structure" delineated by CC&VG's field geologists in this drainage. Further, the insolation of the Phase 1 Leach Facility may significantly modify moisture occurrence and migration in the subgrade foundational materials. It is important that all underdrains be as open and free-flowing as possible. I do not disagree with 50% visual oversight for the "Geotextile Installation" component. In my opinion CC&VG has succeeded in controlling the construction so far. However, I anticipate that the site activity will become even more hectic as construction progresses. It would be unfortunate if oversights in CQA occurred because of inadequate primary inspection manpower. In mundane terms, the Division must be able to judge the adequacy of the CQA effort in some manor. I propose the following standard. On all critical components receiving 100% scrutiny, the primary CQA inspector shall be in attendance whenever materials are being placed. In no instance shall the inspector be absent from the site for more than 20 minutes while the contractor is placing critical component materials. If the Division observes an absence of the primary CQA inspector from an critical component under active construction for longer than 20 minutes a Reason to Believe letter will be issued to CC&VG. Immediate Notification of Problems Noted It is always the Division's intention to obtain immediate treatment and' resolution of any problem occurring at a site. However, occasions arise when some contemplative consideration is necessary to formulate a concern. I did mention my concern regarding adequacy of a single primary inspector to Dave Kidd while at the site on July 14, 1994. I did not phrase it as a formal "Problem Noted" to Mr. Hardaway. Upon return to the office the next day I discussed my concern with the Director, Minerals Program Supervisor and Lead Specialist. Following that discussion I finalized my consideration and issued the Inspection Report containing my formal "Problem Noted". In the future, as always, I will strive to provide immediate indication of any concerns to the operator. Realistically, sometimes it takes a little contemplation.