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<br />The Division's review of the pilot study for compaction testing <br />methods found the study to be inadequate in the following ways: <br />1) The locations of the pilot tests need to be shown on z <br />map. A sketch with approximate locations will suffice. <br />2) It is not clear exactly how the pilot testing was <br />conducted and how the pilot testing locations relate to <br />one another or how the pilot test supports WFU's <br />contention that the weight of the dozer does not affect <br />the compaction of the refuse material. WFU needs to <br />submit a report that clearly describes and documents <br />pilot testing procedures and locations and provides an <br />interpretation of the data relative to the original <br />purpose of the pilot test. <br />3) The Division is confused and concerned by the "erroneous <br />moisture readings" that the equipment is reported to have <br />generated. The following questions need to be answered <br />in order for the Division to have confidence in the data <br />provided: <br />a) If the equipment is giving erroneous moisture <br />readings, then how does WFU know if the <br />density readings given by the same instrument <br />are accurate? <br />b) What evidence is there to show that the <br />moisture of the refuse sample, at the time it <br />was analyzed at the lab, was representative of <br />the moisture of the refuse in the pile? (i.e., <br />what was the time lag between sample <br />collection and sample analysis? How was the <br />integrity of the samples preserved so that the <br />moisture content did not change between <br />collection and analysis?) <br />The report on the pilot testing needs to document <br />sampling and sample handling procedures, verify the <br />reliability of the instrumentation used, and list <br />assumptions regarding erroneous instrument readings. <br />WFU's request that the pilot test be substituted for the compaction <br />testing originally required in the NOV abatement is denied for the <br />following reasons: <br />1) The original intent of the pilot testing was not to <br />demonstrate overall compaction results for the refuse <br />pile, but to assure the Division that the proposed method <br />(excavating to the desired testing depths with a dozer <br />rather than drilling) would yield accurate results. The <br />pilot testing, as presented, has not fulfilled its <br />original intent because of the lack of detail in the <br />report. <br />