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<br />is a most appropriate position for Golder Associates to take when it involves the correct <br />application of the specifications. <br />Further, we do not understand why Qolder Associates' defense of changes to specifications <br />should be cause for criticism. Staff must understand that CC&V does not identify the need for <br />specification changes. Rather the prime engineering contractor and their subcontractors <br />(including Golder) identify and justify the need. There would not be a request for specification <br />change by CC&V unless Golder had justified it and provided the necessary information. <br />Therefore Golder should be expected to defend a request for a specification change, and their <br />professional engineering position should be honored. Further, the language of Number 2 <br />suggests that Golder should not defend a specification change that has been approved by the <br />Office. That mandate also is difficult to understand. <br />Item number 2 also states that Golder does not have a right to discuss the number of tests or <br />retesting requested by the Office. We are not aware that we had any agreement that the Office <br />was empowered to direct an increase (or decrease) in the number of tests without allowing <br />Golder Associates to discuss the request. At a minimum Golder should be presented with <br />professional engineering recommendations that then become topics for discussion. We note that <br />the frequency of testing is described in detail in the approved specifications. We have never <br />asked for a decrease in the testing described in those specifications and we have proposed and <br />conducted additional testing in connection with the minor specification changes that have been <br />approved by the Office. In fact, and as summarized in each weekly report submitted to the <br />Office (in addition to being reviewed at CC&V's expense by Water Waste & Land), we are <br />purposefully conducting tests at a higher frequency than required. <br />Neither CC&V nor Golder Associates was consulted regarding the implication in number 2 that <br />the Office is in a position to require a retest without discussion by Golder. I hope that there is <br />agreement that if the specifications are unquestionably met, quantitatively in terms of the <br />numeric specifications, methodology, and frequency, retesting is not necessary. If any QA <br />sample fails, the material is either removed or reworked and the test is repeated. Thus retesting <br />is an integral part of the approved specifications. CC&V and Golder have, nonetheless, <br />performed additional tests upon request of the Office for educational purposes and will continue <br />to when the request is either for educational purposes to train Office staff in the procedure or <br />when the request for additional tests is reasonable and technically justified. Obviously, as stated <br />earlier, CC&V and Golder have been proponents of and agreed to perform additional tests when <br />a different combination of factors is involved with a particular specification change. However, <br />retesting for the sake of retesting is not warranted. <br />It is our belief that as written, this second item in the October 14th memorandum is not correct <br />and should be modified soon. Otherwise inspectors may be misled and CC&V will be required <br />to respond to criticisms that are unjustified. <br />While we do not consider one additional item in the memorandum to be of substantial concern, <br />we nonetheless would like to have the record show that despite the possible inference of the <br />2 <br />