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i+~ Ic <br />Christine Johnston, October 23, 1995 <br />Page 2 <br />3) The western expansion area described in the first quarter 1995 inspection report did <br />not involve an extension of the rock underdrain. The rock underdrain for this azea of the <br />refuse pile situates 50 to 100 feet south of the subject expansion azea, and was completed in <br />1993. <br />4) EFCI acknowledges that the quarterly inspection report does not address compaction <br />tests or measurements of lift thicknesses. The engineer has been made awaze of compaction <br />tests performed and the data from the tests. The engineer will include references to <br />compaction tests performed and observations of lift conswction in future inspection reports. <br />Documentation of compaction tests is on file at EFCI's Southfield office. Compaction <br />testing was performed on 2/17/95 prior to the quarterly inspection on 3/17/95. Rule <br />4.10.2(2)(b) and the permit application do not require submittal of compaction test reports to <br />the Division. Accordingly, they were not submitted with the first quarter 1995 inspection <br />report. Information on compaction testing will be submitted to the Division following the third <br />quarter inspection and compaction testing (see response 5 below). In addition, documentation <br />of the compaction testing will be provided on the third quarter 1995 engineer's inspection <br />report. <br />5) EFCI completed compaction tests in the first and third quarters of 1995 as mentioned <br />above. These and previous compaction test data were sent to a third party engineering <br />wnsultant for review and evaluation. Although the compaction testing program and its <br />frequency of test locations has been approved for Southfield's specific pile configuration, <br />EFCI will get an engineering evaluation of the current Compaction Testing Program. EFCI <br />will submit the results of this evaluation, along with compaction testing data, to the Division <br />by November 30, 1995. <br />Sediment Pond Inspection Reports: <br />1) EFCI discussed documentation of sediment levels in the ponds with the engineer. We <br />aze working with him to install staff gages or other means to access pond sediment levels. <br />Any such techniques, short of across-sectional survey of the pond, will provide an estimate <br />of the sediment level. The engineer will provide more detailed information comparing the <br />sediment in the pond with the maximum design sediment level in future inspection reports. <br />2) A review of recent quarterly inspection reports indicates that the engineer's <br />maintenance recommendations includes sediment removal (usually at the pond inlet azea), and <br />installation of catwalks. EFMC regulazly removes sediment, especially at pond inlets, when <br />the sediment accumulation reaches a level that could effect the performance of the pond. Such <br />work was completed at Pond Nos. 1 and 5 during this past August. In addition, a review of <br />NPDES discharge records indicates that all ponds affectively treat stormwater events. The <br />other repeated recommendation, installation of catwalks, is not a design requirement and will <br />not be included in future engineer inspections. <br />