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~i ... Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcemeht actions taken during the inspection anti the facts or evidence supporting the enforcement action. A second problem noted was that, while required quarterly stability inspections from 1984 to present were on file, timeliness of report submittal was not always in accordance with Rule 4.09.1(11)(b). The cited rule requires that "the qualified registered engineer shall provide to the Division a certified report within 2 weeks '- after each inspection that the fill has been constructed as specified in the design approved by the Division." Prior to 1995, the operator's report did not include the "constructed as specified" language, but the report was amended in 1995 as directed by DMG. The two week submittal timeframe has not been met on a consistent basis. This was pointed out to the operator. Future stability inspection reports/certifications will need to be submitted to the Division within two weeks of the inspection. A third issue of concern pertains to piezometer monitoring records. In 1994, 30 piezometers were installed along two "critical sections" through the refuse pile, on the lower two refuse benches. The piezometers were installed within 4 separate groups, or series; each series of up to 8 piezometers within one of four drill holes, and each piezometer slotted to allow monitoring of water levels within a specific zone within the pile. As part of the stability analysis, water elevations at which the 1.5 factor of safety could be jeopardized were calculated, and these "critical target depths" were specified for each piezometer. Water levels are monitored quarterly, to allow for comparison against the critical target depth. Pz 307 is the foundation piezometer within Drill Hole #7. The hole is located on the second level bench, along critical section "C", through the center of the pile. Monitoring records for January and April, 1997, indicated that the piezometer was dry, or nearly so, with water level well below the critical target depth of 84.19'. However, the measured depth reported for July 9, 1997, was 26.46' which, if correct, would indicate water level almost 60' higher than the critical depth. Mr. Reschke stated that the sampling had been done by a new employee, and that the reported depth was in actuality not water level, but indicated the depth the sampler was able to reach with the probe. He indicated that the piezometer had been troublesome since it was installed, and that it was frequently difficult or impossible to reach the bottom of the piezometer with the depth probe, due to apparent obstruction or constriction. The problem with Pz 307 has been reported to DMG geotechnical staff. Geotechnical evaluation and recommendation will be included in an addendum to this report, upon completion of review.