We believe that clays which have been removed from a surface impoundment site and engineered (remolded, compacted, etc) are liners. Does EPA agree?
Yes. Q: Page C-11 in the draft questionnaire included an instruction that stated if the surface impoundment has no liner, skip to Question C15. That instruction is not on the final questionnaire. How should the respondent answer Questions C11 – C14 if there is no liner in the impoundment? A: Removing the instruction that was in the draft questionnaire was an error – the version you received should have had an instruction on page C11 telling you to skip to Question C15 if the impoundment has no liner. If the impoundment has no liner, simply skip to Question C15, or leave Questions C11, C12, and C13 blank, and answer NO for C14a, then skip to Question C15. We will interpret unanswered C11, C12 and C13 along with a “NO” answer for C14a as “NO LINER.
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