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Depa,:r.-,e,at of Tran.qport~tion & Development 902 Abel'nethy ROad Oregon City, OR 97045 503 673-0165 FAX 503 675-1126 For ~e past few years, we've been furnishing Liner Certification forms with the rand filter liners supplied to our cuatomem in Clackamas County (the only area in the country' that we ~e required to provide this cemfication). This form certifies that we have l~rformed an air lance test on each seam. Considering our method of welding~ we feel that this test is un.necessary. The air lance test i~ best suittml for the "bar welding" method of joining plastic sheeting. For a bar welder to make a lengthy weld, one must make a continuous series Of short ~dd5. Thus the applicability of the air lance test; if one weld does not overlap the last, the .high pressure ak ~eam will make the gap between ~e two welds quite apparent. Our v,.elder makes a single~ continuous weld down the length of the seam using pinch rollers. The orgy way' for a gap to form would b~ for the heat ,upply to be instarttaneonsly cut off. ~ i~ not possible as it tals~ about 15 minutes for the element to cool once the power supply i-~s been shut off. Our welding personnel routinely "peel test" every seam in at least two locations to ensure the ~tegrity of the weld. If the weld can be pulled apart by hand, it is deemed inadequate. We fc~l that our routine method of testhng welds is much more ef£eetive thaB" (r lan.ze t~st as the air lance test will not reveal a pOor weld. We cta'tairdy recognLze the[validity of the C0unty% effort to protect its cor,~t/me~ts~ Nonetheless, the reqmred mr lance test, in this case, doesn't really guarantee what is implied. Charging, o_xstomer for a mean/ngless test goes against the grain. Please consider exempfia~,g OSI from the ~and filter certification requirement. We are looking forward to your response and to your visit here on the 16th. Sincerely, ORENCO $Y$11zM$, ~C.I ~002 jLB/p