Laserfiche WebLink
g-.Tg �F CALIFpRNIA <br /> PETE WILSON. GOv�rno. <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION �• 1` <br /> 3a=3 ?OUTIER ROAD. SUITE A = <br /> SACRAMENTO. CA 95827.3;98 `\ <br /> 'yONE: 19161 361-56 U � � V �� �'•w ^'" <br /> =< 36 S•5686 ( �f <br /> I''' PEAR 04- 1992 <br /> 2 March 1992 U (� <br /> BY: -- <br /> Mr. Jack Hecht <br /> Cove Contractors <br /> 2711 Navy Drive <br /> Stockton, CA 95206 <br /> COVE CONTRACTORS DISPOSAL SITE, SAN JOAQUIN COUNTY, CASE NO.2797 <br /> We have reviewed your 23 January 1992 letter written in response to deficiencies noted in <br /> the Report of Waste Discharge (RWD) for the Cove Contractors auto shredder waste <br /> (ASW) disposal site. The following addresses main topics of disagreement outlined in <br /> your letter. <br /> Our position remains that site conditions alone at Cove are insufficient to ensure no <br /> impairment of beneficial uses of waters of the State beneath or adjacent to the landfill <br /> from the proposed discharge of Auto Shredder Waste (ASW). The site is a threat to <br /> ground water because of shallow ground water (the RWD states that a 5 foot separation <br /> exists between proposed waste discharge and highest anticipated ground water). The site <br /> is a threat to surface waters as indicated by the fact that engineered levees are required <br /> for 100-year flood protection and no effective storm water management plan has been <br /> proposed. No containment structures or leachate collection and removal system are <br /> proposed other than a partial "capillary break". <br /> The RWD does not demonstrate that Soluble Designated Levels (DLs) for protection of <br /> water quality will not be exceeded. In fact, the RWD acknowledges through the use of an <br /> uncalibrated general computer model that metals will be mobilized in the vadose zone <br /> and total dissolved solids (TDS) in ground water will increase above the secondary <br /> Maximum Contaminant Level (MCL) of 500 mg/1. <br /> Monitoring data for ASW submitted in the RWD also shows high extractable metallic <br /> concentrations well in excess of DLs for an average site which threatens surface and <br /> ground water (see attached memo on regional board ASW policy dated 30 July 1987 and <br /> attached waste acceptance policy memo dated 30 March 1989). Of particular concern is <br /> extractable chromium VI which is extremely mobile and has low numerical water quality <br /> goals of 0.05 mg/l (for protection of human health) and 0.011 mg/1 (for protection of <br /> aquatic life). As indicated in the attachment,for sites like Cove with shallow ground <br /> coater and no effective storm water management plan, the DL for chromium VI would be <br /> 0.011 mg/1. Detection of methane gas associated with in-place waste at the site implies <br /> significant organic decomposition. Therefore, use of the standard citrate buffer Waste <br />