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Cove-Contractors -2- 2 March 1992 <br /> Extraction Test(§66700 of Title 22,California Code of Regulations) for assessment of <br /> extractable metals other than chromium VI is appropriate. <br /> Your letter proposes to change background monitoring wells from designated wells at <br /> the Cove site to selected wells in the Stockton area. However,demonstration is not <br /> provided to preclude anthropogenic sources of TDS for these wells and aquifer <br /> conditions have not been demonstrated to be directly comparable. Although recharge <br /> from Walker Slough may have a localized effect of reducing TDS at Cove, the slough <br /> provides a potential source of ground water replenishment and as such,is a valid aspect <br /> of background water quality. <br /> In addition to the above topics of disagreement,additional issues have not been resolved <br /> as requested. However, we plan to initiate preparation of a preliminary set of tentative <br /> waste discharge requirements (WDRs). Initially,we will request clarification from the <br /> Integrated Waste Management Board and the San Joaquin County of Public Health <br /> Services, Environmental Health Division regarding the California Environmental Quality <br /> Act(CEQA) issue. <br /> After public review, tentative WDRs are submitted to our Board for adoption in a public <br /> meeting. Cove Contractors, Incorporated would be provided the opportunity to present <br /> testimony contesting the tentative WDRs. <br /> If you have any questions,please contact me at (916) 361-5741 or Scott Walker at <br /> (916) 361-5736. <br /> 7 <br /> WILLIAM J. MARSHALL,Chief <br /> Chapter 15 Land Discharge Unit <br /> SDW:WJM <br /> Attachments <br /> cc: Mr.Robert Fujii,California Integrated Waste Management Board,Permitting and <br /> Compliance Division,Closure and Corrective Action Branch,Sacramento <br /> Ms. Betsy Jennings,State Water Resources Control Board,Office of Chief Counsel, <br /> Sacramento(w/o attachment) <br /> Mr. Ed Padilla,San Joaquin County Department of Public Health Services, <br /> Environmental Health Division,Stockton <br /> Mr. Mark Urquhart,Kleinfelder, Incorporated, Sacramento <br /> Mr. David Sadwick,Heller, Ehrman, White, &McAuliffe, Los Angeles <br />