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ST, TE OF CALIFORNIA PETEW SON, Governor CALIFORNIA W-GIONAL WATER QUALITY CONTROL BOARD— CENTRAL VAL'_EY REGION J U L j I'_ --- 3443 ROUTIER ROAD. SUITE A ENVIRONMENTAL HEALTH SACRAMENTO, CA 95827-3098 PERMIT/SERVICES' PHONE: (916) 361-5600 FAX: (916) 361-5686 16 July 1991 } Mr.Jack Hecht Cove Contractors 2711 Navy Drive Stockton,CA 95206 COVE CONTRACTORS, STOCKTON, SAN JOA COUNTY, CASE NO.2797 Our records indicate that the following reports and documents have been submitted: (1) Report of Waste Discharge,Cove Contractors Disposal Site,San Joaquin County, dated 2 January 1991 (Kleinfelder,Inc.); (2)Ground Water Monitoring Work Plan,dated 15 February 1991 (Kleinfelder,Inc.); and(3)Report of Waste Discharge Application Form and Annual Fee, dated 21 February 1991. The Report of Waste Discharge (RWD)proposes to accept treated auto shredder waste (ACW) to bring the inactive facility to a grade suitable for final closure. The total amount of ACW proposed for disposal is 66,000 cubic yards with an approximate site life of five years. If a sufficient source of ACW is not found,then inert waste is proposed to make up the difference. A concrete parking and foundation slab is proposed as an engineered alternative to a final prescriptive standard landfill clay cap. Cove Contractors wishes to close the site in approximately five years so that it may be developed as an industrial warehouse facility. Should foundation conditions make development infeasible, then a prescriptive standard cap is proposed. Correspondence dated 18 June 1990 from the San Joaquin County Division of Environmental Health Services indicates that the Solid Waste Facilities Use Permit (SWFP)for the Cove Contractors facility has not been renewed. Furthermore, the California Integrated Waste Management Board,in a letter to Mr. Edwin Oyarzo dated 11 April 1990,clarified the requirements for permit review, closure/post-closure maintenance plans, and compliance with the California Environmental Quality Act (CEQA). It is apparent that a CEQA determination and a new or revised SWFP for waste discharge will be required for the project as proposed. We question whether market conditions and the additional permit requirements justify discharging additional ACW. Using clean fill to bring the site to grade may substantially improve foundation conditions for future development and preclude the need for a new or renewed SWFP. Initiation of the CEQA process would still be required for the project but would probably be less complex.