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A016. a e 1W 1W k%1 KLEINFELDER ATTACHMENT 1 SAMPLING OF PONDED SURFACE WATER On March 6, 1992, the Cove Contractors site was inspected by the Regional Water Quality Control Board (RWQCB), the Integrated Waste Management Board, and the San Joaquin County Public Health Service. A representative from Kleinfelder accompanied the inspection team. The RWQCB collected two grab samples from surface water in the northeastern portion of the site. The two bodies of water sampled were small, having dimensions of approximately 30'x40' and 20'x30' with a depth of 6" or less. The samples were collected during intermittent rainfall after a period of heavy rainfall. Kleinfelder collected splits of those samples. The samples collected by Kleinfelder were analyzed for halogenated volatile organics (EPA 8010) and aromatic volatile organics (EPA 8020). The results were nondetect for both samples, which is consistent with the RWQCB findings. A copy of the Chain of Custody and the analytical report is attached. The RWQCB states that the sample results indicate exceedance of water quality goals (WQGs) and compare selected analytical results with water quality goals including secondary MCLs, Agricultural Water .Quality Goals, Freshwater Aquatic Life Protection Criteria, and SNARLS. We believe that the use of these WQGs is not appropriate for this situation. The water samples were collected from two small areas. The site is fenced so the surface water is not likely to contact humans. The fill areas across the site are below the natural surrounding grade so runoff is prevented from contacting offsite surface water. Instead, surface runoff travels to a low point along the -northern boundary of the site and then either infiltrates or evaporates. In addition, Cove Contractors has never proposed to discharge to surface water liquids that may have contacted auto shredder residue (ASR). Since the site is fenced to control entry, it is not likely that humans will wander on site and drink the surface water. Therefore, citing exceedance of human health based goals such as MCLs or SNARLS is not appropriate. Cove Contractors does not intended nor has ever intended to use water that may have contacted the ASR for agricultural purposes and therefore, comparison with Agricultural Water Quality Goals is not valid. Discharge to surface water is not proposed, so comparisons with Freshwater Aquatic Life Criteria is not reasonable. In addition, a comparison to Freshwater Aquatic Life Criteria is made assuming that chromium detected in the ponded water was completely in the form of chromium VI. To date, chromium VI has not been detected in ground water at the site. It appears that this assumption is not supported by the monitoring data. RESPONSIBILITY FOR PREPARATION OF A SWAT The RWQCB argues that the September 1989 SWAT prepared for the Cove Contractors site is incomplete because it does not include a portion of fill that extends onto the adjacent property to the north. Our understanding of the history of the site is that the original owner of the property that now encompasses the Cove Contractors parcel and the parcel immediately north of the Cove Contractors parcel was California Clay Products. California Clay Products operated the site as a landfill and the initial filling operations began as early as 1955. The area in question (Area B in the Report of Waste Discharge) was filled by California Clay Products with a combination of inert debris and ASR. Cove Contractors purchased the southern portion of the California Clay Products property in 1979. California Clay Products retained ownership of the parcel that contains Area B. CM10-92-13 Page 1 of 2 Copyright 1992 Kleinfelder, Inc. Lot