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KLEINFELDER Section 13273.3 of the California Water Code defines operator of a landfill for the purpose of assigning responsibility for completion of a SWAT. Cove Contractors was neither the operator or manager of the Area B landfill nor the land owner of the parcel that contains Area B. Therefore, it appears that requiring Cove Contractors to prepare a SWAT for that area is not justified. On behalf of Cove Contractors, we request that the RWQCB reevaluate their position on this issue. EXPOSED ASR The RWQCB is concerned about exposed ASR, but a significant amount of exposed ASR is located on the Martin Metals site. In recent correspondence (letter dated May 5, 1992) addressed to San Joaquin County Public Health Services (a copy of which letter was sent to the RWQCB), Cove Contractors said they will regrade the area of Cove Contractors property in question and apply additional soil cover on areas where ASR may be exposed. Thus, we believe the issue of exposed ASR at the Cove Contractors site has been addressed. Cove Contractors anticipates that the work will be completed before the beginning of the next rainy season. SUMMARY Analytical results from the split samples support the analyses presented by the RWQCB with respect to volatile organics, no volatile organics were detected. Kleinfelder believes that the comparison with WQGs presented in the RWQCB letter is not appropriate and levels found in the samples should not be problematic under appropriate standards. In addition, it does not appear that Cove Contractors should be held liable for preparation of a SWAT for the landfill (Area B) that occupies the property immediately north of the Cove Contractors site because Cove Contractors was and is neither the operator or manager of the Area B landfill nor the land owner of the parcel that contains Area B. The RWQCB is requested to reevaluate their position on these issues. CM10-92-13 Page 2 of 2 Copyright 1992 Kleinfelder, Inc.