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e0 333 BUSH STREET SAN FRANCISCO, CALIFORNIA 94104-2878 FACSIMILE (41S) 772-6268 TELEPHONE (415) 772-6000 525 UNIVERSITY AVENUE PALO ALTO, CALIFORNIA 9 4301-190 8 FACSIMILE (415) 324-0638 TELEPHONE (415) 326-7600 1300 S.W. FIFTH AVENUE PORTLAND, OREGON 97201-5696 FACSIMILE (503) 241-0950 TELEPHONE (503) 227-7400 HELLER, EHRMAN, WHITE & MCAULIFFE ATTORNEYS A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 601 SOUTH FIGUEROA STREET, 40TH FLOQ , LOS ANGELES, CALIFORNIA 90017-5758 TELEPHONE 1213) 689-0200 • FACSIMILE (213) 6144.166a' 701 FIFTH AVENUE SEATTLE, WASHINGTON 98104-7098 FACSIMILE (206) 447-0849 TELEPHONE (206) 447-0900 15108-0001 Mr. Steven Sasson San Joaquin County Public Health Services Environmental Health Division 1601 East Hazelton Avenue Stockton, California 95201 Re: California Clay Landfill, Permit No. 39 -AA -0010 3242 South El Dorado Stockton California Dear Mr. Sasson: We are writing on behalf of Cove Contractors in regard to the notice of inspection provided by your agency to the California Clay Landfill, which is currently operated by Cove Contractors. As you know, Cove is not currently accepting new Automobile Shredder Residue ("ASR") at the landfill pending finalization of Waste Discharge Requirements ("WDRs") from the Regional Water Quality Control Board. This letter addresses issues that I had intended initially to discuss with you by telephone; I have been unable to do so because you have not returned my telephone calls to you. Cove hereby submits the attached letter from Kleinfelder, Inc., Cove's engineering consultants for the site. As the Kleinfelder letter demonstrates, Cove is not in violation of any of the sections of the California Code of Regulations cited in your March 6, 1992, notice of inspection. As always, Cove is interested in continuing to take all reasonable steps to assure that the landfill continues to operate in a manner that protects health, safety and the environment. Cove is equally interested, however, in being treated fairly by your agency and in not having unreasonable restrictions imposed upon the use of its property. Cove is concerned that your agency is not being reasonable in its treatment of Cove, and is unfairly targeting Cove based on unfounded allegations in an improper attempt to inhibit Cove's property rights. da o,N 1201 PACIFIC AVENUE WASHINGTON 98402-4308 IFACP�IiMILE 572-6743 t .(#206) tY,/Li,Wi,O�i @206) 572-6666 May 5, 1992} I-V ? 3 550 WEST 7TH AVENUE ANCHORAGE, ALASKA 99501- 3 571 FACSIMILE ( 9071 277-1920 TELEPHONE (907) 277-1900 15108-0001 Mr. Steven Sasson San Joaquin County Public Health Services Environmental Health Division 1601 East Hazelton Avenue Stockton, California 95201 Re: California Clay Landfill, Permit No. 39 -AA -0010 3242 South El Dorado Stockton California Dear Mr. Sasson: We are writing on behalf of Cove Contractors in regard to the notice of inspection provided by your agency to the California Clay Landfill, which is currently operated by Cove Contractors. As you know, Cove is not currently accepting new Automobile Shredder Residue ("ASR") at the landfill pending finalization of Waste Discharge Requirements ("WDRs") from the Regional Water Quality Control Board. This letter addresses issues that I had intended initially to discuss with you by telephone; I have been unable to do so because you have not returned my telephone calls to you. Cove hereby submits the attached letter from Kleinfelder, Inc., Cove's engineering consultants for the site. As the Kleinfelder letter demonstrates, Cove is not in violation of any of the sections of the California Code of Regulations cited in your March 6, 1992, notice of inspection. As always, Cove is interested in continuing to take all reasonable steps to assure that the landfill continues to operate in a manner that protects health, safety and the environment. Cove is equally interested, however, in being treated fairly by your agency and in not having unreasonable restrictions imposed upon the use of its property. Cove is concerned that your agency is not being reasonable in its treatment of Cove, and is unfairly targeting Cove based on unfounded allegations in an improper attempt to inhibit Cove's property rights.