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E <br />Ar. Steven Sasson <br />May 5, 1992 <br />Page 2 <br />E <br />Cove will continue to be a responsible corporate <br />citizen and will continue to comply with each of the regulations <br />discussed in the Kleinfelder letter. moreover, despite our <br />serious concerns regarding your agency's treatment of Cove, and <br />although Cove has committed no violation and is not required to <br />do so, Cove will voluntarily take the following steps: <br />a) submit further details of the site drainage plan as <br />an addendum to the Report of Disposal Site Information <br />(11RDSI11); and <br />b) identify areas of exposed ASR and apply additional <br />soil to the extent necessary to cover any exposed ASR <br />and to prevent any ponding of water on top of ASR. <br />The analysis presented in the Kleinfelder letter esta- <br />blishes that there are no violations at the site. Cove will pro- <br />ceed based on the understanding that there are no violations at <br />the site and that the additional steps proposed to be taken by <br />Cove are acceptable to your agency unless you notify us otherwise <br />and provide substantiation for your position. Cove welcomes the <br />opportunity to resolve these issues amicably, but is prepared <br />with convincing evidence and analysis to contest forcefully any <br />alleged violations. If your agency disagrees with Cove's <br />position as expressed in this letter, Cove hereby requests a <br />hearing on these issues and on all aspects of your agency's <br />handling of matters relating to the Cove landfill and the RDSI. <br />Cove continues to be highly responsive in taking all <br />steps necessary for the lawful continuation of its landfill <br />operations. Cove appreciates that your agency recognizes the <br />importance of your following the State policy of beneficially <br />using available landfill capacity. Cove looks forward to your <br />agency's cooperation in allowing Cove promptly to continue to <br />make productive use of this site. If you have any questions, <br />please call me at (213) 639-7629. <br />sincerely, <br />David B. Sadwick <br />Encl. <br />cc: Ron Valinoti, San Joaquin County Public Health Services <br />William J. Marshall and Scott Walker, California Regional <br />Water Quality Control Board --Central Valley Region <br />Robert Fujii, Alexander Richards and Stacey Mason, <br />California Integrated Waste Management Board <br />Betsy Jennings, State Water Resources Control Board <br />Jack Hecht, Cove Contractors <br />