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Mr. Ron Valinoti <br />October 10, 1991 <br />Page 3 <br />(4) A Report of Waste Discharge (submitted January 3, <br />1991) . <br />All of these submittals were made to the Water Board and PHS in <br />order to keep the Facility in compliance with all of the require- <br />ments and obligations currently in force for an existing <br />landfill. <br />By letters dated August 26, 1991 and September 9, 1991, <br />Cove received comments from the PHS on the Report of Disposal <br />Site Information and the Periodic Site Review Report. However, <br />Cove received no proposed permit revisions or revised conditions <br />as a result of its application for permit review. <br />II. Cove May Continue To Operate Under Its Existing Permit. <br />Cove is not seeking and has not sought a new or revised <br />permit, nor does is it intend to change the landfilling activi- <br />ties authorized by the Permit issued in 1979 — Cove simply <br />intends to continue the activities authorized under the existing <br />Permit. There are no proposed changes of significance to the <br />design or operation of this Facility.y Rather, Cove will con- <br />tinue its historic ASW disposal operations at the Facility in <br />order to bring the remaining pit to surrounding grade so that the <br />Facility can be closed.!' <br />Cove has prepared detailed responses to the comments <br />and requests for further information from PHS. Responses to the <br />comments are attached hereto as Exhibit 6. (For ease of <br />reference, Exhibit 6 reiterates the information contained in <br />Exhibit 5 in a point -by -point summary of each PHS comment <br />followed by each Cove response.) Cove will be happy to provide <br />any further information requested by PHS. However, the deadline <br />for PHS to issue a proposed new permit has long ago expired;b' <br />thus Cove may now lawfully continue its current operations under <br />its existing Permit at this Facility. <br />4/ See 14 Cal. Code of Regulations S 18211, requiring revision <br />of a permit where the permittee proposes to make significant <br />changes to the design or operation of the facility, meaning <br />changes which do not conform to the terms or conditions of the <br />existing permit. <br />5/ See 14 Cal. Code of Regulations, S 18211, comment section, <br />indicating that review of historic operations is subject to <br />limited scrutiny. <br />6/ See 14 Cal. Code of Regulations S 18207(a) (allowing 75 days <br />to issue a proposed new permit). <br />