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10/10/91 10:16 $916 366 7013 SACRAMENTO <br />k"K L E I N F E L D ER <br />October 9, 1991 <br />File: 24-215600-E01 <br />Mr. Steve Sasson R.E.H.S. <br />Public Health Services <br />San Joaquin County <br />P.O. Box 2009 <br />Stockton, California 95201 <br />Subject: Responses to September 9, 1991 PHS Letter <br />regarding Cove Contractors Disposal Site <br />Dear Mr. Sasson: <br />Cj 012/018 <br />The following are responses to the September 9, 1991 San Joaquin Public Health Services <br />(PHS) letter to Mr. Jack Hecht, Cove Contractors (Attachment 1), regarding comments on the <br />Periodic Site Review (PSR). The responses are based on the PSR and discussions with Cove <br />Contractors. The comments from the PHS September 9, 1991 letter are followed by responses <br />below. <br />Comment 1: <br />"The PSR states remediation of in place waste would be expensive and not warranted in view <br />of the fact that elevated total dissolved solids and sulfate could not be attributed to waste in the <br />groundwater- The presence of auto shredder waste (ASW) in the groundwater below an <br />unlined landfill of questionable contents provides a conduit by which contamination may eruer <br />the drinking groundwater supply therefore remediation may be warranted. " <br />Section 17709, Title 14 CCR allows waste in contact with groundwater under conditions <br />approved by the Regional Water Quality Control Board (RWQCB). The RWQCB is aware <br />that auto shredder waste (ASW) in contact with ground water at the site, and indicated that a <br />conceptual closure plan which would cover and close the ASW in place could be submitted and <br />would be viewed as a feasible approach to closure. This was among the results of a meeting <br />which was attended by Cove Contractors, the RWQCB, the PHS and Kleinfelder at <br />Kleinfelder's offices in Sacramento in February of 1990. <br />As a result of this meeting and a subsequent meeting with RWQCB staff, a corrective action <br />evaluation was included in a Report of Waste Discharge (RWD) submitted to the RWQCB on <br />January 10 1991, which was also included in the Periodic Site Review Report (Appendix D) <br />submitted to PHS in January 1991. Based on a request by the RWQCB staff, a cost estimate <br />for removal of the waste, or other remedial options, was included in the Corrective Action <br />Report. <br />The hydrogeologic and groundwater quality conditions at the site are very complex. <br />Groundwater beneath the site is influenced by Walker Slough and variations in groundwater <br />levels between three hydrogeologic zones. Kleinfelder has been performing groundwater <br />monitoring at the site and most recently submitted a groundwater monitoring report to the <br />JM -91-4 <br />Page 1 of 7 <br />Copyright 1991 Kleinfelder, Inc. <br />KIIINFFLOER ", - it f'r,)nwtIto, CA O')Fi27 11)Iht <br />