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10/10/91 10:21 $916 366 7013 SACRAMENTOQ016/018 5 months out of the year, roughly 1000 CY of cover soil will be required for winter operation. Accordingly, a stockpile of 1000 CY will be maintained by Cove Contractors at the site for this purpose. Because the pit is already excavated, all future cover material will be obtained from off-site. This will involve import of appropriate amounts of clean cover soil for cover for winter months only and as a contingency for periods of unusually high wind that may create waste dust problems. [Appropriate closure cover soil will also be imported for the final cover upon site closure.] The source of the borrow material is unknown because the sources for borrow material will be negotiated based on availability and economics of local cover. Borrow projects typically may involve a variety of sources as they become available based on local construction projects. Because the soil requirements for cover for the site are relatively small (1000 CY annually), availability of cover material should not be a problem. Local borrow which becomes available from local construction projects far exceeds these demands. Additionally the low annual cover requirement is spread over approximately five years, and it is not practical or economical for Cove Contractors to be forced to enter a long term agreement for cover just to show exactly where the materials will be obtained from. "PDM section B- 6a corresponding to PSR section D.6 regarding fire control the PSR states "In the event of fire at the site, site operators should be trained to use the onsite soil stockpile and equipment to cover smoldering loads. " A description of an onsite soil stockpile location is not indicated anywhere in the PSR. " "Section 17561 Article 6 Chapter 3 77de 14 of the California Administrative Code states that burning wastes are to be "... deposited in a safe area and extinguished .... "A burning waste safe area is not indicated in the PSR. The history of the site has shown fire to be a problem with the Cove Contractors site. EHD requires that a letter from the local fire authority be submitted with he PSR stating that this facility is in conformance with local fire ordinances and that the local fire authority approves the facility as proposed. " On -Site Soil Stockpile The on-site cover soil stockpile will be replenished annually prior to the winter to contain 1000 cubic yards of soil. It is anticipated that a portion of this soil will remain in the unlikely event of a landfill fire (See lire Safety, below). The cover stockpile for 1000 cubic yards will be up to approximately 180 feet long by 40 feet wide (assuming 10% slopes in the long direction and 8 foot total height). The location of the stockpile will be kept near the fill area for economy of operation. During Phase I operations (Drawing 2), the stockpile will be located east of the pit. During Phase H operations (Drawing 3), the stockpile will be placed on the fill kept in the same location because it will be the area of the fill which will be brought to final grade first. Fire Safety On September 17, 1991, Kleinfelder contacted Captain White of the Stockton Fire District and requested a letter indicating the site is in compliance with their requirements and regulations. Captain White indicated he would have his staff inspect the site and supply written 1M-914 Page 5 of 7 Copyright 1991 KMainfelder, Inc. KLEINFELDER 3077 Fite Circle, Sacramento, CA 95827 (916) 366-1701