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10/10/91 10:04 $916 366 7013 <br />October 9, 1991 <br />File: 24 -215600 -EA 1 <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 />_ _SACRAMENTO _ _ _ 16002/018 <br />Subject: Responses to San Joaquin Public Health Services Letter <br />dated August 26, 1991, Cove Contractors Disposal Site <br />r - <br />The following are responses to the August 26, 1991 San Joaquin Public Health Services (PHS) <br />letter to Mr. Jack Hecht, Cove Contractors (Attachment 1) with comments on the Report of <br />Disposal Site Information (RDSI). The responses are based on the RDSI and discussions with <br />Cove Contractors. The comments from the PHS August 26, 1991 letter are followed by <br />responses below. <br />Comment I <br />"The presence of waste in contact with groundwater is in violation of section 17709 Title 14 <br />CCR. PHS EHD requests a remediation plan be submitted as part of the RDSL " <br />Response to Comment 1 <br />Section 17709, Title 14 CCR allows waste in contact with groundwater under conditions <br />approved by the Regional Water Quality Control Board (RWQCB). <br />The RWQCB is aware that auto shredder waste (ASW) is in contact with ground water at the <br />site, and has indicated that a conceptual closure plan which would cover and close the in-place <br />ASW is appropriate. This was among the results of a meeting which was attended by Cove <br />Contractors, the RWQCB, the PHS and Kleinfelder at Kleinfelder°s offices in Sacramento in <br />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 RWQCB staff, a cost estimate for <br />removal of the waste, or other remedial options, was included in the Corrective Action 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 3 hydrogeologic zones. Kleinfelder has been performing groundwater <br />monitoring at the site and most recently submitted a groundwater monitoring report to the <br />Page 1 of 10 <br />Copyright 1991 Kleinfelder, Inc. <br />KLEINfEI-1)Ek 1077 Fite O, ;x flo (A 958 2,' (()10)300-1701 <br />