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10/10/91 10:07 V916 366 7013 Response to Comment 3 SACRAMENTO R004/018 __ A— The July 30, 1987 letter by RWQCB calls out soluble designated levels for the "average site" (bottom page 2). The treatment standard in Table B-2 was a proposed treatment standard by DHS for classification of ASW as non -hazardous. These standards were used comparatively for the ASW shown. The specific WET test results from Snitzer Steel and LMC were used in the site specific SFSOIL vadose zone modelling to evaluate ground water impacts. In addition to stipulating that levels are for the "average site", the RWQCB letter also states further information is available in the designated level methodology. It should be noted that the RWQCB has abandoned the use of "average site" numbers which were those quoted by PHS from the 1987 letter. Instead they now request that the discharger make a site specific assessment of the attenuative capacity of the site, which was done for the Cove Contractors site. Kleinfelder performed an assessment of impacts of continued disposal and closure on ground water. This assessment included site specific modeling (SPSOIL) of the proposed disposal and closure methods, which was presented in Appendix J of the RDSI (The RWQCB has accepted SESOIL modeling results in the past and is pleased with the modelO). r i , "RDSI fails to describe the type of landfill operation as per the permit desk manual i.e. daily cover, modified landfill, area fill, liquid waste ponds, etc. " The operation was described in the RDSI as a pit. This refers to a trench (or cut and fill) operation, although this type of operation is not specifically included in the partial list of types of operations in the desk manual. "RDS1 neglects to describe cover depth, cell size, presence of scales, confined unloading, or cover frequency as per section 17682 little 14 CCR based on peak daily tonnage figures of 130 tons per day which requires daily cover and average daily load of 19 tons per day which requires cover every 48 hours. " As discussed in the RDSI, ASW primarily contains small pieces of plastic and rubber, inert material and small metal bits from the shredding process. Most liquids are volatilized during the shredding operation and a silicate/cement treatment is applied to the ASW to control metals leaching. Page 3 of 10 Copyright 1991 Kteinfelder, Inc. K1 F1N"'rLDLFZ 191(0366-t701