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Class III landfill which has insufficient natural protection." <br />The Cove Contractors site is not lined and therefore is not in <br />compliance with WDR 87-22. <br />Response to Comment 2 <br />The referenced RWQCB resolution permits disposal of ASW to Class <br />III landfills. The RWQCB designates appropriateness of disposal <br />of ASW to Class III sites, based on evaluation of site-specific <br />conditions. <br />The RDSI contains an ASW disposal study in Appendix J which <br />includes a designated level assessment, which is an approach <br />often used by the RWQCB to analyze waste and ground water <br />effects. In addition, Section I contains hydrogeologic <br />discussions evaluating the capillary rise, ground water quality, <br />and other information which is the basis for the proposed closure <br />methods for the remaining portions of the on-site pit. <br />The RWQCB is aware of water quality at the site through the RWD <br />and past and ongoing monitoring, and indicated before performance <br />of the RWD that differing closure methods, which may not include <br />lining of the site, should be addressed. Therefore, the RWD <br />contains a Corrective Action Evaluation as mentioned above. This <br />evaluation was meant to conceptually present the options. It <br />also included a preliminary analysis of economics as specifically <br />requested by the RWQCB. The issue of whether or not the site <br />requires a liner under the referenced RWQCB document is a <br />discretionary item of the RWQCB. <br />Additional relevant information regarding this issue is in the <br />RDSI which presents the SWAT (Appendix F) for the site that <br />includes information on ground water quality. In addition, the <br />Periodic Site Review Report spends considerable effort discussing <br />ground water issues through the RWD (Appendix D) and Section F, <br />which summarizes recommendations and Conclusions. <br />Comment 3 <br />RDSI states on page 16 "Metals concentrations for treated ASW <br />given in table B-1 are all below the proposed DHS treatment <br />standards . . . 11 Treatment standards per the CRWQCB letter dated <br />7/30/87 are lower than the proposed California State Department <br />of Health Services (DHS) treatment standards. The concentrations <br />of Cadmium, Lead, Nickel and Zinc in treated ASW are higher than <br />the treatment standards per above mentioned CRWQCB letter. PHS- <br />EHD requests additional information to clarify this discrepancy <br />as part of the RDSI. <br />2 <br />