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Response to Comment 3 <br />The July 30, 1987 letter by RWQCB calls out soluble designated <br />levels for the "average site" (bottom page 2). The treatment <br />standard in Table B-2 was a proposed treatment standard by DHS <br />for classification of ASW as non -hazardous. These standards were <br />used comparatively for the ASW shown. The specific WET test <br />results from Snitzer Steel and LMC were used in the site specific <br />SESOIL vadose zone modelling to evaluate ground water impacts. <br />In addition to stipulating that levels are for the "average <br />site,10 the RWQCB letter also states further information is <br />available in the designated level methodology. <br />It should be noted that the RWQCB has abandoned the use of <br />"average site" numbers which were those quoted by PHS from the <br />1987 letter. Instead they now request that the discharger make a <br />site specific assessment of the attenuative capacity of the site, <br />which was done for the Cove Contractors site. Kleinfelder <br />performed an assessment of impacts of continued disposal and <br />closure on ground water. This assessment included site specific <br />modeling (SESOIL) of the proposed disposal and closure methods, <br />which was presented in Appendix J of the RDSI (The RWQCB has <br />accepted SESOIL modeling results in the past and is pleased with <br />the model). <br />Comment on Section A-1 <br />RDSI fails to describe the type of landfill operation as per the <br />permit desk manual i.e. daily cover, modified landfill, area <br />fill, liquid waste ponds, etc. <br />Response to Comment on Section A-1 <br />The operation was described in the RDSI as a pit. This refers to <br />a trench (or cut and fill) operation, although this type of <br />operation is not specifically included in the partial list of <br />types of operations in the desk manual. <br />Comment on Section A-4 <br />RDSI neglects to describe cover depth, cell size, presence of <br />scales, confined unloading, or cover frequency as per section <br />17682 Title 14 CCR based on peak daily tonnage figures of 130 <br />tons per day which requires daily cover and average daily load of <br />19 tons per day which requires cover every 48 hours. <br />Response to Comment on Section A-4 <br />As discussed in the RDSI, ASW primarily contains small pieces of <br />plastic and rubber, inert material and small metal bits from the <br />