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PUBLIC HEALTH SEtICES <br />SAN JOAQUIN COUNTY <br />JOGI KHANNA ivLD., M.P.H. <br />Health Officer <br />P.O. Box 2009 • (1601 East Hazelton Avenue) • Stockton, California 95201 <br />(209) 468-3400 <br />September 9, 1991 <br />Mr. Jack Hecht <br />Cove Contractors <br />2711 Navy Drive <br />Stockton C.A. 95206 <br />San Joaquin County Public Health Services Environmental Health <br />Division (EHD) has reviewed the Periodic Site Review (PSR) for the <br />Cove Contractors Site. <br />The following are two major concerns of the PSR as it correlates to <br />the California Integrated Waste Management Board Permit Desk Manual <br />(PDM) which states that the operation of a facility does not <br />adversely affect the environment public health or safety: <br />1) The PSR states remediation of in place waste would be <br />expensive and not warranted in view of the fact that elevated <br />total dissolved solids and sulfate could not be attributed to waste <br />in the groundwater. The presence of auto shredder waste (ASW) in <br />the groundwater below an unlined landfill of questionable contents <br />provides a conduit by which contamination may enter the drinking <br />ground water supply therefore remediation may be warranted. <br />2) EHD feels that any proposal which adds new waste on top of <br />the existing landfill will add to the potential for contamination <br />at this unlined class III landfill site especially since waste is <br />present at -20 feet mean sea level and first ground water is <br />present at -17 feet mean sea level. <br />The following is a line by line evaluation of the Periodic Site <br />Review: <br />PDM section A-3 corresponding to PSR section C.4. The PSR refers <br />to drawing 1 as showing site access from El Dorado street. The map <br />known as drawing one does not clearly show the site access gate or <br />driveway. <br />PDM section A -5,A -6,B -1,B-2 corresponding to PSR sections C.6, <br />C.6.1.5, D.1, and D.2. These sections are not present in the PSR. <br />EHD requests these sections be made available to continue <br />processing the 5 year permit review. <br />PDM section B -5b corresponding to PSR D.5.3. This section of -the <br />A Division of San Joaquin County Health Care Services <br />