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f 1 <br />' ®Pp.U1N <br />). <br />PUBLI] HEALI H SEII�ICES <br />SAN JOAQUIN COUNTY a <br />JOGI KHANNA NI.D.. M.P.14 <br />s'. <br />Health Officer <br />P.O. Box 2009 • (1601 East Hazelton Avenue) • Stockton, California 95201 <br />cq�o�oR <br />(209) 468-3400 <br />•f�Li! <br />Mr. Jack Hecht <br />Cove Contractors <br />2711 Navy Drive <br />Stockton, CA 95206 <br />RE: Cove Contractors Solid Waste Facility 39 -AA -010 <br />San Joaquin County Public Health Services, Environmental Health <br />Division (PHS-EHD) has reviewed the Report of Disposal Site <br />Information (RDSI) for the Cove Contractors Site as it correlates <br />to the California Integrated Waste Management Board Permit Desk <br />Manual. <br />The following concerns need to be addressed by you or your staff in <br />order for us to consider the RDSI complete. The additional <br />information may be provided as an addendum to the RDSI or a revised <br />version of the RDSI may be submitted. <br />1) The presence of waste in contact with ground water is in <br />violation of section 17709 Title 14 CCR. PHS-EHD requests a <br />remediation plan be submitted as part of the RDSI. <br />2) California Regional Water Quality Control Board (CRWQCB) Waste <br />Discharge Requirement (WDR) 87-22 permits the disposal of Auto <br />Shredder Waste (ASW) to class III landfills under specific <br />conditions "as designated by the regional board." The <br />resolution also states that "... processed shredder waste may <br />pose a significant threat to water quality if discharged to an <br />unlined Class III landfill which has insufficient natural <br />protection." The cove contractors site is not lined and <br />therefore is not in compliance with WDR 87-22. <br />3 ) 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 ...." Treatment standards per the CRWQCB letter <br />dated 7/30/87 are lower than the proposed California State <br />Department of Health Services (DHS) treatment standards. The <br />concentrations of Cadmium, Lead, Nickel and Zinc in treated <br />ASW are higher than the treatment standards per above <br />mentioned CRWQCB letter. PHS-EHD requests additional <br />information to clarify this discrepancy as part of the RDSI. <br />The following concerns are indexed to the particular RDI section <br />in question: <br />A Division of San Joaquin County Health Care Services 10 <br />