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U <br />5-471 = CALIFORNIA <br />CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br />CENTRAL VALLEY REGION <br />1-3 =OUT EA ROAO. SUITE A <br />C McNlu. CA 95827-3098 <br />214ON2 .9161 36 t -5000 <br />Z - 4 4- 101.5086 <br />2 March 1992 <br />Mr. Jack Hecht <br />Cove Contractors <br />2711 Navy Drive <br />Stockton, CA 95206 <br />U VVI <br />MAR 04 1992 <br />U 1 /7 <br />BV_ <br />L <br />COVE CONTRACTORS DISPOSAL SITE, SAN JOAQUIN COUNTY, CASE NO. 2797 <br />We have reviewed your 23 January 1992 letter written in response to deficiencies noted in <br />the Report of Waste Discharge (RWM) for the Cove Contractors auto shredder waste <br />(ASW) disposal site. The following addresses main topics of disagr6ement outlined in <br />your letter. <br />Our position remains that site conditions alone at Cove are insufficient to ensure no <br />impairment of beneficial uses of waters of the State beneath or adjacent to the landfill <br />from the proposed discharge of Auto Shredder Waste (ASW). The site is a threat to <br />around water because of shallow ground water (the RWD states that a 3 foot separation <br />exists between proposed waste discharge and highest anticipated ground water). The site <br />is a threat to surface waters as indicated by the fact that engineered levees are required <br />for 100 -year flood protection and no effective storm water management plan has been <br />proposed. No containment structures or leachate collection and removal system are <br />proposed other than a partial "capillary break'. <br />The RWD does not demonstrate that Soluble Designated Levels (DLs) for protection of <br />water quality will not be exceeded. In fact, the RWD acknowledges through the use of an <br />uncalibrated general computer model that metals will be mobilized in the vadose zone <br />and total dissolved solids (TDS) in ground water will increase above the secondary <br />Maximum Contaminant Level (MCL) of 300 mg/1. <br />Monitoring data for ASW submitted in the RWD also shows high extractable metallic <br />concentrations well in excess of DLs for an average site which threatens surface and <br />ground water (see attached memo on regional board ASW policy dated 30 July 1987 and <br />attached waste acceptance policy memo dated 30 March 1989). 'Of particular concern is <br />extractable chromium VI which is extremely mobile and has low numerical water quality <br />goals of 0.05 mg/l (for protection of human health) and 0.011 mg11(for protection of <br />aquatic life). As indicated in the attachment, for sites like Cove with shallow ground <br />water and no effective storm water management plan, the DL for chromium VI would be <br />0.011 mg/l. Detection of methane gas associated with in-place waste at the site implies <br />0 <br />significant organic decomposition. Therefore, use of the standard citrate buffer Waste <br />