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U <br />Cove Contractors <br />.2 - <br />El <br />Extraction Test (§66700 of Title 22, California Code of Regulations) for assessment of <br />extractable metals other than chromium VI is appropriate. <br />Your letter proposes to change background monitoring wells from designated wells at <br />the Cove site to selected wells in the Stockton area. However, demonstration is not <br />provided to preclude anthropogenic: sources of TDS for these wells and aquifer <br />conditions have not been demonstrated to be directly comparable. Although recharge <br />from Walker Slough may have a localized effect of reducing TDS at Cove, the slough <br />provides a potential source of ground water replenishment and as such, is a valid aspect <br />of background water quality. <br />In addition to the above topics of disagreement, additional issues have not been resolved <br />as requested. However, we plan to initiate preparation of a preliminary set of tentative <br />waste discharge requirements (WDRs). Initially, we will request clarification from the <br />Integrated Waste Management Board and the San Joaquin County of Public Health <br />Services, Environmental Health Division regarding the California Environmental Quality <br />Act (CEQA) issue. <br />After public review, tentative WDRs are submitted to our Board for adoption in a public <br />meeting. Cove Contractors, Incorporated would be provided the opportunity to present <br />testimony contesting the tentative WDRs. <br />If you have any questions, please contact me at (916) 361-3741 or Scott Walker at <br />(916) 361-5736. <br />C.1-7 <br />7 <br />WILLIAM j. MARSHALL, Chief <br />Chapter 15 Land Discharge Unit <br />6IN&MR-61 <br />cc: 1,Tir. Robert Fujii, California Integrated Waste Management Board, Permitting and <br />Compliance Division, Closure and Corrective Action Branch, Sacramento <br />Ms. Betsy Jennings, State Water Resources Control Board, Office of Chief Counsel, <br />Sacramento (w/o attachment) <br />Mr. Ed Padilla, San Joaquin County Department of Public Health Services, <br />Environmental Health Division, Stockton <br />N -4r. Mark Urquhart, Kleinfelder, Incorporated, Sacramento <br />iMr. David Sadwick, Heller, Ehrman, White, & McAuliffe, Los Angeles <br />