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` OMemorand u m • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3443 Routier Road Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS: 8-495-5600 TO: Greg Vaughn FROM: Camilla Williams Senior Engineer Engineering Geologist DATE: SIGNATURE: r n'f 'L1-��G`� �v 1 June 1989 SUBJECT: DRILLING MUD, CUTTINGS AND DEVELOPMENT WATER DISPOSAL, KEARNEY-KPF, SAN JOAQUIN I have reviewed the two proposals dated 9 December 1988 and 23 January 1989 submitted by Hargis and Associates on behalf of Kearney-KPF. The first document is entitled Disposal of Drummed Material at the Kearney Site and contained analytical results of these drummed materials left by the previous on-site investigation. The second is entitled Drilling Mud, Cuttings and Development Water Disposal and covers those wastes being generated during the ongoing investigation. This proposal was reiterated by letter dated 18 April 1989. These disposal plans have been discussed in detail in subsequent telephone conversations with Hargis. Per these conversations, the plans have been augmented to include aquifer test water. Both documents proposed to dispose of the wastes in the field in the western portion of the site (west field). This field is in a non-manufacturing area and is believed to be uncontaminated. On 3 May 1989, I was at the site to inspect the proposed disposal areas. My report of that inspection and of the map of the proposed disposal areas is attached. Review of Documents The first document contained analytical results for heavy metals and volatile organic constituents (VOCs) from 44 drums. Of these drums, five contained purge water, each of which were sampled and analyzed. The remaining drums contained the muds and cuttings of which drums were composited to obtain ten samples which were analyzed. The drilling muds and cutting were analyzed for the total concentration and not the soluble concentration. The results for totals were at least two orders of magnitude less than the respective Total Threshold Limit Concentration (TTLC) values for all the Title 22 metals except for arsenic. The highest arsenic concentration in any of the samples was 14 mg/kg and the TTLC is 500 mg/kg. The analytical results for concentrations of heavy metals from the samples of purge water were either not detected or were below the primary or secondary drinking water standards. In the first document the analytical results for VOC concentrations in the drummed drilling mud and cuttings all below 1 mg/kg. The maximum concentration detected for any VOC was trichloroethylene (TCE) at 10.7 mg/kg which is far below the TTLC of 2040 mg/kg. Other VOCs detected in the purge water were 1.1-dichloroethane (DCA) , 1 ,1-dichloroethylene (I)CE) , trichlorotrifluroethane