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Memo to Greg Vaughn -3- 1 June 1989 Discussion/Conclusions/Recommendations Hargis has proposed disposing of to land drilling muds, cuttings and development water. They have also requested disposing of aquifer test water (during telephone conversations) using the same criteria/restrictions as the development water. In order to allow a waste disposal to land, regulations under the Porter- Cologne Water Quality Control Act require that Waste Discharge Requirements (WDRs) be written. Issuance of WDRs requires a Report of Waste Discharge and a filing fee to be submitted, thereby adding to the complexity and length of the process. Staff does not have the authority to permit waste disposal to land without WDRs. WDRs can be waived, but the case must be taken to the Regional Board for their decision. Resolution 82-036 provides guidance for waiving WDRs but these actions are conditional and may be terminated for any type of discharge or any specific discharger. In October and November 1988, the disposal options for the drilling muds, cuttings and development waters were discussed with Hargis. At that time, I had informed Hargis that the preferable option of disposal would be transporting the materials to a permitted facility, for example, hauling the muds and cuttings to a landfill and the purge waters to the sewer. However, these disposal options were declined by the facility and the two documents were subsequently submitted. Hargis has proposed of disposing to land two sets of muds, cuttings, purge and aquifer test waters: the first is those drummed materials from a previous on- site investigation of which there are analytical results; the second being those materials currently being generated by the remedial investigation of which full analytical results have not been reported. In order to respond to both proposals, it is assumed that the unknown contaminant concentrations of the latter collection of wastes would be similar to those of the drummed materials. Having reviewed the analytical results, it appears that the drummed muds and cuttings cannot be disposed of to land if an attenuation factor of ten is used and the results are compared to the DWS of each respective constituent. However, if an attenuation factor of 100 is used and the results are compared, then the concentrations are below the respective DWS and therefore, disposal of the muds and cuttings could be performed and should not be a threat to water quality. In my opinion, on-site disposal of these materials is reasonable when other site specific factors are considered. (Refer to the attached inspection report. ) Hargis may dispose of the muds, cuttings, development and aquifer test waters if the following conditions are met. • All wastes should be containerized/stored, labeled and have representative samples taken for analyses prior to disposal . The criteria for the number of samples per volume of wastes should be similar to that previously established by Hargis for the sampling of the drummed material . • Analyses on the muds and cuttings must be for soluble concentrations.