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• MEMORANDUMS <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routier Road Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS: 8-495-5600 <br /> TO: Greg K. Vaughn FROM: Robert L. Niblack <br /> Senior Engineer Engineering Geologist <br /> TPCA/RCRA Unit TPCA/RCRA Unit <br /> DATE: 13 April 1989 SIGNATURE <br /> SUBJECT: CORRECTION OF DEFICIENCIES IN HYDROGEOLOGICAL ASSESSMENT REPORT FOR MARLEY <br /> COOLING TOWER COMPANY, STOCKTON, SAN JOAQUIN COUNTY <br /> Marley Cooling Tower Company (MCTC) submitted a Hydrogeological Assessment Report (HAR) <br /> dated 27 April 1987 in order to comply with the Toxic Pits Cleanup Act (TPCA) . A <br /> Regional Water Quality Control Board (Board) staff memorandum dated 10 September 1987 <br /> commented on the HAR, noting three areas of deficiency. MCTC responded to the <br /> comments, and stated that a HAR addendum would be submitted to correct the <br /> deficiencies. To this date no document entitled 'HAR addendum' has been submitted to <br /> the Board. Several reports have been submitted, however, which include the information <br /> missing in the original HAR. <br /> The original deficiencies, and the information submitted which corrects them are <br /> discussed in the next three sections of this memorandum. <br /> WASTE CHARACTERISTICS <br /> In the 10 September 1987 memorandum Board staff commented, "TPCA requires full waste <br /> characterization as required in Section 25208.8(b) of the TPCA, " and asked for an <br /> estimate of the quantity of contaminated sludge contained in the surface impoundment. <br /> Section 25208.8(b) requires, "A description of the volume and concentration of <br /> hazardous waste constituents placed in the surface impoundment, based on a <br /> representative chemical analysis of the specific hazardous waste type and accounting <br /> for variance in hazardous waste constituents over time. " <br /> The specific hazardous waste type discharged to the surface impoundment was storm water <br /> runoff contaminated with a solution of wood preservative chemicals including copper, <br /> chromium, and arsenic up to 1982, and a solution of copper and chromium after 1982. <br /> This fact has been restated in several site assessment reports received from MCTC. <br /> MCTC estimated the volume of contaminated material in the surface impoundment in cross- <br /> sections and calculations developed from soil sampling conducted in 1988. The <br /> estimates are found in Appendix A of a report titled "Engineering and Environmental <br /> Analysis of Storm Water Retention Pond Closure Alternatives" submitted to the Board <br /> by MCTC in November 1988. <br /> Contaminant levels in storm water runoff which was formerly directed to the pond are <br /> described in Table 2-1 of a report titled "Groundwater Treatment Plant Operation <br /> Report" submitted in March 1988. This table describes the range of the following <br /> constituents found in storm water runoff from the site: hexavalent chromium, total <br /> chromium, copper, arsenic, alkalinity, calcium, magnesium, sodium, potassium, sulfate, <br />