FIELD DOCUMENTS AND WORK PLANS 1989

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Marley ,Cooling Tower CO.* -2- • 13 April 1989 chloride nitrate, pH, conductivity, total dissolved solids, total suspended solids, turbidity, total organic carbon, and oil and grease. The waste characterization information submitted to date is adequate to satisfy the requirements of Section 25208.7(b) of the TPCA. GROUND WATER The 10 September 1987 staff memorandum noted that the HAR did not include all information required under Section 25208.8(f) (3) of the TPCA. Deficiencies included lack of storage coefficient values for ground water bodies identified in the HAR. Staff also noted that more accurate transmissivity values would be needed for a ground water extraction system. MCTC completed multiple well aquifer tests in November 1987, seven months after they submitted their HAR. The results of those tests were presented in a report titled "Construction and Testing of Pilot Extraction Well EW-1." Aquifer parameters were also discussed on page 9 in the Comprehensive Monitoring Evaluation (CME) prepared by Regional Board staff. Storage coefficient values as well as transmissivity values for the aquifer at MCTC were reported in the CME. The ground water information lacking in the original HAR is now present in the files of the Board. MCTC has met the requirements of Section 25208.8(f) (3) of the TPCA. VADOSE ZONE Staff noted that chemical characterization of vadose zone soils had not been performed at the MCTC site. Section 25208.8(i ) of the TPCA requires a chemical characterization of the rock material underlying the impoundment, including analysis for those constituents discharged into the impoundment. MCTC submitted chemical analyses for samples taken from borings in the impoundment in the report titled "Engineering and Environmental Analysis of Storm Water Retention Pond Closure Alternatives" submitted to the Board in November 1988. The data and cross sections included in Appendix A of this report satisfy the requirements of Section 25208.8(i) of the TPCA. DEFINITION OF THE EXTENT OF GROUND WATER. CONTAMINATION A HAR is not complete until the extent of ground water contamination resulting from use of a surface impoundment has been determined. MCTC has installed over 63 monitoring wells in their efforts to delineate the plume of ground water contamination emanating from this wood treatment facility. The surface impoundment is only one of two sources which contribute to the overall degradation of the ground water beneath the facility. It may be impossible to differentiate between the wastes migrating from the impoundment and the retort pit. MCTC is presently in Phase V of their ground water investigation. The monitoring wells installed in this phase of the investigation should bound the down gradient edge of the contaminant plume, over one mile south of the facility. Upon submission of the results of the Phase V of the ground water investigation the requirements of Section 25208.8 of the TPCA shall have been satisfied.