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BEAVER CHEMICAL COMPANY 2 19 December 1989 INSPECTION MEMO I met with Jim Heaviland, Vice President of Operations, and Joel Rosenow, Quality Assurance Manager, to discuss the facility operations, the potential water quality impacts, the need for a ground water investigation and for monitoring requirements, and the applicability of California Code of Regulations, Title 23, Chapter 3, Subchapter 15 (Subchapter 15) to BCC's discharge to its wastewater disposal pond. At the beginning of our discussion, I explained to BCC our approach to their facility. First, we would access the potential threat to water quality, by inspecting the facility and taking samples of their discharge and the pond. If a potential threat exists, we would require BCC to develop and implement a ground water monitoring program. If results showed that ground water quality has been impacted, then BCC will be required to retrofit their ponds to meet Subchapter 15 requirements or eliminate the ponds and remediate any impacts resulting from the pond. Although not mentioned during the meeting, BCC may be required to retrofit its pond if BCC is discharging a designated waste (which contains a constituent or group of constituents which may not be contained by the waste management unit (or pond) as specified in Subchapter 15) . Mr. Heaviland stated that BCC had conducted sampling of the water and sediment in their wastewater pond. Mr. Heaviland gave me a copy of the interoffice memo with sample results (see Attachment 1) . Basically, the results show that the water contained volatile organics (96 ppm-Acetone, 55 ppm-Isopropyl/Alcohol , 65 ppm-N-butanol ) and some metals in the sediments (330 ppb-Barium, 18 ppb- Arsenic) using the EPA toxicity test. It should be noted that the laboratory indicated on the report that n-butanol could possibly be chloroform, benzene, or perchloroethylene since they all have the same retention time when run through a gas chromatograph. The above results were from one grab sample and a more complete sampling program is needed to qualitatively and quantitatively characterize the wastewater and pond sediments. BCC will be required to have a sampling program that accomplishes the following: 1) Characterize all current waste streams associated with the production of each of the various types of chemicals and the wastewater in the pond. Samples representative of the current waste streams and pond wastewater shall be analyzed for general minerals, volatile and semi- volatile organics, pesticides, and metals at a minimum. 2) Pond sediments shall be characterized as described in Section 66699 of Article 11, Chapter 30, Division 4, Title 22, California Code of Regulations. Samples, representative of pond sediments in the entire pond, shall be analyzed for total metals and organics to determine if the Total Threshold Limit Concentration (TTLC) has been exceeded. a) If the TTLC has been exceeded for any of the constituents, then the sediments will be considered hazardous.