SITE INFORMATION AND CORRESPONDENCE

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BEAVER CHEMICAL COMPANY 3 19 December 1989 INSPECTION MEMO 2) b) If any of the results are less than the TTLC but greater than ten times the Soluble Threshold Limit Concentration (STLC) for any of the constituents, then BCC will be required to reanalyze the samples in order to determine the soluble metal and organic levels in the sediments (Note: The metal and organic samples should be retained until all analysis are complete) . Results from the above program should enable BCC to determine which constituents to monitor in the ground water monitoring program and determine if the pond contains any hazardous wastes from past discharges. Mr. Heaviland stated that the previous plant manager thought that BCC was required by the Regional Board to close the pond. I told him the pond could be used as long as the discharge into the pond did not impact or threaten to impact water quality. The plant inspection included a tour of the facilities and sampling of the wastewater discharge and pond. Weeds were growing on the berm around the pond and I noticed some surface cracks in the top of the berm on the north side of the pond. I told BCC that the berm around the pond would have to be better maintained and the San Joaquin County Mosquito Abatement District could assist them in setting up a maintenance program to control weeds and rodents. Field sample results of the wastewater taken at the collection sump prior to discharge to the pond were as follows: pH=3 and Electric Conductivity = 4,000 ,mhos/cm. The Semi-volatile (EPA 625) sample was a grab sample from the collection sump. ICAP metals, Biological Oxygen Demand, and Total Dissolved and Suspended Solids analysis were run on composite samples of the wastewater in the collection sump and the pond. The results are summarized in Attachment 2 and photocopies of the laboratory results are included in the attachment. The results indicate that BCC's discharge is a designated waste since it contains a significantly high amount, 34770 mg/1 , of Total Dissolved Solids (compared to the State Secondary Drinking Water Standard of 500 mg/1 ) . The results also show that Aluminum, Chromium, Iron, and Manganese exceeded the Primary or Secondary Drinking Water Standards. Therefore, it is necessary for BCC to develop a ground water monitoring program and submit to our office for approval . The objectives of the program should be to determine the depth of the shallow water bearing zone beneath the pond, the direction of ground water flow in this zone and water quality in the zone. Results from this phase of work should enable BCC to determine the extent of further work. INSPECTION SUMMARY AND RECOMMENDATION: Sample results indicate that BCC's discharge to their clay-lined wastewater pond is a designated waste. Therefore, a ground water investigation and monitoring program will be required. BCC is also required to begin a sampling program that characterizes its discharge to the pond and the wastewater and sediments in the pond. Once the discharge has been characterized and once we determine the impact