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STb TE,OF CALIFORNIA • • GEORGE DEUKMEJIA N, Governor _ r CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION 3443 ROUTIER ROAD, SUITE A r SACRAMENTO, CA 95827-3098 16 July 1990 pp Mr. Kirk Moon I V Ekt U.S. Chemical Company J U L 18 19^1 1448 Shaw Road Stockton, California 95205 ENVIRONMENTAL HEALTH PERMIT/SERVi(;ES APPROVAL OF REVISED WASTE CHARACTERIZATION WORK PLAN, U.S. CHEMICAL COMPANY, STOCKTON FACILITY, SAN JOAQUIN COUNTY We have received and approve the 2 July 1990 Revised Waste Characterization Work Plan for the surface impoundment at the USC Stockton facility submitted by Harding Lawson Associates. The Toxic Pits Cleanup Act (TPCA) requires a representative chemical analysis of 1) the volume and concentration of the hazardous wastes and an accounting for variance in hazardous waste constituents over time, and 2) an analysis for all pollutants discharged into the surface impoundment. The proposed testing is a reasonable attempt to identify specific listed or characteristic hazardous waste constituents or the pollutants that may be impacting the quality of the ground water. The following are staff comments on the 2 July 1990 work plan which must be considered and incorporated in the waste characterization report: 1 . The work plan states that dyes up to 13 ppm and scents up to 5,000 ppm are used. These "custom" phenols and aromatics and their breakdown products, if present, will show up on the chromatograph and MS but may not be identifiable by the lab with the EPA Method 8240 and 8270. Please report the total amount of unknown peaks. 2. The work plan states that the GC/MS analyses 8270 and 8240 is proposed for both wastewater and sludge samples. Methods 624 and 625 are the applicable analyses for wastewater samples. Our laboratory had difficulty using Method 601 due to the forming detergent component of the wastewater. Also, the work plan states that direct (GC) 'aqueous' injection will be used to identify acids, bases, and alcohols, staff assumes that the term 'solvent' not 'aqueous' was meant. 3. The surface impoundment profile conducted on 12 June 1990 appears to have been able to define a one inch thickness of sludge above the surface impoundment liner. Staff assumes that the thickness and distribution of the sludge isopachs rely of the difference between as-built construction drawings and the soundings; the Board has no information to support the contention that the surface impoundment bottom was sufficiently level to distinguish a one inch thick accumulation of sludge at the distal end of the surface impoundment. We agree that additional stratified samples need to be collected if the sediments are thicker or thinner, or display an apparent variability in color.