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August 11, 2000 -2 - 003-7170 Pond 4. When Pond 4 reaches its hydraulic capacity, it flows by gravity through an outlet pipe to Pond 5. The remaining stormwater ponds (Ponds 6, 7 and 8) have not received any wastewater from the facility and are not hydraulically connected to Ponds 1 through 5. There is record that, on extreme occasions,water has been pumped from Pond 5 to Pond 6. Totalizing meters (that measure volume discharge) were installed in several process piping locations and Owens-Brockway monitored flow in the meters over a 6 month period in 1998. In July 2000, Owens-Brockway installed additional totalizers throughout the process system. Currently, operating totalizers are located at the outlet of the production well, the inlet of the RO unit, the inlet and outlet to the cooling tower, the shear spray feed, the make-up water feed lines to both API separators (recently replaced or installed), the outlets between the API separators and Pond 1 (recently replaced or installed), and the feed line for floor washing (recently installed). Current plans are to complete installation of totalizers with the replacement of the totalizer between the RO outlet and the process ponds which was not operating during the time of this study. Oil collects on the surface of both API separators, particularly in Separator A/B, from the parts wash- down area and floor wash-down. Skimmers operating in both separators are used to remove oil as it collects on the surface. Oil is removed from the facility by an oil collection and recycling vendor. Signs of oil staining in the surface soils in the interior slope of Pond 1 indicates that oil has, in the past, entered into Pond 1. The API separators were installed to eliminate oil from entering Pond 1. Water is removed from the API separators with vertical turbine pumps. Intakes for the pumps are 7 to 8 feet below any floating petroleum product on the surface of the water in the separator sumps. As an additional measure, we understand that Owens-Brockway changed their oiling practices in December 1999 in order to further reduce the amount of oil that entered the separators. In a letter to the California Regional Water Quality Control Board dated July 7, 2000, Owens-Brockway stated that the volume of oil skimmed from the separators in the first 6 months of 2000 (subsequent to changing oiling practices in December 1999) had been reduced to only 20 percent (one fifth) of the volume collected in the first 6 months of 1999. In addition to the process wastewater circuit, domestic wastewater is discharged to two systems, each containing septic tanks and leachfields. The primary system is located near the process wastewater ponds and has a capacity of 20,000 gallons per day. The second septic system is smaller and serves the "VIP warehouse." Both systems are pumped out, inspected and reseeded on a quarterly basis. Ground water is currently monitored via four monitoring wells on a quarterly basis. The RWQCB has indicated that the ground water downgradient of the process wastewater ponds has been impacted by process wastewater infiltrating into the ground. The WDRs specify that discharges from the facility shall not cause ground water to contain waste constituents in concentrations statistically greater than background water quality, except for coliform. For coliform, increases shall not exceed 2.2/100 milliliters (ml) over any 7-day period. To determine compliance with this specification, the WDRs require that a workplan be submitted presenting an evaluation of the adequacy of the existing monitoring well network with respect to potential contaminant source areas, ground water quality and elevation data,and historical ground water flow directions. 1.2 Previous Investigations Previous ground water investigations conducted at the site have included the installation and monitoring of wells, sampling and analysis of supply well water and process water, and periodic ground water monitoring. The following is a brief description of these investigations. R00-37.doc Golder Associates