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*Memorandum CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD e CENTRAL VALLEY REGION 3201 S Street Sacramento, California 95816 Phone: 445-0270 Paul E. Jepperson FROM: Robert E. Fujii To: Associate Water Resource Supervising Engineer Control Engineer Jerrold A. Bruns, Chief Standards, Policies, and Special Studies Section DATE: 17 July 1986 SIGNATURE: SUBJECT: MARLE.Y COOLING TOWER COMPANY (CLOSURE AND POST-CLOSURE PLAN REVIEW) I have reviewed the Surface Impoundment Closure and Post-Closure Plans and have the following comments: 1 . On page 20: The closure schedule is confusing since there are two tasks numbered 7 and no days allowed for construction of the drainage controls. 2. On page 26: Existing data appear to indicate that copper (Cu) and Arsenic (As) are absorbed in the upper soil strata. However, Chromium VI (Cr VI) which is also present in the soils underlying the Marley Cooling Tower Company (MCTC) site is very mobile. Analyses of samples from monitoring wells located near the surface impoundment (MW-5, MW-207, and MW-102) have indicated levels in excess of the drinking water standard for total Chromium (total Cr) of 0.05 mg/1 . Therefore, MCTC should characterize the concentrations present in the pond sediments and also the soils immediately underlying the surface impoundment. Once characterized, an assessment of whether it is reasonable and economically feasible to remove these materials can be made. 3. On page 53: Due to the close proximity of the stormwater retention pond to the retort pit it may be difficult to establish a point of compliance and develop a ground water monitoring program for just the pond alone. Therefore, MCTC should cocrdinate the post-closure monitoring for the pond with the existing monitoring program for the overall site. This will entail quarterly monitoring of all on-site and off-site wells. The parameters suggested in the plan should be adequate (Cu, As, Cr VI, total Cr) along with an additional analysis for nitrates. Since the MCTC surface impoundment has been determined to be a Class I waste management unit, the specifications for the final closure design and post- closure maintenance activities are governed by the Department of Health Services (DHS) regulations which are contained in Title 22, Division 4, Chapter 30, of the California Administrative Code. The design specifications, although not directly covered under our regulations (i .e. , Subchapter 15), are still subject to review and approval by the Regional Board. Based on my review and discussions with the staff of DHS regarding their specific comments on the final closure design we concur that it does not meet the requirements of Title 22. Therefore, if MCTC addresses the comments drafted by DHS this should satisfy the concerns of the Regional Board as well . REF:mlm