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Antonia Vorster -2- 21 October 1987 To assess the above items a ground water monitoring program is recommended. Results would determine landfill classification, i .e. , I, II, III or unclas- sified, which in turn will dictate closure requirements or any additional work necessary. Additionally, J-M landfills have been placed in Rank 4 of Calderon's Solid Waste Assessment List. Rank 4 facilities must submit their SWAT by April 1989 and complete their SWAT report by July 1990. To avoid any future work, I suggested the current ground water monitoring system be designed in accordance with Calderon requirements. J-M officials were receptive to this suggestion. 2. Ponds Two ponds on-site receive process and cooling water. Water samples from 19861 indicated all constituents are well below drinking water standards with the exception of mercury and chromium. Aqueous concentrations of mercury and total chromium in the pond ranged from 2-3 ppb and 95-145 ppb, respec- tively. Drinking water standards are 2 ppb for mercury and 50 ppb for total chromium. Considering expected attenuations in the soil column and aquifer dilution, existing mercury concentrations are not an obvious problem. Unfortunately, no information is available prior to 1986 to assess if 1986 concentrations are representative. Ground water monitoring wells may be, warranted. J/M officials inquired about the possibility of leaving pond sludge in place and closing the pond 's in-situ. As previously discussed, the sludge has no priority pollutants or appreciable metal content. The only concern would be TDS and mineral leachability. Analysis using WET methodology (Title 22, California Administrative, Section 66700) specifying deionized water would answer this question. However, 1986 inspections of the ponds indicated that achieving a minimum 2' cover needed for in-situ pond closure may be difficult. Staff recommended that sludge be disposed of in on-site landfills, if appropriate. On-site landfill disposal is contingent upon landfill ground water monitoring and analysis of pond sludge. 3. Soils During inspections, crushed pipe and numerous gray-white deposits were noted surrounding the ponds and on dirt access roads. Kleinfelder's boring logs noted asbestos in the upper 1 '-6' depending on location. This material may be carried to Little John Creek by storm runoff. Since asbestos has been placed on the Proposition 65 list, no discharge of asbestos materials to surface waters will be allowed after November 1988. 1(J/M A-C Pipe Corporation "Report of Disposal Site Information° J. H. Klein- felder and Assoc. 1986)