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Antonia Vorster -4- 21 October 1987 Potentially, stormwater could be combined with PVC blowdown water if discharge of blowdown water to ponds is allowed. J/M could create a new pond or refur- bish the two existing ponds. To prevent raw materials from the PVC process from entering the on-site ponds and creating a potential ground water pollution probem or TPCA site, J/M should develop a Spill Contingency Plan. SUMMARY J/M should submit a closure plan that addresses the following items: 1. Ground Water Monitoring for on-site Landfills Landfill closure requirements will be based on results of this monitoring. To avoid future work, the monitoring program should meet Calderon Requirements. Staff also recommends that permanent boundry markers be installed at all existing landfill sites. A copy of the Calderon guidelines are attached. 2. Existing Ponds Analyze pond sludge for TDS and general minerals using WET methodology with deionized water. Develop a closure strategy and time schedule for implementa- tion. Ground water monitoring wells should be considered. 3. Soils Develop a procedure and time schedule for addressing asbestos containing soils on-site. This procedure should be submitted to DHS and Regional Board staff for review. 4. Ongoing Operations J/M should indicate its preference for stormwater and 'PVC blowdown discharge. Off-site discharge to Little John Creek will require an NPDES permit and monitoring. On-site pond disposal of PUC blowdown water will require the following infor- mation to assess its impact and acceptability. o File a Report of Waste Discharge. o Determine background water quality. o Determine volume, chemical characterization and variability of blowdown. Analyses should include TDS, metals (use AA), general minerals, priority pollutants, and oil and grease.