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. I k 0 0 STATE OF CALIFORNIA-- GEORGE DEUKMEJIAN,Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD- CENTRAL VALLEY REGION =a m 3201 S STREET SACRAMENTO,CALIFORNIA 95816-7090 PHONE: (916)445-0270 .SUN 1 2 vff 11 June 1984 Mr. A. J. Diepenbrock Arcady Oil Company 1515 Hope Street, Suite 202 South Pasadena, CA 91030 ARCADY OIL COMPANY, CLASS III DRILLING MUD DISPOSAL SITE, SAN JOAQUIN COUNTY Your 22 May 1984 letter requests a variance from the use of drinking water standards to regulate the disposal of drilling muds and fluids at your Holt site. Your request was based on the contention that there is no fresh-water underlying the area and "layers of clay muds and hardpan prevent the downward percolation of ground water. In support of these claims, excerpts from the State Department of Water Resources' Bulletin #146, San Joaquin County Ground Water Investigation (dated 1967) , were included Arcady also con—te--nTed that ri ing muds are 'an effective sealant and as such, no water can seep through the walls and bottom of the ponds containing the wastewater content of the drilling fluid". The waste discharge requirements presently in effect at Arcady specify that wastes deposited at the site shall be limited to nontoxic drilling muds which contain no oil , grease, or heavy metals. No Group 1 or 2 wastes may be accepted. Arcady has violated these requirements which are the standards used to regulate the disposal of drilling muds at the site. Our 1 May 1984 letter to Arcady referenced Drinking Water Standards as a measure of the ground water contamination resulting from the site. In assessing the impacts of pollution from the site, all beneficial uses of both surface and ground water in the area must be considered. Surface water pollution is of concern since shallow ground water at Roberts Island is pumped to Whiskey and Trapper Sloughs to drain the island. Bulletin,#146, San Joaquin Counter Ground Water Invest dation, was a -r ional study of ground water conditions in the county. As such, site specific conditions are not reported and should not be inferred. Regardless, Bulletin #146 states that pockets of fresh-water quality ground water are found in the Delta. Arcady contends that drilling muds are an effective sealant against seepage from the ponds and that in-situ clay and hardpan layers will prevent percolation of ground water contamination. Since Arcady's own monitoring reports show heavy metal and salt contamination in the shallow ground water, these contentions are obviously in error,