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s MEMORANDUM TO: William S. Johnson 4 August 1982 FROM: Robert S. Jones SUBJECT: ARCADY OIL COMPANY DISPOSAL SITE Arcady Oil Company maintains a Class III non-toxic drilling mud disposal site located at Whiskey Slough and Holt Road, Holt, California. The site contains several diked lagoons adjacent to the slough. Board Order No. 76-152 pre- scribes requirements on the facility. In response to complaints, the San Joaquin Local Health District and our office inspected the Arcady Oil Company for improper use of this site. The inspections revealed the following conditions: 1 . 9 July 1981 - Code Begley of State Hazardous Waste Management Branch collected samples of waste material from the Arcady disposal ponds. The analyses of the samples showed metal concentrations. For the trace metals analyzed, chromium of 427 mg/kg exceeded the CAM cleanup level of 50 mg/kg. 2. On 7 January 1982, WRC Engineer Bob Fujii , of our office, inspected the facility. He noted the following points in the report: a. The disposal site was inundated with rain water. b. There were oil deposits present in the ponds. c. The main access gate was unlocked and the site was unattended. 3. On 10 March 1982, Don K. Rothenbaum, of our office, collected samples of waste material from the Arcady disposal ponds. Metal concentrations were found in the analysis of the sludge samples. For the trace metals analyzed, chromium at 287 mg/kg exceeded the CAM cleanup level . 4. On 9 June 1982, officials from the San Joaquin Local Health District inspected the site. They found excessive oil deposits on the water in the disposal ponds. Furthermore, their inspection revealed that the entire levee area on the north end of the site (adjacent to EBMUD pipelines) has inadequate pro- tection from washout or erosion into the Whiskey Slough waterways. Based on the information gathered in the above mentioned inspections, it appears Arcady Oil Company is presently in violation or threatened violation of Board Order No. 76-152, Discharge Specifications A1 ,3,4,8,9,10,ll*, and 12, Provisions B.3** *The high water table in this area leads to a potential degradation of the under- . ground and surface water supply ** Discharger does not comply with Monitoring and Reporting Program contained in Board Order No. 76-152, which requires ponded water within the disposal site to be sampled and analyzed on a quarterly basis.