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a� 9 V MAR 2 1978 MEMORANDUM AN JOAQUIN LOCAL HEALTH DISTRICT TO: Richard R. Rose FROM: Larry F. Nash SUBJECT: Arcady Oil ; Company, Class III Drilling Mud Disposal Site, Order No. 70-152 On 15 February 1978, I inspected the subject mud disposal site with Joe Gains, site operator, and Ed Holsworth, owner of nearby Whiskey Slough Harbor. Mr. Holsworth had previously contacted our office concerning oil from the Arcady Oil Company site covering his marina waters and interferring with his water supply. We walked along the levee, which separates the disposal area and Trapp Slough. There were several areas where the levee had washed out and which were now temporarily repaired with sand bags. The water in the disposal area appeared to be at the same level as Trapper Slough, which, according to Mr. Hols- worth, was at High Tide. Muskrats were observed during the inspec- tion and Mr. Holsworth and Mr. Gains believe there are probably muskrat holes beneath the levees. Mr. Holsworth stated that the levee is in much better shape now with the sand bag repairs. However, an excessive flood tide such as occurred the previous week would probably over top the levee since there was only about six inch freeboard. Ed Holsworth said that he had been advised to expect a two foot in- crease above normal tides when the snow melt occurs this spring. Joe Gains explained. that because of the high water and flooded dis- posal site he has been unable to bring in equipment to rebuild the levee. He has ordered sorbant pads to place around the site to collect and remove the remaining oil . I advised him that, as soon as possible, he would have to raise the levees to the level required to protect against the 100 year flood; and that if additional flood tides occur, he will have to take what- ever immediate steps possible to prevent further "flushing" of the disposal site, such as additional sand bagging or repairing and clo.,ii.ng of the tide gate between Trapper and Whiskey Sloughs. If he could repair the t i de> gates acid close it during low tide, he could also probably expedite the rebuilding of the levees. The source of the oil at the mud disposal site is presumably illicit dumping since all authorized mud haulers have been told that only non-toxic mud without oil may be disposed. The site is unattended, however, and is not adequately fenced to prevent dumping by un- authorized persons. Also, there are no signs posted prohibiting un- authorized disposal .