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+ MEMORANDUM • <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routler Road Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 <br /> TO: Greg Vaughn FROM: Camilla Williams <br /> Senior WRC Engineer Engineering <br /> Geologist <br /> DATE: 2 January 1990 SIGNATURE: V n,�; <br /> SUBJECT: SOIL ASSESSMENT AND REVISION OF WASTE DISCHARGE REQUIREMENTS, <br /> KEARNEY-KPF, SAN JOAQUIN COUNTY <br /> I have reviewed the 28 November 1989 letter from Hargis and Associates regarding <br /> the need for additional soil analyses and sampling at the Kearney-KPF facility. <br /> This letter states that the Regional Board assumed that soils in the Pond 1 area <br /> were acidic. Soil samples from the Pond 1 area were analyzed using a citric acid <br /> Waste Extraction Test (WET) . We required the citric acid WET because previously <br /> analyzed samples from the Pond 1 area were acidic based on the data submitted <br /> by Canonie Environmental and SNR Company (refer to Figures 10-2 through 10-6, <br /> Tables 10.1 through 10.6 of the Hydrogeologic Assessment Report and Tables 2 and <br /> 6 of the Report of Supplement Monitoring Wells Installation and Laboratory <br /> Testing) . Therefore, the requirement to analyze samples using the citric acid <br /> WET was based on previous data and not on an assumption. <br /> Hargis has proposed to reanalyze selected samples from the Pond 1 area using the <br /> deionized water WET, as this test would simulate the effects of precipitation <br /> percolating through nonacidic soils better than the citric acid WET which they <br /> have just performed. Hargis has also proposed to collect additional surface soil <br /> samples in the areas where the Department of Health Services collected samples <br /> in February 1987. Because additional time will be required to reanalyze and <br /> collect these samples, Hargis will need additional 14 weeks to submit the Soil <br /> Assessment Report. The Soil Assessment Report is to be included in the Selected <br /> Closure Alternative Documentation with a compliance date of 19 January 1989 as <br /> specified in Waste Discharge Requirements (WDRs) Order No. 89-163. <br /> If the Selected Closure Alternative Documentation is submitted 14 weeks later <br /> (27 April 1989) , subsequent dates in the WDRs must accordingly be delayed. <br /> However, in telephone conversations with Peter Quinlan, he has stated that the <br /> 1 December 1990 compliance date for pond closure will not be delayed. Therefore, <br /> the interim compliance dates between January and December 1990 in existing WDRs <br /> must be adjusted. <br /> Because staff cannot grant extensions to Board adopted WDR' s, the WDR' s will need <br /> to be amended. Prior to revision of the WDR' s Hargis must submit a new time <br /> schedule which will be considered in the revised WDRs. <br /> CKW:ej <br />