SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

• MEMORANDUM • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road Phone: (916) 361-5600 Sacramento, CA 95827-3096 ATSS Phone: 8-495-5600 N A TO: Greg Vaughn FROM: Camilla Williams "'fl Senior Engineer Engineering Geologi �s CVRWQCB DEC 4 1989 ENVIRONMENTAL HEALTH PERMkT/SERVECES DATE: 30 November 1989 SIGNATURE: dyY ( ��i�(1 �0 SUBJECT: REVIEW OF PHASE I DRILLING MUD, CUTTINGS, DEVELOPMENT AND AQUIFER TEST WATERS DISPOSAL REPORT, KEARNEY-KPF, STOCKTON, CALIFORNIA I have reviewed the analytical results of the wastes produced during Phase I of the Groundwater Assessment field activities at Kearney-KPF-. Hargis and Associates submitted these results in a letter dated 14 November 1989. Wastes produced during the remedial investigation (drilling muds, cuttings, aquifer test and development waters) were containerized, sampled and analyzed prior to disposal in three separate areas in the field in the western portion of the site. A total of approximately 105,000 gallons of mud, 4,000 gallons of cuttings, and 13,300 gallons of development and aquifer test waters were disposed of in their respective areas. Based on the submitted data, the remedial investigation wastes disposed on-site met the criteria set forth in our letter of 1 June 1989. Additional wastes will be produced from Phase II of the remedial investigation. Approximately 15,500 gallons of mud and cuttings will be added to the two respective disposal areas. It is logical to assume that contaminant concentrations in the Phase II wastes will be similar to those concentrations of the Phase I wastes (listed in Tables 5 through 11 in the 14 November 1989 letter) . Because site conditions have not changed except that the ground water table has continued to drop, it appears that an attenuation factor of 100 for inorganic and organic constituents would be applicable and conservative. An attenuation factor of 1000 is assumed for copper and zinc (3 November 1988 Regional Board letter to owners/operators of Class III landfills). A list of potential inorganic and organic contaminants and their respective disposal limit concentrations is attached. These disposal limit concentrations should not be exceeded. These limits are reasonable guidelines, but if higher disposal limit concentrations are employed, Hargis should justify their usage. The disposal of wastes from Phase II of the remedial investigation should be performed using many of the same disposal conditions for the Phase I wastes. The following conditions should be met for disposal of wastes from Phase II of the remedial investigation. • All wastes should be containerized/stored, labeled and have representative samples taken for analyses prior to disposal. The criteria for the number of samples per volume of wastes should be similar to that previously established by Hargis for the sampling of the Phase I materials.