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California Regional Water Quality Control Board <br /> I Central Valley Region <br /> •��'°""'"°� Steven T.Butler,Acting Chair °'°°��� <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Intemet Address: http://www.swrcb.ca.gov/—rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 22 March 1999 <br /> Mr. Truong Mai <br /> Environmental Resources Management(ERM) <br /> 620 Bercut Drive <br /> Sacramento, CA 95814 <br /> ARCADYDISPOSAL SITE, SAN JOA QUIN COUNTY(Case No. 2794) <br /> I have reviewed the 19 February 1999 ERM Summary Report for soil investigations at the Arcady <br /> disposal site. The report provides laboratory results for drilling mud waste and groundwater samples. <br /> Waste and groundwater were samples collected in July 1997 and December 1998 using direct-push <br /> methods. <br /> Waste management alternatives at the Arcady site depend in part on the classification of the drilling mud <br /> wastes. Whether these wastes are classified as inert or designated under Title 27 or hazardous under <br /> Title 22 are long-standing issues. The analytical results in the ERM report should be evaluated under <br /> applicable regulations and waste classification criteria. <br /> Perhaps the most critical point is whether the wastes are hazardous. Soluble chromium exceeded <br /> hazardous levels (Title 22 STLC values) in three of six samples analyzed. A discussion of hazardous <br /> waste classification pursuant to Title 22 should be provided. <br /> Waste classification under Title 27 is typically based on the soluble concentrations of waste constituents. <br /> Several soil samples were analyzed for major inorganic constituents and trace metals using de-ionized <br /> water (DI) in the waste extraction test(WET). The DI-WET method instead of the citric acid WET was <br /> used by ERM to better simulate natural, non-acidic conditions at the site. Comparisons of the DI-WET <br /> results to background water quality and water quality objectives should be provided. Surface water <br /> quality should also be considered since storm water runoff from the site is apparently not controlled. The <br /> analysis should consider all constituents of concern and not be limited to metals. This type of analysis is <br /> necessary to determine if the waste is classified as an inert waste or a designated waste under Title 27. <br /> The report does not address whether soils underlying the drilling muds are contaminated by waste <br /> constituents. This information is needed to evaluate waste management options for the site. <br /> The report does provide a brief comparison of total metal concentrations in waste samples to published <br /> values for soils in California. This comparison, however, does not reveal whether the soluble waste <br /> constituents pose a threat to water quality. <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />