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WASTE DISCHARGE REQUIREMENTS -2- JOHNS-MANVILLE MANUFACTURING, INCORPORATED JM A/C PIPE CORP. FORMOSA PLASTICS, USA SAN JOAQUIN COUNTY 5. The facility has twelve disposal areas (landfills A - K) and two surface impoundments (Settling Ponds). The disposal areas and surface impoundments occupy about 32 acres of the total site, as shown in Attachment B, which is incorporated herein and made part of this Order. 6. The disposal of asbestos waste to the landfills at this facility ceased in 1983. The disposal of other waste ceased in July 1987. The landfills are currently is undergoing closure. No part of the facility has a liner or leachate collection and recovery system (LCRS). 7. Wastes discharged to landfill K were covered with a two foot layer of native soil in 1988. The other landfills had been covered with similar layers prior to 1987. 8. Title 23, California Code of Regulations, Division 3, Chapter 15 (hereafter Chapter 15), Section 2510(g) states that, "Persons responsible for discharges at waste management units which are closed, abandoned, or inactive on the effective date of these regulations may be required to develop and implement a monitoring program in accordance with Article 5 of this subchapter." 9. The 1990 SWAT found elevated levels of chromium VI, selenium, dissolved iron, sulfate, and Total Dissolved Solids (TDS) which exceeded the established maximum contaminant levels or water quality goals for ground water. The SWAT indicates that these were found in an upgradient well. Additionally, a trace amount of toluene was detected in a downgradient well, although the measured amount was below any established numerical limits. 10. The 1990 SWAT found beneficial use impairment of surface waters at the site, with a range of asbestos levels between 7 and 66 x 106 fibers/liter (f/1). The numerical water quality objective for asbestos in sources of drinking waters is the EPA Primary MCL of 7 x 106 f/1. 11. The Discharger has proposed a three-phased approach to close the landfills and surface impoundments and to remediate the discharge of asbestos to surface waters. If the first phase is successful in getting the concentration of asbestos in surface water below the water quality objective, then no further action is proposed by the Discharger. If the water quality objective is not met, the next phase will be implemented until the threat to water quality is eliminated.