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HomeMy WebLinkAboutMITIGATION 9/22/1986STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-- CENTRAL VALLEY REGION SAN JOAQUIN WATERSHED BRANCH OFFICE: 3614 EAST ASHLAN AVENUE FRESNO. CALIFORNIA 93726 ~, PHONE: {209) 445-5116 Mr. Chuck Jimerson KERN COUN¥'F f.i~A~'~H DE?T. C & D Truck Wash 3775 Pierce Road ' Bakersfield, CA 93308 ~i ",~ C & D TRUCK WASH PONDS, BAKERSFIELD, KERN COUNTY We understand that you plan on eliminating the discharge to the disposal ponds at your facility by connecting to the City sewer system. Past sludge samples collected from the disposal ponds show high concentrations of a few base/neutral extractable organic compounds (see enclosure). We will therefore require that soil samples from beneath the disposal ponds be collected once the ponds are no longer in use. The purpose of the soil samples is to determine how far downward the above-mentioned compounds have migrated. If there has not been significant downward migration, we will proceed with the rescission of Waste Discharge Requirements, Order No. 67-154. If there has been significant downward migration, further investigation will be required. The study, to determine if there is any downward migration of base/neutral extractable organic compounds, should include the use of accepted Quality Assurance/Quality Control procedures, sampling procedures, and methods of analyses. The analyses run should include analyses for purgeable aromatics (EPA Method 8020) and base/neutral extractable organics (EPA Method 8270). A plan for conducting the proposed study should be submitted to this office for review prior to implementation. The proposed plan should contain a time schedule for conducting the work and submitting the results. The plan and the study must be prepared under the direction of a California registered civil engineer, engineering geologist, or geologist. Should you have any questions regarding this matter, please contact Russell .l,.s of this office at (209) 445-5500. F. SCOTT NEVINS Senior Engineer RWW: hmm Enclosure cc: Department of Health Services, Sanitary Engineering Branch, Fresno Kern County Health Department, Bakersfield CALIFORNIA REGIONAL WATER QUALITY CONTROL BOA~RD eCENTRAL VALLEY REGION 3614 E. Ashlan SAN JOAQUIN WATERSHED BRANCH Telephone: (209) 445-5116 Fresno, CA 93726-6905 State Lease Line: 421-5116 TO: File . FROM: Mike Mazaheri DATE: 13 May 1986 SIGNATURE: \~\~-~- ~ . SUBJECT: Holden Truck Plaza/Truckwash disposal ponds On 22 April 1986 I collected duplicate sludge samples from the ponds (north & south) in truckwash facility. Samples were collected near the point of outfall of wastewater to the ponds and were collected about 1100. The samples were kept in the ice box and were taken to the Twinning laboratory about 1430 i~ the same day. Samples from the both ponds were sent to be analyzed for nutral/base, acid, and pesticides (EPA methods 8270, and 8080), the sample from the south pond was also to be analysed for h~lognated volatile organics (.EPA method 8010)? A sample from the north pond was previously analyzed for the same constituents. CHEMISTS a ENGINEERS 140~ Grenlle ~1 W. Goshen Vlsalla. CA g32T7 ~) 651-21~ ~1 Office PI~ DrYs. Suite 310 Bakersfield. CA g~ (~5) 3~.5216 Please Address All ~all to P.O. Box 1472, Fresno, California 93716 ~ 8~ ~986 ~O~ : CaZ~Eo~n~ ~eg~on~ ~e~ QuaZ~y Con~oZ ~o~ Cen~a~ V~ey ~eg~on 36Z4 ~ A~Z~n Avenue ~e~no C~ ~3726 ~a~Ze: 2 ~ece~ve~: 4-22-86 ~o~ ~e Mr. Mike Mazaheri: Enclosed are the analysis results from the sludge samples you submitted. They include base-neutral/acid compounds, organochlorine pesticides (and PCBs) and volatile halogenated compounds. The test results are being submitted with the invoice to follow, pending completion of contract. The sample extracts had to be diluted to keep substances dissolved in the extracting solvents. Therefore detection limits are greater for EPA Methods 8270 and 8080 then usual for solid samples. The sample also would not release the volatile compounds found in EPA Method 8010 under the conditions found in EPA Method 5020. This also leads to higher detection limits, as~evident in the results. If you have any questions regarding the analysis or results, please call. THE TWINING LABORATORIES, INC. aohn Br±carello Chemistr7 Division JB:lt 2c:herewith ENGINEERING AND ANALYTICAL SERVICES FOR CONSTRUCTION. 'I~-STING. CONTROL. A~D RESEARCH Soil Foundation and Geological lnv=sdgations. Con.vtruction Materi~b Inspection ~nd T,~ting. Ch~'m~cai ~nd PhyxicaJ Anaiy~es of Concrete, SIe~L Ai]oy~ SoiL~. Plant Trout. Fert~Rzer%, Fc~cl~, Water~ Min~. ln.~cticides. Food product~. Alc~holic Bevernge~ Ga.~s. Pa~t~. Petroleum Products, Crop Damage inv~liga~ion. E.xpert Witness Coon Teztimony. As · mutual protCCUon to client, the public a~d ours~lve~ nj] ~ports a~c submitted ~s thc confidential property of client, s, and authorization for publicatio~ of Name : California Regional Water Ouality Control Board Date Received: 4/22/86 from MAke Location : Holden Truck Date Analyzed: 4/28/86 Analyat : J. Bricarello Sample 1:North Pond Exam. No. : Sample 2:South Pond Invoice No. Page : 1 Method 8270 - Base/Neutral Compound Sample i Sample 2 ug/g ug/g ug/g acenaphthene ND 8.8 2.0 benzidine ND ND 2.0 1,2,4-trichlorobenzene ND ND 2.0 hexachlorobenzene ND ND 2.0 hexachloroethane ND ND 4.0 b£a(2-chloroethyl)ether ND ND 2.0 -2-chloronaphthalene ND ND 2.0 1,2-dichlorobenzene ND ND 2.0 1,3-dichlorobenzene -- ND 'ND 2.0 1,4-dichloroben=ene ND ND 2.0 3,3'-dichlorobenzidine ND ND 2.0 2,4-dinitrotoluene ND ND 2.0 2,G-dinitrotoluene ND ND 2.0 1,2-diphenylhydrazine(azobenzene) ND ND 4.0 _.~/d~thene 2.8 6.5 2.0 4-chloropheny phenyl ether ND ND 2.0 4-bromophenyl phenyl ether ND ND 2.0 b~a(2-chloroiaopropyl) ether ND ND 2.0 bia(2-chloroethoxy) methane ND ND 2.0 hexachlorobutadiene ND ND 4.0 hexachlorocyclopentadiene ND ND 4.0 isophorone ND ND 2.0 _ naphthalene 4.5 37 2.0 nitrobenzene ND ND 2.0 N-nitroaodimethylamine ND ND 2.0 N-nitrosodiphenylamine ND ND 2.0 N-nitrosodi-n-propylamine ND ND 4.0 bis (2-ethylhex~? Phtha!ate .................. 52 ____4_Z .... 2.0 ben=yl butyl phthalate ND 14 2.0 dt-n-butyl phthtalate 5.0 5.0 2.0 di-n-octyl ~h__thel~t_e ................ ND 8,3_ 2.0 diethyl phthalate ND ND 2.0 dimethyl phthalate ND ND 2.0 Fresno Moclesto Stockton Visalia Date Received: 4/22/86 {rom Mike Mazaheri Location : Holden Truck Plaza Date Analyzed: 4/28/86 Analyat : J. Bricarello Sample 1:North Pond Exam. No. : Sample 2:.South Pond Invoice No. : Page : 2 Method 8270 - Ba~e/Neutral (continued) Compound Sample I Sample 2 MDL ug/g ug/g ug/g benzo(a)anthracene ND 11 2.0 benzo (a) pyrene ND ND 2.0 benzo(b)£1uoranthene ND ND 2.0 benzo(k)~luoranthene ND ND 2.0 ._g~y~p~ ............. ND 16 2.0 acenaphthylene .......................... ~'D .... ND 2.0 anthracene .~.. ND 6.8 2.0 benzo(ghi)perylene ND ND 2.0 ___,f.,L~or_.ene ..... 3.8 _ 21' 2.0 phenanthrene 28 78 2.0 dibenzo(a,h)enthracene ND ND 2.0 indo(1,2,3-cd)pyrene ND ND 2.0 ND 24 2.0 ug/g = microgram per gram MDL: Method Detection Limit ND: Not Detected above MDL Fresno Modesto Stockton Vls:,lia Name = Cali£ornia Regional Water Oualit¥ Control Board Date Received: 4/22/86 £rom Mike Mazaheri Location = Holden Truck Plaza Analyat = J. Bricarello Sample l:North Pond Exam. No. : Sample 2:South Pond Invoice No. : Page : 3 Nethod - 8270 Acid Extractable Compound Sample I Sample 2 MDL ug%g ug/g ug]g 2,4,6-trichlorophenol ND ND 1.0 4-chloro-S-methylphenol ND ND 1.0 2-chlorophenol ND ND 1.0 2,4-dichlorophenol ND ND 1.0 2,4-dimethylphenol ND ND 1.0 2-nitrophenol ND ND 1.0 4-nitrophenol ND ND 1.0 2,4-dinitrophenol ND ND 1.0 2-methyl-A,6-dinitrophenol ND ND 1.0 pentechlorophenol ND ND 1.0 phenol ND ND 1.0 J ug/g = microgram per gram MDL: Method Detection Limit ND: Not Detected above MDL Fresno Modesto Stockton Visalia PURGEABLE VOLATILE ORGANICS Name : Cali£ornia Regional Water Ouality Control Board Date Received: 4/22/86 ~rom Mike Location : Holden Truck Plaza Date Analyzed: 4/24/86 Analyat : J. Bricarello Sample l:South Pond Exam. No. : Invoice No. Page : 4 PURGEABLE HALOCARBON$ EPA Method 8010 COMPOUND Sample i MDL ug/g ug/g Chloromethane ND 0.5 Chloroethane ND 0.1 Bromomethane ND 0.5 Vinyl Chloride ND 0.05 Dichlorodi£1uoromethane ND 0.5 Methylene Chloride ND 0.5 Trichloro£1uoromethane ND 0.05 1,1-Dichloroethene ND 0.05 1,1-Dichloroethane ND 0.05 1,2-Dichloroethene ND 0.05 Chlo~o£orm 0.7 0.05 1,2-Dichloroethane ND 0.05 1,1,1-Trichloroethane ND 0.05 Carbon Tetrachloride ND 0.05 Bromodichloromethane ND 0.05 1,2-Dichloropropane ND 0.05 1,3-DichloroDroDene ND 0.05 Trichloroethylene ND 0.05 1,1,2-Trichloroethane ND 0.05 Chlorodtbr.o~omethane ND 0.05 2-Chloroethyl Vinyl Ether ND 0.1 Bromo£orm' ND 0.5 1,1,2,2-Tetr=chloroethane ND 0.1 Tetrachloroethylene ND 0.1 Chlorobenzene ND 0.1 1,3-Dichlorobenzene ND 0.1 1,2-Dichlorobenzene ND 0.1 1,4-Dichlorobenzene ND 0.1 ug/g = microgram per gram MDL: Method Detection Limit ND: None Detected above MDL Fresno Moclesto Stockton Visalia Name : Cali£ornia Reqional Water Quality Control Board Date Received: 4/22/86 £rom Mike Mazaheri Location : Holden Truck Date Analyzed: 4/28-5/6/86 Analyst : N. Norby Sample 1:North Pond Exam. No. : Sample 2:South Pond Invoice No. : Page : ORGANOCHLORINE PESTICIDES EPA Method 8080 COMPOUND Sample 1 Sample 2 MDL ug/g ug/g ug/g Aldrin ND ND 1.0 BH¢ ND ND 1.0 gamma BHC (Lindane) ND ND 1.0 Chlordane ND ND DDD ND ND 1.0 DDE ND ND o,p-DDT ND ND 1.0 p,p-DDT ND ND 1.0 Dieldrin ND ND 1.0 Endrin ND ND 1.0 Endrin aldehyde ND ND 1.0 Endoaul£an I ND ND 1.0 Endoaul£an II ND ND 1.0 Endoaul£an Sul£ate ND ND 1.0 Heptachlor ND ND 1.0 Heptachlor Epoxide ND ND 1.0 Toxaphene ND ND 1.0 PCB ND ND 1.0 ug/g = microgram per gram MDL: Method Detection Limit ND: None Detected above MDL Fresno Modesto Stockton Visalia - '_ E E OCI ITE .... /'. ',~'-:~ t/'.' ~ .. ~.;:~..~ ..~, ..~ C~li~ornia R~onal ~at~r qualit7 Control Board C~ntral Vallo7 3614 Ea~ A~hlan Avenue ~" Fresno, CA 93726 ATTN: Dle , ... ..... : : ~- .... .:-. RE: Gent lemen: At%ached are copies of the chemical analysis of %he wa%er samples procurred from %we %es% holes completed a~ the C & D Truck Wash "s~ps" located on %he Jim's Pipe & Supply facility, on Dece~er 21, 1989. 'The samples were procurred as described in our Dece~er 13, 1989 correspondence %o Mr. Chuck Ji~erson, as copied %o your office. As can be seen from %he at%ached, %he laboratory results were "none detected". We believe %ha% %he analysis of %he water samples, and analysis of the pre~ous soil samples, indicates %ha% %he site ready for physical closure as all results have been ~'none detected". Please review these resul~ and advise as to %he procedures required for physical closure of Your earliest review is appreciated. Respect fully ~E. ~23270 lr S~PSLTR.ChD ilLC ON & · _4'-,"-,©( lATE'--- CIVIL ENGINEERING SURVEYING~ ~~' October 11, 1989 " California Regional Water Quality Control Board Central Valley Region 3614 East Ashlan Avenue Fresno, CA 93726 ATTN: DaLe~s sary C "'& D Truck Wash RE: _~, Gent lemen: In April of 1988 this office transmitted a copy of the C & D Truck Wash report to your office. In August of 1989 your Board sent an evaluation of our report to Mr. Chuck Jimmerson. In that evaluation your Board stated "Soils sample test results in this case are of limited value in determining whether there is a potential for ground water pollution. Subsequently, this office and your office have corresponded regarding the "evaluation" and our "previously approved work plan". We have stated that the property owner, who is not C & D Truck Wash, nor Chuck Jimmerson, is desirous of selling the property and is awaiting clearance from your Board to close the sump s. We have sent your office a copy of our evaluation of your Board's actions in early September 1989, subsequent to our meeting in Sacramento with State Senator Don Rogers, and State Assemblyman Trice Harvey. We have attached a copy of that evaluation again for your use. The following conclusions are presented below for your immediate review and comments: 1. We have completed all work as required by the RWQCB, see September 22, 1986 correspondence. 2. The RWQCB has not stated that we have/have not complied with their requirements as stated in their September 22, 1986 correspondence. 3. The RWQCB have failed to demonstrate that there has been "significant downward migration" that would require "further investigation" as referenced in their September 22, 1986 correspondence. 4. The RWQCB is requiring additional work far beyond the requirements of their September 22, 1986 correspondence. 1701 WI=:~TVVINO OlqlV~ · SUITE 103 · I~AKEEF:ISI~I::LO. (~A ~-"A01 California Regional Water Quality Control Board October 11, 1989 Page Two of Two We have also telephoned your office three or four times since early September to ask questions about your evaluation and time schedules. Gentlemen, due to the lack of progress on this project, we are requesting, for our client, a meeting with you in your office at your earliest convenience. If satisfactory resolution of the project is not reached at that meeting'we will be requesting a meeting with the Executive Director. We are awaiting your response, which we believe will be immediat- ely forthcoming. ~Res~c~ul ly Submitted, ~J~hn R. Wilson, R.C.E. #23270 ~eg; Expires 12-31-89 lr Enclosure cc: Mr. Chuck Jimmerson Mr. James Boylan Mr. Don Rogers California State Senator Mr. Trice Harvey California State Assentblyman Department of Health Services, Sanitary Engineering Branch Kern County Health Department, Ms. D. Washington llLE ON & AE SOClATE'- CIVIL ENGINEERING SURVEYING September 1, 1989 Mr. Chuck Jimerson c/o C&D Truck Wash 3775 Pierce Road Bakersfield, CA 93308 Dear Mr. Jimerson, ~PUrsuant~ to~:7-~r'' meeting with- ~Mr. Don Rogers~',.~' California State Senator, and Mr. Trice Harvey, California Assen%blyman, we have prepared the following information to document the current status of the C&D Truck Wash project. This letter was the means by which the Regional Water Quality Control Board (RWQCB) would also review the status of C&D Truck Wash, as further described in their correspondence dated August 8, 1989, which was addressed to you.at the ablove address. HISTORICAL · Although my records may not be complete, 'the following is a factual representation of documents I have in my possession. May 13, 1986 "Memorandu3n" to file from Mike Mazaheri, RWQCB, regarding sludge samples collected near the point of outfall of wastewater to tHe ponds. Samples were analyzed according to EPA Methods 8270 and 8080. Results indicated that minor amounts (less than ?8 ppm) of fourteen compounds were detected. September 22, 1986 Correspondence to Mr. Chuck Jimerson from F. Scott Mevins requirinq; a. soil samples from beneath the disposal pond be collected. b. analyses run should include analyses for purgeable arom- atics (EPA Method 8020) and base/neutral extractable organics (EPA Method 8270). c. a plan for conducting the proposed study should be submitted to this office for review prior to implemen- tation. The letter also stated "The purpose of the soil samples is to determine how far downward the above mentioned compounds have migrated. If there has not been signifi- cant downward migration, we will proceed with the reces- sion of Waste Discharge Requirements, Orner No. 67-154. If there has been significant downward migration, further investigation will be required". -i- Chuck Jimerson C&D Truck Wash Page 2 July 23, 1987 Correspondence from John R. Wilson to RWQCB. attention Russell Walls. Preliminary proposal for investigation of the soil beneath the holding ponds for the truck wash. August 18, 1987 Correspondence from RWQCB James B. Wolfson to Mr. Chuck Jimerson regarding comments on the "work plan". Oct ober. _7., 1987 CorresPondence from John R. Wilson to RWQCB regard'lng the "revised" proposal, stating that the truck wash has been connected to the City of Bakersfield sewer, and the soil in the bottom of the facility is dry enough to procure samples. April 13, 1988 Correspondence from RWQCB, Russell W. Walls to Mr. Chuck Jimerson, regarding "Report of Recent Inspection". The letter stated "...we understand an assessment of pond soils is currently being conducted to determine if the soils pose a threat to water quality". April 14, 1988 Report to RWQCB from John R. Wilson. The report was a summary of the assessment of the site soils. Soils were analyzed per EPA Methods 8020 and 8270. The results indicate that no constituents were detected in any of the samples. August 8, 1989 Correspondence to Mr. Chuck Jimerson from RWQCB, Larry Beatty. Comments regarding "site assessment". Last sentence of the report stated "Soils sample test results in this case are o£ limited value in determining whether there is a potential for ground water pollution". Required Test Methods The RWQCB required the EPA Test Methods 8020 and 8270 be employed for the soil =amples as further described in our assess- ment . The RWQCB, in the August 8, 1989, correspondence is now requiring that a water sample be procured for analysis by EPA Test Method 610. Conclusions 1. We have completed all work as required by the RWQCB, see September 22, 1986, correspondence. 2. The RWQCB has not stated that we have/have not complied with their requirements as stated in their September 22, 1986, correspondence. Chuck Jimerson C&D Truck Wash Page 3 3. The RWQCB have failed to demons%rate that there has been "significant downward migration" that would require "further investigation", as referenced in their September 22, 1986, correspondence. 4. The RWQCB is requiring additional work far beyond the requirements of their September 22, 1986 correspondenc, e. In general, we have completed all work as required by the RWQCB and we have demonstrated that contamination does not exist in the soil as determined by their required methodology ..... We will await further review of our assessment in light of %he above information. Respectfully Submitted, " J~bhn R. Wilson, R.C:E. #23270 keg. Expires 12/31/89 STATE OF CcALI FORN IA , EJIAN, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL ;,P~L2~ ~ CENTRAL VALLEY REGION ~ !~ C [~ 0 ¥ I~ SAN JOAOUIN WATERSHED BRANCH OFFICE: 36. EAST ^SHLAN AVENUE F*UG 0 9 1989 FRESNO. CALIFORNIA 93726 PHONE: (209l 445-5116 Envimnrnental Health Div. Kern County Health Oe~ 8 August 1989 Mr. Chuck Jimerson C & D Truckwash 3775 Pierce Road Bakersfield, CA 93308 SITE ASSESSMENT, C & D TRUCKWASH Enclosed for your information is a memo concerning our review of a site assessment report for the subject facility. The memo indicates that detection limits for soil samples collected and tested in accordance with EPA Methods 8020 and 8270 are higher than applicable water quality goals, by several orders of magnitude. Soil sample test results are therefore of little or no value in determining whether there is a potential for ground water pollution. You must collect ground water samples for testing in accordance with EPA 610, to determine whether ground water pollution has occurred beneath the site as a result of past on-site waste disposal practices. Prior to 25 August 1989, please submit a work plan and time schedule for ground water sampling and testing for PAH's. The work plan and time schedule must be prepared, under the direction of a California registered civil engineer, engineering geologist, or geologist. Should you have any questions concerning this matter, please contact Dale Essary at (209) 445-5145. LARRY W. BEATTY Senior Engineer Enclosure DEE:cJs cc: Department of Health Services, Sanitary Engineering Branch, Fresno Kern County Health Department, Bakersfield Memorandum CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD*CENTRAL VALLEY REGION 3614 E. Ashlan SAN JOAQUIN WATERSHED BRANCH Telephone: (209) 445-5116 Fresno. CA 93726-6905 State Lease Line: 421-5116 TO: Larry W. Beatty FROM: Dale E. Essary Senior Engineer Staff Engineer DATE: 8 August 1989 SIGNATURE: SUBJECT: C & D TRUCKWASH SITE ASSESSMENT BACKGROUND The subject facility consists of a truck repair shop and a truckwash. The truckwashing operation is limited to trucks which are not associated with hauling of chemical products. Wash water from the truckwash was discharged into two unlined ponds from 1964 (approximately) until September 1987, at which time the truckwash was connected to the City of Bakersfield sewer system. The Regional'Board adopted Waste Discharge Requirements (WDR) in June 1967 (Resolution No. 67-154) for regulation of the on-site waste discharge. On 22 April 1986, a staff member collected sludge samples from the C & D Truckwash ponds. Samples were analyzed for base-neutral/acid extractable compounds (EPA Method 8270), organochlorine pesticides and PCB's (EPA 8080), and volatile halogenated compounds (EPA 8010). The following constituents, all polynuclear aromatic hydrocarbons (PAH's), were detected at concentrations which exceed water quality goals: Minimum Water Detection Quality Concentration Limit Goal Constituent (uq/q) (uq/q) (uq/ll A~enaphthylene 8.8 2.0 .0028 * Anthracene 6.8 2.0 " Benzo(a)anthracene 11.0 2.0 " Chrysene 16.0 2.0 " Fluorene 21.0 2.0 Pyrene 24.0 2.0 " · EPA 1-in-a-Million Incremental Cancer Risk Estimate, for sum of Polynuclear Aromatic Hydrocarbons. Our letter of 22 September 1986 asked C & D Truckwash to submit a work plan for conducting a study to determine the extent of soil degradation by base-neutral/acid extractable organic compounds (EPA Method 8270) and purgeable aromatic compounds (EPA 8020) beneath the disposal ponds. C & D TRUCKWASH SITE ASSESSMENT -2- A work plan dated 9 July 1987 was submitted by John R. Wilson, Registered Civil Engineer, and reviewed by staff. Staff comments on the work plan were provided to the discharger with our letter of 18 August 1987. A revised work plan dated 7 October 1987 was submitted by John R. Wilson, and that plan was implemented. A report of findings of the study entitled Assessment of On-Site Disposal Ponds, C & D Truck Wash, Bakersfield, California (Assessment Report), was submitted by John R. Wilson in May 1988. The comments below pertain to my review of the May 1988 Site Assessment Report. PROVIDED INFORMATION The disposal site consists of an unlined excavation 150 feet by 220 feet in area, used for percolating and evaporating washwater from the truckwash. The excavation is three to eight feet below natural grade. In late 1987, after the truckwash facility was connected to the City of Bakersfield sewer system, the excavation was allowed to dry. Three test holes were drilled using continuous flight hollow stem auger equipment. Samples were collected with a split-spoon sampler at ground surface, and at five-foot intervals until ground water was encountered. The surface soil samples and the samples collected at five-foot depths were tested for purgeable organics (EPA 8020) and base-neutral/acid extractable organics (EPA 8270). Water was encountered at a depth of 18 feet below natural ground surface. The soils between ground surface and the saturated zone consist of slightly silty to clean, medium fine to coarse sands. Water samples were not collected. Test results indicate that no constituents were detected in any of the samples. The cwner'wishes te close the excavation by grading the excavation to surface elevation. COMMENTS Soil samples were tested by BC Laboratories, Inc., Bakersfield, in accordance with EPA Method 8020. Soil tests were also conducted using EPA Method 8270 by FGL Environmental, Analytical Chemists, Santa Paula, and by Analytical Technologies, Inc., San Diego. These labs are State certified labs for the test methods indicated. Appropriate holding times were observed in all cases. Laboratory results submitted in the Assessment Report indicate that most of the detection limits for constituents tested using EPA Methods 8020 and 8270 are higher than applicable water quality goals, by C & D TRUCKWASH SITE ASSESSMENT -3- several orders of magnitude. Detection limits ranging from 0.013 to 2.3 parts per billion are achievable for PAH's by using EPA Method 610/8310, according to EPA Handbook SW 846, 3rd Edition. Laboratory results of EPA Method 8270 represent total concentrations of semi-volatile organic constituents present in the soil samples, expressed in units of milligram of constituent per kilogram of solid waste (mg/kg). Water quality goals represent soluble concentration limits of each constituent in units of milligram constituent per liter water (mg/1), and are not directly comparable, to total soil concentrations. Therefore, I used the Designated Level Methodology to determine the Total Designated Level for constituents of a solid waste, as calculated by the following formula: Total Water Environmental Leachability Designated = Quality X Attenuation X Factor Level (mg/kg) Goal (mg/1) Factor Determination of the Environmental Attenuation Factor (EAF) and Leachability Factor (LF) is dependent on site-specific conditions. Boring logs provided in the report suggest that the site consists of moderately to highly permeable surface and subsurface soils. Considering this and the relatively shallow depth (18 feet) to ground water encountered during sampling, I used an EAF of 10. The LF is equal to the reciprocal of the fraction of the constituent concentration that is leachable, which is a function of the biochemical activity of the site soils. The Designated Level Methodology suggests using a LF of 10 for toxic organic constituents when information on the leachable fraction of solid waste constituents is unavailable. Total Designated Levels for EPA Method 8270 constituents were developed using these factor values, and using the most restrictive water quality goals available for the' protection of ground water for domestic use. The Total Designated Levels that were determined to be lower than the applicable detection limits are listed in the table below. Detection limits from laboratory results submitted in the report are also listed for comparison. C & D TRUCKWASH SITE ASSESSMENT -4- Water Total Detection Quality Designated COnstituent Limit (m~/ka) Goal (mq/1) Level(m~/ka) Polynuclear Aromatic Hydrocarbons (PAH's): .0000028 (sum) .00028 (sum) * Acenaphthylene 1.0 * Anthracene 0.17 -~.* Benzo(a)anthracene 1.0 Benzo(a)pyrene 1.0 Benzo(b)fluoranthene 1.0 Benzo(k)fluoranthene 1.0 Benzo(g,h,i)perylene 1.0 * Chrysene 1.0 Dibenzo(a,h)anthracene 1.0 * Fluorene 0.17 Indeno(1,2,3-c,d)pyrene 1.0 Phenanthrene 0.17 * Pyrene 1.0 Benzidine 1.7 .0000003 .00003 Bis(2-chloroethyl)ether 0.17 .00003 .003 2-Chlorophenol 0.17 .0001 .01 1,4-Dichlorobenzene 0.17 .0003 .03 3,3'-Dichlorobenzidine 0.34 .00001 .001 2,4-Dichlorophenol 0.17 .0003 .03 4,6-Dinitro-o-cresol 5.0 .013 1.34 2,4-Dinitrotoluene 0.17 .00011 .011 1,2-Diphenylhydrazine 1.0 .000042 .0042 Hexachlorobenzene 0.17 .00000072 .000072 Hexachlorobutadiene 0.17 .00045 .045 Hexachlorocyclopentadiene 0.17 .001 .1 Nitrobenzene 1.0 .0005 .05 N-nitrosodimethylamine 0.17 .000003 .0003 N-nitrosodiphenylamine 1.0 .0049 .49 2,4,6-Trichlorophenol 0.17 .0012 .12 * Detected in April 1986 Regional Board sludge samples As indicated, the detection limits from laboratory results greatly exceed the Total Designated Levels in most cases. However, the Designated Level Methodology indicates that if a calculated Designated Level falls below the detectable concentration using currently available analytical methods, Designated Levels should be set at the lowest acceptable method detection limit achievable. C & D TRUCKWASH SITE ASSESSMENT -5- FINDINGS AND CONCLUSIONS 1. The Assessment Report indicates that no constituents were detected using EPA Methods 8020 and 8270. However, detection limits are higher than applicable water quality goals for most constituents tested by EPA 8020 and 8270, by several orders of magnitude. 2. Detection limits of EPA Method 8270 test results are higher than Total Designated Levels calculated for the site using the Designated Level Methodology. 3. The Designated Level Methodology indicates that Designated Levels should be set at the lowest acceptable method detection limit achievable. Lower detection limits are achievable for PAH's by using EPA 610/8310. 4. A ground water sample should be collected and tested for PAH's in accordance with EPA Method 610 to determine whether ground water pollution has occurred beneath the site as a result of past waste discharge operations. Soil sample test results in this case are of limited value in determining whether there is a potential for ground water pollution. ' ~ .,. KERN COUNTY HEALTH DEPARTME Division of Environmental Health SERVICE COMPLAINTFORM~% (-'~/,~ Date.__J..__._..~__.~.~.~ Time: Service Request [] Complaint CT No. Assigned to:..~_~ atlon ' City ...... Directions Reporting Person Address Phone Address Phone RESULTS OF - ' '  KCHO 580 2760 372-EH (R.11-80) pue .,~ . aSeald - '~ '--~ .... '" :':. "' :~ ' '. L.~JKERN COUNTY HEALTH DEPARTME~,J / . ' : ~'~ '" :" ' ' ' ~ '~'~-'~ Division of Environmental Health ~ .~ .~ ~..--~ Re~ortlng ~rson Address Phone ~o~rty Owner ~ Address ~ ~one _ _~, z~,} . . X a.,.., ...-.~~: ,~-- ...x., ~_. RESULTS OF ' ,:.b .',.', ' .... INVESTIGATION,' ',,~' '~_ Complainant notified.. . , ~, of results :Investigated by ..... Date ......................................... · ' ':' ' : "~' KCHD 580 2760372-EH (R.11-80) C & D TRUCKWASH SITE ASSESSMENT -2- A work pla~, dated 9 July '""' - ~ .R. Wilson, RegisterS-- - '.' - . ,~ f,~- comments on the work ~ ~AJ~ - )tter of 18 August 1~ ~v._~/ ? ~fsubmitted by John R ~ findings of the st ~ & D Truck Wash, Ba) bmitted by John R. ~ tmy review .of the Ma' PROVIDED ] The dispos ~t by 220 feet in ar '~from the truckwash. 91 grade. In late 19~ __ the City of Bakersf~ .. ,~ a~lowed to dry. Three test h~=~ were drilled using continuous flight hollow stem auger equipment. Samples were collected with a split-spoon sampler at ground surface, and at five-foot intervals until ground water was encountered. The surface soil samples and the samples collected at five-foot depths were tested for purgeable organics (EPA 8020) and base-neutral/acid extractable organics (EPA 8270). Water was encountered at a depth of 18 feet below natural ground surface. The soils between ground surface and the saturated zone consist of slightly silty to clean, medium fine to coarse sands. Water samples were not collected. Test results indicate that no constituents were detected in any of the samples. The cwner'wishes te close the excavation by grading the excavation to surface elevation. COMMENTS Soil samples were tested by BC Laboratories, Inc., Bakersfield, in accordance with EPA Method 8020. Soil tests were also conducted using EPA Method 8270 by FGL Environmental, Analytical Chemists, Santa Paula, and by Analytical Technologies, Inc., San Diego. These labs are State certified labs for the test methods indicated. Appropriate holding times were observed in all cases. Laboratory results submitted in the Assessment Report indicate that most of the detection limits for constituents tested using EPA Methods 8020 and 8270 are higher than applicable water quality goals, by %I%IIL ON & _4E~E~OClATE~ r L ciViL F:NGINE~RING SUI:::IVI~ YING Septen%ber 1, 1989 Mr. Chuck Jimerson c/o C&D Truck Wash 37?5 Pierce Road Bakersfield, CA 93308 Dear Mr. Jimerson, ~' ~Pdrsuant · ~0~!'"0dr meeting with' ~ Mr. Don Rogers~','~ California ..~'. State Senator, and Mr. Trice Harvey, California Assen%blyman, we have prepared the following information to document the current status of the C&D Truck Wash project. This letter was the means by which the Regional Water Quality Control Board (RWQCB) would also review the status of C&D Truck Wash, as further described in their correspondence dated August 8, 1989, which was addressed to you.at the above address. HISTORICAL ' Although my records may not be complete, the following is a factual representation of doctunents I have in my possession. May 13, 1986 "Memorandum" to file from Mike Mazaheri, RWQCB, regarding sludge samples collected near the point of outfall of wastewater to th'e ponds. Samples were analyzed according to EPA Methods 8270 and 8080. Results indicated that minor amounts (less than 78 ppm) of fourteen compounds were detected. Septen%ber 22, 1986 Correspondence to Mr. Chuck Jimerson from F. Scott Mevins requirinq; a. soil samples from beneath the disposal pond be collected. b. analyses run should include analyses for purgeable arom- atics (EPA Method 8020) and base/neutral extractable organics (EPA Method 8270). c . a plan for conduct lng the proposed study should be submitted to this office for review prior to implemen- tation. The letter also stated "The purpose of the soil samples is to determine how far downward the above mentioned compounds have migrated. If there has not been signifi- cant downward migration, we will proCeed with the reces- sion of Waste Discharge Requirements, Orner No. 67-154. If there has been significant downward migration, further investigation will be required", -1- Chuck Jimerson C&D Truck Wash Page 2 July 23, 1987 Correspondence from John R. Wilson to RWQCB. attention Russell Walls. Preliminary proposal for'investigation of the soil beneath the holding ponds for the truck wash. August 18, 1987 Correspondence from RWQCB James B. Wolfson to Mr. Chuck Jimerson regarding comments on the "work plan". October.7., 1987 Correspondence from John R. Wilson to RWQCB rega'r~ng't-he "revised" proposal, stating that the~truck wash has been connected to the City of Bakersfield sewer, and the soil in the bottom of the facility is dry enough to procure samples. April 13, 1988 Correspondence from RWQCB, Russell W. Walls to Mr. Chuck Jimerson, regarding "Report of Recent Inspection". The letter stated "...we understand an assessment of pond soils is currently being conducted to determine if the soils pose a threat to water quality". April 14, 1988 Report to RWQCB from John R. Wilson. The report was a summary of the assessment of the site soils. Soils were analyzed per EPA Methods 8020 and 8270. The results indicate that no constituents were detected in any of the samples. August 8, 1989 Correspondence to Mr. Chuck Jimerson from RWQCB, Larry Beatty. Comments regarding "site assessment". Last sentence of the report stated "Soils sample test results in this case are of limited value in determining whether there is a potential for ground water pollution". Required Test Methods The RWQCB required the EPA Test Methods 8020 and 8270 be employed for the soil samples as further described in our assess- ment. The RWQCB, in the August 8, 1989, correspondence is now requiring that a water sample be procured for analysis by EPA Test Method 610. Conclusions 1. We have completed all work as required by the RWQCB, see September 22, 1986, correspondence. 2. The RWQCB has not stated that we have/have not complied with their requirements as stated in their September 22, 1986, correspondence. Chuck Jimerson C&D Truck Wash Page 3 3. The RWQCB have failed to demonstrate th~-t there has been "significant downward migration" that would require "further investigation", as referenced in their September 22, 1986, correspondence. 4. The RWQCB is requiring additional work far beyond the requirements of their September 22, 1986 correspondence. In general, we have completed all work as required by the RWQCB and we have demonstrated that contamination does not exist in the soil as determined by their required methodology.. .- ..... ~. We will await further review of our assessment in light of the above information. Respectfully Submitted, J~bhn R. Wilson, R.C~E. #23270 ~eg. Expires 12/31/89