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HomeMy WebLinkAboutBUSINESS PLAN 2/27/1991 ".~""....- - ,..... ,'. . /~. \ STATE OF CALIFORNIA 27 February 1991 rf;:;-~, I! f \ \ r ,~...: ('.'-\ ;--- ; I ¡ ! .........::. \ \__ f:::::' r-:-. ,,' I ; ! ¡---:"..'_-' :;:;.1 / : ,i 17/__ " I .. " , .'--...::<:J i ¡ :: ' ,_J m, Ii ":/i ' ---<-.:..--::~_,S 1, Ii i I: í ! -'---, I / J¡¡ í " it ~!¡:! .....//9°/ N¡I \...; L -../ f/ l ; í! ----- /'1 !;f -------- ; ¡ V : I ~L::/ I CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD- CENTRAL VALLEY REGION SAN JOAQUIN WATERSHED BRANCH OFFICE: 3614 EAST ASHLAN AVENUE FRESNO, CA 93726 PHONE: (209\ 445-5116 FAX: (209) 4-&5·5910 . ' Mr. Michael Pisarcik, Environmental Control Manager Nalco Chemical Company One Nalco Center Naperville, Illinois 60563-1198 TPCA CLOSURE REPORT, NALCO CHEMICAL COMPANY, KERN COUNJY We have reviewed the subject report and have provided our comments in the enclosed memorandum~ The information indicates that the closure activities described therein have most likely resulted in the removal of contaminated soils and that soils which continue to underlie the former surface impoundment do not pose a threat to water quality. Therefore, we will initiate actions to remove this facility from the active list of facilities subject to the Toxic Pits Cleanup Act. Although contaminated soils which threatened to degrade ground water have been removed, the memorandum also indicates that 2,4,6 trichlorophenol and bis (2- ethylhexyl) phthalate may exist in the soils at concentrations in excess of the respective Proposition 65 Significant Risk Levels. The company may wish to evaluate the wisdom of leaving contaminants in the soils at concentrations in excess of the Proposition 65 Significant Risk Levels. If you have any questions regarding this matter please contact Martin Amos at (209) 488-4391. r: ~l~~~ F. SCOTT NEVINS Senior Engineer Enclosure MRA:cjs cc: Mr. James Giannopoulos, State Water Resources Control Board, Sacramento Ms. Astrid Johnson, Department of Health Services, Toxic Substance Control Division, Fresno Kern County Health Department, Bakersfield -- ·MEMORANDU. CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3614 East Ashlan Avenue Phone: (209) 445-5116 Fresno, CA 93726 ATSS Phone: 8-421-5116 TO: F. SCOTT NEVINS Senior Engineer FROM: MARTIN AMOS Staff Engineer DATE: 27 February 1991 SIGNATURE: J?j'd:; 4'~ SUBJECT: TPCA aOSURE REPORt, NALCO CHEMICAL CfXrtPANY, KERN COUNTY I have reviewed the subject report entitled "Closure Report, Evaporation Pond, Nalco Chemical Company, Bakersfield,. California. II The report was prepared by Kleinfelder, Inc. and is dated 4 January 1991. Nalco proposed to clean close the surface impoundment by removing all the affected soils containing contaminants at concentrations which could potentially impact ground water. An evaluation of the closure activities and confirmation sample results is provided below, followed by my comments. GEOLOGIC AND GROUNDWATER CONDITIONS Information collected from three onsite monitoring wells indicates that ground water occurs at a depth of approximately 150 feet and exhibits a flat gradient and variable flow direction. Geologically, the surface impoundment is underlain by alternating beds of clays/silts and sands/gravels. Based on these conditions it appears that an attenuation factor approaching 1,000 could be expected. CLOSURE WORK CONDUCTED 1. In total, approximately 680 tons of contaminated material, including contaminated soils and liner materials, was excavated from former surface impoundment and surrounding areas. These materials were transported to the GSX-Laidlaw class I landfill in Buttonwillow for disposal under hazardous waste man ifest. 2. Different areas of the surface impoundment and adjacent areas were excavated to different depths as indicated on Plates 6 and 7 (attached). Confirmation samples were collected from the locations indicated on Plates 6 and 7. The 28 samples collected from the locations shown on Plate 6 were analyzed for zinc. Similarly, the 8 samples collected from locations shown on Plate 7 were analyzed for phenolic compounds by method 8040. Analytical results for all of the zinc confirmation samples indicate that the contaminated and affected soils have been removed and the remaining soils exhibit background concentration of less than 100 ppm. Analytical results for all of the 2,4,6 trichlorophenol confirmation samples were reported as non-detectable at concentrations less than 5.0 ppm. 3. The excavation was backfilled with Cal-Mat Class 2 aggregate base and compacted to at least 90% relative compaction by wheel rolling with a skip loader. The compacted surface was also sloped to prevent storm w9ter accumulation above the former surface impoundment area. ' I n_..~ _.._.J L...I --h, I' '" A()I -..--..---... ··-~--·---------.-,_..;i...,,,¿;:-i.'"2:.;.·:;/:.::...-__ e e NAlCO CHEMICAL CO. -2- 27 February 1991 COMMENTS: 1. Copies of Hazardous Waste Transport Manifest nos. 8-8285648, 51, and 53, submitted with the report, do not include sections 18, 19, and 20 which verify that the disposal facility received the waste described. 2. As stated above, a detection limit of 5.0 ppm was reported for 2,4,6 trichlorophenol analyses conducted on confirmation samples. Throu9h previous investigation, concentrations as great as 1.0 ppm were detected in the soils at a depth of one foot below the impoundment, but were not found above the detection limit of 0.6 ppm at depths of 5, la, and 30 feet. Thus, the detection limit reported for the confirmation samples is five times greater than the greatest concentration of 2,4,6 trichlorophenol identified in soils through previous sampling. Based on the confirmation test results, the leachable concentration of 2,4,6 trichlorophenol from underlying soils may be as great as 0.5 mg/I (estimated using a leachability factor of approximately one tenth of the total concentration in soils obtained from a document entitled "The Oesignated level Methodology for Classification and Cleanup level Determination," prepared by Jon Marshack of OUr Sacramento office). This concentration is approximately 400 times the EPA National Ambient Water Quality Criteria, One-in-a-MiJlion Cancer Risk Estimate of 1.2 ppb. When compared with an expected attenuation factor of 1,000 (based on the above described geological and ground water conditions), it appears that even if concentrations of 2,4,6 trichlorophenol remain in soil at concentrations equivalent to the detection limit, they do not threaten to pollute or degrade ground water underlying them. However, a concentration equivalent to the detection limit is approximately 1,000 times the Proposition 65 Significant Risk level of 5 ppb. It may be prudent for the company to evaluate the implications of leaving soils in place which potentially contain concentrations exceeding the Proposition 65 Significant Risk leveL 3. Although confirmation soils were not tested for bis (2-ethy1hexyl) phthalate (OEHP), based on previous sampling results, it appears that its presence in soils underlYing the surface impoundment was limited to shallow depths of about one foot. Excavation of soils in the areas where OE»P was identified focused primarily on the removal of zinc to background levels, since it appears to have migrated much deeper than the organic contaminants of concern. Therefore, the removal of the zinc affected soil most likely resulted in removal of any OEHP affected soil and, along with it, any threat to water quality which it posed. However, OEHP, if present at a concentration in remaining soils equivalent to the detection Jimit reported during previous investigation, could exceed its Proposition 65 Significant Risk level of 40 ppb by 15 times. As stated above in comment no. 2, it may be prudent for the company to evaluate the implications of leaving soils in place which potentially contain concentrations exceeding the Proposition 65 Significant Risk level. 4. Polychlorinated dibenzo dioxins and furans (PCOO/PCOF) are common contaminants of industrial grade polychlorinated phenols. Therefore, where 2,4.6 trich10rophenoI is detected, PCOO/PCOF are potentially present. I , ! ~~._..- - .--....-- ,.-... . . e - HALCO CHEMICAL CO. -3- 27 February 1991 I' i I I In general, trichlorophenol tends to be more mobile in soils than PCDD/PCDF and, therefore, would be expected to be present at greater depths in soils underlying the surface impoundment than any associated PCDD/PCDF. Areas where 2,4,6 trichlorophenol was identified at detectable levels, described in comment no. 2 above, were excavated to depths of 6 and 12 feet, respectively. Therefore, it is expected that any PCDD/PCDF which might possibly have been associated with the 2,4,6 trichlorophenol were removed with the excavated so il s . CONCLUSIONS It appears that the contaminated soils have been removed and soils remalnlng beneath the former impoundment no longer pose a threat to water quality. Although the threat to water quality has been removed, it may be prudent for the company to evaluate the implications of leaving soils in place which potentially contain conncentrations of 2,4,6 trichlorophenol and DEHP in excess of the Proposition 65 Significant Risk Level. aa "U ;%) o 5 '5 ,z· "10 N 4=a> I (¡,) '"'" eM ...., o o .~ - ^ r- m, Z -n m r- o m ;::J' mZ ØJ Q!.. ';It" 8 ~ . ~,9 -(I) ~ 3 I ~ [ ~(') ::;0 3 ~, ¡-§ '< ' (') o z :!], :c ~ > :j a2 ~ ~. b!~ z ;2 (')- ~. 5' ('), » -i Õ Z C/) 0) "Ó õ :Þ -I ,.., ~~_iil__ .......a..._...... ) 13172(1 1320 13176(0) . 1.3179(0) . 1.3167(0) . 0) ~ ~ (10) t9 f2J ItIß IZJ e EXPLANATION Area excavated to 3 feet below. gunlte Area excavated 10 Ii 'e.' b.low gun". Ar.a excavat.d from J to 7 f..t b.low gunlt. Area ..avaled to a feet below gunlte Ar.a excaval.d to '0 t..t below gunlte Area .xcavated to '2 f.et below gunlte e¡ 13156(0) Sample Location and number · (Sam pl. d.pth) Approxlmat. .cal.: I" = 10' 0 5 10 I I (FEET) I I I "Ò ;D 0 c... !! IT! n - z :> \) ^ ~ I r- ,) ... m ,)' '. ':.¡ - , ;:) ;:) Z I ") ." ;) .. m r- 0 m ,;;¡O . ~ '-.' .;;.~,,:-;'~!"ryv. J::.:. ,p. '~~.'.,"" ,,".... . <'."~,;'-~.~" ::- t I, () 0 Z ~ J Z ª æ. I 8 ð ~ I I 2 I ~~ !: I ~ ~ ~~ s:: ) ~ , fl~ z . -à en G) , , 6 I '. D) ::J () '< ~ 0 z en .....¡ "U r- :Þ -i rT\ < :.fI,'" . . ','.Ø.'1t¡.... EXPLANATION ~ Ar.a .Kcava..d '0 .} ,... b.law gun It. ~ Ano .xcoyot.d 10 6 ,..I b.low 9unlt. 123 Ar.a .xcoya'.d from .} to 7 f..1 b.low Qunlt. fZ1 Ar.a .xaval.d '0 II f... b.low gunll. If! Ar.a .xcavat.d '0 10 f..t b.low lIuoll. [ZJ Ar.a .Kcayal.d '0 I 2 f ..1 b.low Qunlt. IJI58 Sampl. Locallon and numb.r . Approxlmat. Ical.: I" = 10' 0 5 10 I I (FEET) -- STA;E OF CALIFORNIA e ,~ CALIFORNIA REGIONAL WATER QUALITY CONTROL 8 CENTRAL VALLEY REGION GEORGE DEUKMEJIAN, GOlfe",'!!. SAN JOAQUIN WATERSHED BRANCH OFFICE: 3614 EAST ASHLAN AVENUE FRESNO. CALIFORNIA 93726 PHONE: /2091445-5116 9 January 1991 Mr. Michael R. Pisarcik, Environmental Control Manager NALCO Chemical Company One NALCO Center Naperville, III _ ~ J ____' TPCA INSPECTION,~LCO CHEMICAL COMPANY,~ERN COUNTY One of our staff recently inspected the surface impoundment at the Company's Bakersfield facility. Enclosed is a report on the inspection. If you have any questions regarding the inspection, please contact Martin Amos at (209) 488-4391. f F. SCOTT NEVINS . Senior Engineer Enclosure -:- MRA:mra/cjs cc: Ms. Astrid Johnson, Department of Health Services, Fresno Kern County Health Department, Bakersfield Mr. Ronnie Neves, NAlCO, Bakersfield e Memo~andurÞ 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: F. Scott Nevins Senior Engineer FROM: Martin Amos Staff Engineer DATE: 9 January 1991 SIGNATURE: 2' z.~ a~ I SUBJECT: TPCA INSPECTION, NALCO CHEMICAL CfMPANY, KERN COUNTY On 3 December 1990, I conducted a non-sampling inspection of the subject facility to determine compliance with the Toxic Pits Cleanup Act (TPCA). During the inspection, I was accompanied by Mr. Ronnie Neves, Distribution Supervisor for Nalco. Nalco distributes chemicals used in oilfield exploration/production from its facility at 4851 Stine Road in Bakersfield. Currently, chemicals are not blended or mixed at the facility. Drums of the chemical are loaded into trucks in a docking area on the north side of the warehouse. Rinseate is stored in two tanks and recycled for further use. A tank farm, situated west of the warehouse, contains the two storage tanks used for recycle. The tanks are underlain by concrete and surrounded by a berm approximately one foot tall. Any spillage which may occur from the tank area is collects in a floor drain and flows to a sump housed in a shed directly to the south. Fluids collected in the sump are pumped to the two tanks for recycle. A letter dated 1 Nóvember 1990 from the State of California, Department of Health Services classifies operations at the facility as a recycle process, so long as Nalco complies with the conditions specified therein. Nalco operated a surface impoundment (toxic pit) west of its warehouse and recently removed contaminated soi ls from beneath it. I observed the former surface impoundment and found that it has been filled to existing grade and compacted. Mr. Neves stated that the impoundment was clean closed. I observed that the former discharge pipe has been capped so discharge cannot occur. Our review of Nalco's closure plan for the surface impoundment dated 26 July 1990, states that "it appears appropriate provided that items 3 and 4 are adequate ly addressed during the closure process." Item 3 requested that analysis of DEHP be conducted as part of the confirmation sampling work, since it was identified as a contaminant of concern in previous sampling events. Item 4 requests that analysis of below-impoundment soils and impoundment liner materials for dioxins, since it could be associated with 2,4,6 trichlorophenol. Mr. Neves indicated that it rained a few days prior to the inspection. I observed some rain water ponded in the bottom of the loading dock. Mr. Neves stated that rainfall on_areas other than the loading dock and tank farm area, drain to a storm water catch basin just south of the warehouse. I DO\I;owøn hv.~1. I , J.,Ú i , I - e NALCO CHEMICAL COMPANY -2- 9 January 1991 CONCLUSIONS AND RECOMMENDATIONS: 1. Contaminated soils have been removed and the former súrface impoundment has been filled to the existing grade. 2. DHS has classified Nalco's handling of rinseate as a recycling operation when conducted in accordance with the guidelines specified in correspondence dated 1 November 1990. MRA:cjs I I I . e e TPCA COMPLIANCE INSPECTION REPORT Type of inspection: Annual inspection -X- Cease discharge ___ * If this was a cease discharge inspection, did the material being tested pass the paint filter test? Closure -X- * If this was a voluntary closure, has the facility successfully met closure? * If this was a closure inspection of a leaking surface impoundment, has the facility successfully met closure? Post-closure * If this was a post-closure inspection, is the maintenance, cover, monitoring or other post- closure care effective? Exemption renewal * If this was an exemption renewal inspection, was the Regional Board able to make all of the findings necessary for exemption renewal? Other * If the purpose of the inspection was not one of the above, briefly describe. Discharger: Nalco Chemical Company Location and county: Bakersfield, CA I Kern County contact(s): Mr. Ronnie Neves, Distribution Supervisor Inspection date: 3 December 1990 Inspected by: Martin Amos Accompanied by: Ronnie Neves yœ/rc ", yœ / (!3) yœ/rc yœ/rc yœ/ro e CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD- CENTRAL VALLEY REGION - GEORGE DEUKMEJIAN, Governor STATE OF C~lIFO;:¡'''A - - -- ~ SAN JOAQUIN WATERSHED BRANCH OFFICE: 3614 EAST ASHLAN AVENUE FRESNO, CALIFORNIA 93726 PHONE: (2091445·5116 03 November 1988 [ffi1!<eIlO\'UII[Q) NOV 041~ Mr. Karsten Odland NALCO Chemical Company One NALCO Center Naperville, Illinois 60566 EnvttanmenIaIHNhb ON. Kn CMtr H.... o.t. REPORT OF RECENT COMPLIANCE INSPECTION OF NALCOCHEMICAL COMPANY'S EVAPORATION POND, KERN COUNTY On 25 November 1988, Scott Moore of our office inspected the NALCO Chemical Facility evaporation pond to determine if section 25208.4 (a) of the Toxic pits Cleanup Act (TPCA) of 1984, and Waste Discharge Requirements, Order No. 76-251, were being complied with. Any site assessment activity was also to be identified during the inspection. A copy of the inspection memorandum is enclosed. The memorandum indicates, that the potential for NALCO Chemical to violate cease discharge regulations specified under section 25208.4 (a) of the TPCA, exists. Such a violation may have already occurred. Prior to 03 December 1988, please provide us with a technical ~eport that includes a work plan to meet cease discharge provisions, and a work plan for the proper closure of the impoundment. The report must be prepared under the direction of a California registered civil engineer or engineering geologist, and must contain a time schedule for conducting the work. F. Scott Nevins Senior Engineer VSM cc: Russel Carey, Kleinfelder And Associates, Fresno Vern Reichard, Kern County Health Department, Bakersfield Gerry White, State Department of Health Services, Fresno I I. I I · . . :.'; c ::: ~~ :. :: :: c ~ L :,.. . . CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD -CENTRAL VALLEY REGION 3614 E. Ash/an SAN JOAQUIN WATERSHED BRANCH Telephone: (209) 445-5116 Fresno. CA 93726-6905 State Lease Line: 421-5116 TO: F. SCOTT NEVINS Senior Engineer FROM: V. SCOTT MOORE Assoc. Engr. Geol. DATE: 03 November 1988 SIGNATURE: SUBJECT: REPORT OF RECENT COMPLIANCE INSPECTION OF NALCO CHEMICAL· COMPANY'S EVAPORATION POND, KERN COUNTY On 25 October 1988, I inspected the evaporation pond at the NALCO Chemical Company Facility in Bakersfield, Kern County. Russ Carey of Kleinfelder and Associates, and Clay Epperson of NALCO Chemical Company accompanied me. The purpose of the inspection was to determine if NALCO is in compliance with section 25208.4 (a) of the Toxic pits Cleanup Act (TPCA) of 1984, Waste Discharge Requirements, Order No. 76-251, and to identify any site assessment activity. SITE HISTORY The current NALCO Chemical Company Facility has been used for the blending and marketing of specialty chemicals used in oil since 1977. These chemicals consist of corrosion and scale inhibitors, and emulsion breakers. An August 1988 review of the Hydrologic Assessment Report (HAR) prepared by Kleinfelder and Associates, indicated that soils beneath the evaporation pond have been contaminated as a result of leakage, by pollutant metals arsenic, zinc, barium, chromium, lead and vanadium. Concentrations of one or more of these metals, were determined to exceed Soluable Threshold Limit Concentrations (STLC) for samples collected from borings drilled beneath the pond. Zinc concentrations exceeded Maximum Contaminant Levels (MCL) for a ground water sample collected from monitoring well MW-2, which is situated approximately 35 ft. northwest of the evaporation pond. This well intercepts the first water at approximately 135 ft. below grade. Also indicated in the HAR was that a sample of storm water runoff was collected from the evaporation pond in December of 1987. The analytical results from this sample determined concentrations of zinc to exceed STLCs which according to Section 6669, Title 22 of the California Code of Regulations, constitutes a hazardous level. All constituents from the aforementioned sampling locations are considered to be by-products of the chemicals handled at the facility. Waste discharges to the pond according to the HAR, ceased with the installation of two above-ground waste storage tanks in 1986. Liquids and sediment were also removed from the pond in 1986, and since then, theHAR indicates that the pond has received only storm e - NALCO Inspection (2) 03 November 1988 water runoff. OBSERVATIONS AND COMMENTS An inspection of ,the surface portion of theC-evaporation pond found it to be dry. Sediments were observed in the pond, but accumulations approximated only 1 inch in thickness. According to Mr. Carey, the bulk of the sediments had been removed at an earlier date in 1986. As a result of the sediment removal, the synthetic liner was torn in numerous places and a hole was punched into the south gunite wall of the pond. The hole was observed to have been repaired, but the synthetic liner is still in very poor condition. An inspection of the Leachate Collection and Removal system (LCRS) portion of the pond, revealed the presence of moist sediment and puddles at the base of the observation pipe. A hand sample of the moist sediment was collected by Mr. Epperson. The sample contained sediments which were immersed in a clear, odorless liquid. According to Mr. Epperson, the liquid was derived from yard wash that drained into the observation pipe from the asphalt-surfaced yard. He also stated, however, that he hadn't checked the LCRS for an extended period of time since no fluids were being stored in the pond. After checking around the perimeter of the evaporation pond, I noticed that water from the yard wash hose was allowed to drain via erosional notches, beneath the gunite liner and possibly into the LCRS at a location near the skimmer tank. Such drainage may also serve as an explanation as to why sediments in the LCRS are moist. If constituents exist in the LCRS at concentrations above hazardous levels, this is a violation of the cease discharge provisions of TPCA. section 25208.2 (f) of TPCA states that a "discharge" means to place, dispose of, or store liquid hazardous wastes in a surface impoundment. Therefore, any accumulation of fluids (rain water, yard runoff, etc.) in the pond including the LCRS, that results in the placement, disposal, or storage of liquid hazardous wastes, is considered to be a hazardous discharge and is in violation of section 25208.4 (a) of the TPCA. This section states that a person shall not discharge liquid hazardous wastes or hazardous wastes containing free liquids into a surface impoundment after June 30, 1988, if the surface impoundment or the land immediately beneath it contains hazardous wastes and is within 1/2 mile upgradient from a potential source of drinking water. Evidence of site assessment activity, was not present except for the capping of the two effluent pipes that previously discharged liquid wastes into the evaporation pond prior to 1986, the repair of the hole in the south gunite wall, and the removal of sediment from the pond. e e NALCO Inspection (3) 03 November 1988 INSPECTION SUMMARY The following list of items summarizes the findings of my inspection of the NALCO Chemical Company's evaporation pond. Also included in these items are comments pertaining to each finding. 1 No fluids were present in the surface portion of the evaporation pond at the time of mý inspection. The potential that NALCO Chemical Company will be in violation of regulations specified under Section 25208.4 (a) of the TPCA, however, exist if, rain water, yard runoff, etc., results in the placement, disposal; or storage of hazardous wastes in the pond. 2 - An inspection of the LCRS portion of the evaporation pond, revealed the presence of moist sediment and fluid puddling. The origin of the fluid was not determined, but is likely to be yard runoff water that has drained into the LCRS observation pipe, and/or yard runoff that has drained into the LCRS via erosional openings between the pond's gunite and clay liners. Such accumulations of yard runoff in the LCRS may have resulted in the discharge of liquid hazardous wastes. Such a discharge would be a violation of section 25208.4 (a) of TPCA. 3 - No visual evidence of site assessment was present, except for the removal of sediment from the pond floor and walls, the repair of a hole in the pond's south wall, and the capping of two effluent pipes used previously for the discharge of fluid wastes to the pond. Mr. Carey, however, stated that Kleinfelder and Associates . is currently conducting an investigation to determine the vertical and lateral extent of contamination at the site, and that work plans for site closure are dependent on the outcome of this investigation. This investigation was initiated in response to a letter from our office dated,26 August 1988. VSM STf..ìl OF C:,lIFORNIA e. - .' ~ (~. GEORGE DEUKMEJIAN, GO£' CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD- CENTRAL VALLEY REGION .. ~.~~\.;, ;'-a .: . .., . .........' SAN JOAQUIN WATERSHED BRANCH OFFICE: 3614 EAST ASHLAN AVENUE FRESNO. CALIFORNIA 93726 PHONE: (2091445·5116 26 August 1988 Mr Karsten Odland NALCO Chemical Company One NALCO Center Naperville, Illinois 60566 REVIEW OF HYDROGEOLOGIC ASSESSMENT REPORT, NALCO CHEMICAL COMPANY, BAKERSFIELD FACILITY, KERN COUNTY I I I I Enclosed for your information is a copy of the review of the Hydrogeologic Assessment Report (HAR) for the Evaporation Pond at the NALCO Chemical facility. The attached memorandum summarizes the information presented in the HAR and discusses the adequacy of the report with regard to the specific requirements of the Toxic pits Cleanup Act (TPCA). Our review of the HAR indicates that some of the information required by TPCA (Section 25208) has not been adequately addressed. Enough information has been provided , however, to determine that ground water beneath, and around the facility has been degraded as a result of improper liquid waste disposal. Prior to 15 October 1988, please provide us with a technical report that includes a work plan to determine the lateral and vertical extent of the ground water contamination that has occurred at, the site. This plan should include a time schedule for completing the work and should also include proposed work that would be sufficient to address the items in the HAR that are deficient. If you have any questions regarding this matter, please contact v. Scott Moore at (209) 445-6121. F F. Scott Nevins Senior Engineer VSM cc: Russel o. Carey, Kleinfelder And Associates, Fresno Vern Reichard, Kern County Health Department, Bakersfield Gerry White, State Department of Health Services, Fresno e- u ~ G n1 ö ~,. Ct n c~ ~ ~ rn e 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: F. SCOTT NEVINS Senior Engiqeer FROM: V. SCOTT MOORE Assoc. Engr. Geologist DATE: 26 August 1988 SIGNATURE: j/ ~~ SUBJECT: ' REVIEW OF HYDROGEOLOGIC ASSESSMENT REPORT, NALCO CHEMICAL COMPANY, BAKERSFIELD, KERN COUNTY FACILITY INFORMATION The current NALCO Chemical Company site has been blending and marketing of specialty chemicals production since 1977. These chemicals consist of scale inhibitors, and emulsion breakers. used for the used in oil corrosion and The cleanup activities at the NALCO facility are being conducted at the request of the Regional Water Quality Control Board, Central Valley Region. This memorandum deals specifically with activities associated with the Toxic Pits Cleanup Act of 1984 (TPCA) at the site. COMMENTS I have reviewed Kleinfelder's Hydrogeologic Assessment Report (HAR) that was submitted for the NALCO facility. The following discussion relates section 25208.8 of the Health And Safety Code with the contents of the HAR. Each section of the code will be quoted and followed by a discussion of the adequacy of the contents of the HAR. BAR REQUIREMENTS A. A description of the surface impoundment including its physical characteristics, its age, the presence or absence of a liner, the liner's compatibility with the hazardous wastes discharged to the impoundment, and design specifications of the impoundment. Only one surface impoundment came under discussion in Kleinfelder's HAR. This impoundment commonly is referred to as the evaporation pond and was constructed in 1977 for the collection of equipment rinse water. This impoundment failed and was repaired in 1979. Currently, a cracked area exists along the south guni te wall and may be susceptible to leakage of impoundment water. 1 ...-ø..... e- - NALCOCHEMICAL HAR 26 August 1988 The outer dimensions of the impoundment are approximately 84 ft. by 44 ft. and the depth is 6 ft. The design operating level is 5 ft. and yields an operating capacity of 80,000 gallons. The walls of the impoundment maintain a 1:1 slope. A sump is situated along the impoundments west side (see plate 4). The liner consists from bottom to top of: a 1.5 foot thick layer of compacted clay: a 4 in. thick layer of concrete gunite: and a 3/16 in. thick sealant. At present, the impoundment does maintain a Leachate Collection And Removal System to collect any fluids that may penetrate the sealant and gunite layers. This system, however, has limited capabilities for the detection of leakage from the impoundment. 'B. A description of the volume and concentration of hazardous waste constituents placed in the surface impoundment, based on a representative chemicals analysis of the specific hazardous waste type and accounting for variance in hazardous waste constituents over time. Known hazardous substances used at the NALCO facility include as follows: a) - Emulsion breakers b) - Oxygen scavengers c) - Scale inhibitors d) - Corrosion inhibitors e) - Cleaners Hazardous substances are listed in Tables 2.1 and 2.2, and in Appendix C of the HAR. Information as to the hazardous substances stored in the impoundment prior to 1985, however, does not exist according to Kleinfelder's findings. In December of 1987, a sample of storm water runoff was collected from the impoundment and tested. A review of the various types of EPA and' Standard test methods used found that most were appropriate for the detection of pollutant organics, and inorganic ion~ and metals known to be associated with hazardous substances handled at the facility. Test descriptions and methods used are listed in Appendix (B) of the HAR. There are some concerns, however, regarding certain aspects of sample analysis. For one, it was noted that the GC/FID method used for the detection of total extractable hydrocarbons (TEH) was not u~ed for the analysis of soil samples. Since TEH 2 e - NALCO CHEMICAL HAR 26 August 1988 concentrations were present in pond water and ground water samples, they may also be present in soils and other vadose 'zone lithic horizons. It was also not clear why individual compound analytical refiul ts for ethylene glycol, isobutyl alcohol, and isopropanol were reported as one concentration value under the TEH Test Description and not separately as they were in Table' 2.2. As it stands, there is no way of determining which particular contaminant is the maj or contributor to TEH concentrations presently existing in ground water beneath the subject site. Secondly, it is not clear why follow-up analyses were not conducted to determine the type and possible toxicity of the unidentified base/neutral and acid extractable organics detected in on-site ground water (see Table 7.4 of the HAR). These concerns should be addressed. .., Results of sample analysis demonstrated concentrations of inorganic (ie. zinc, lead, arsenic, barium and selenium) and organic (ie. bis-(ethylhexyl phthalate and total extractable hydrocarbons) contaminants. Subsequent samples taken from the vadose zone, and ground water directly below, and marginal to the impoundment, all demonstrated concentrations of inorganic and/or organic contaminants similar to those found in the impoundment. Some specific contaminants that commonly show up in most of the aforementioned zones include: Inorqanic Orqanic Arsenic Barium Chromium Lead Vanadium Zinc Toluene Ethyl benzene Xylene Bis(2-ethylhexyl) phthalate TEH (unidentified) Many of the organic and inorganic contaminants detected in the soil and ground water directly beneath, or marginal to the impoundment, can be considered to be by-products of the known hazardous substances kept in storage at the NALCO facility. The volume of the hazardous waste contained within the impoundment during Kleinfelder's inspection in 1987, approximated 7,000 gallons which is roughly 10% of the impoundment's operating capacity. c. A map showing the distances, within the facility, to the nearest surface water bodies and springs, and the distances, within one mile from the facility's perimeter, to the nearest surface water bodies and springs. (Section 25208.8(C» 3 - e NALCO CHEMICAL HAR 2~ August 1988 The map included in the HAR, demonstrated that the Farmers Canal is situated 1000 ft. to the east of the site, and the stine Canal 3000 ft. to the west. The nearest other bodies of surface water are the Kern River and the Buena vista Canal, situated 4 miles to the north and 3 miles to the west respectively. D. Tabular data for each surface water body and sprinq shown on the map specified in subdivision (c) which indicate its flow and a representative water analysis. The report shall include an evaluation and characterization of seasonal chanqes and, if substantive chanqes result from season to season, the tabular data shall reflect these seasonal changes. Tabular hydrology data of the Kern River was provided in the HAR, but was a copy of the 1987 Kern County Water Agency Improvement District, No. 4 investigation results. No surface water investigations were conducted by Kleinfelder even though they indicated they would in their November, 1987 HAR Work Plans Report. Since the Farmers Canal is nearest to the impoundment, all data required in (D) of the HAR should be collected and tabulated for this surface body of water. E. A map showing the location of all wells within the facility and the locations of all wells within one mile of the facility's perimeter. The report shall include, for each well, a description of the present use of the well, a representative water analysis from the well, and when possible, the water well driller's report or well log. These required maps were provided in the HAR. According to their Well Locations Map (see· Plate 11), 21· domestic and agricultural water wells were identified. Only 7 of the 21 wells, however, were analyzed due to being inoperable, abandonment, or denial of permission to access the well. Based on the oil And Gas Well Locations Map (see Plate 12), 20 oil and gas wells are situated within 'one mile of the NALCO facility. No water, oil or gas wells were situated on the subject property. Off-site water well sample data and their analytical results are provided in tabular form for the 7 wells mentioned previously. Not provided, was a description of the present use of each well. This must be provided. Also not provided, were water well logs or driller's reports. F. An analysis of the vertical and lateral extent of the perched water and water bearing strata which could be affected by leachate from the surface impoundment, and the confining beds under and adjacent to the surface 4 e e NALCO CHEMICAL HAR 26 August 1988 impoundment. This analysis shall include the following: 1. Haps showing contours of equal elevation of the water surface for perched water, unconfined water añd confined ground water required to be analyzed by this subdivision. Two copies of regional maps generated by the Kern County Water Agency were provided, and show the regional depth to ground water for an unconfined aquifer (see Plate 7), and the ground water elevations to the top of the same unconfined aquifer (see Plate 8) . Both maps show contours of equal groundwater elevations. Approximate ground water elevations for the unconfined aquifer are also provided in the site Ground Water Gradient maps (see Plates 10 and 10.1) of the HAR. 2. AD estimate of ground water flow direction of the perched water, and all water bearing strata on both the maps and the subsurface geologic cross sections. The regional ground water gradient is estimated to be to the south, but ground water gradient maps (see Plates 10 and 10.1) provided in the report indicate that it is probably locally influenced, . trending to the northwest at one time and to the northeast at another. Depending on the direction of ground water flow, the gradient ranges between .001 and .0002. Depth to ground water in the vicinity of the impoundment approximates 150 ft. The required subsurface geologic cross sections for this site, were not provided in the HAR. 3. AD estimate of the transmissivity, permeability, and storage coefficient for each perched zone of water and water - bearing strata identified on the maps specified in paragraph (1). Aquifer test results for the unconfined aquifer beneath the site demonstrated the following characteristics: a) - Flow rate ranged between .0009 and 3.65 ft/year. b) - Permeability (based on the upper 25 ft. of aquifer) ranged between 10-7 to 1000 em/sec. c) - Transmissivity is 95.6 gpd/ft. d) - Specific yield (in place of storage coeff.) is 0.1. Kleinfelder estimated I storage coefficient, unconfined aquifers. specific yield stating that instead of the requested it is appropriate for 5 e e NALCO CHEMICAL HAR 26 August 1988 4. A determination of the rate of qround water flow. This information is listed in F-3 above. 5. A determination of the water quality or each zone or the water-bearinq strata and perched water which is identified on the maps specified in paraqraph (1) and which is under, or adjacent to, the facility. This determination shall be conducted by takinq samples either from upgradient of the surface impoundment of from another location 'which has not been affected by leakage from the surface impoundment. Samples from seven off-site water wells believed to be unaffected by contamination, were collected and analyzed for quality. The possibility exists, however, that water wells CBK-11 and CBK-12 (see Plate 11) may have been contaminated due to the fact that they are downgradient of the NALCO facility. All seven wells were perforated from depths ranging between 240 ft. and 690 ft. below the ground surface and approximately 40 ft. to 105 ft. below the top of the unconfined aquifer. The results of the analysis for· the inorganics are provided in tabular form in the HAR. Zinc concentrations of 0.02 mg/l were detected in well CWS-4. Kleinfelder stated that organic consti tuents were not detected in any of the seven wells that were sampled, so results were not tabulated. All water sample, laboratory analyses documents are provided in Appendix B of the Har. G. An indication as to whether the ground, water is contiguous with regional bodies of ground water and the depth measured to the ground water, including the depth measured to perched water and water-bearing strata identified on the maps specified in paragraph (1). Ground water occurs at a depth that ranges between 135 ft. and 200 ft. in the immediate vicinity of the NALCO facility. Monitoring wells (MW-1, MW-2, and MW-3) at the site encountered ground water at a depth of 135 ft. below ground surface. Whether or not ground water below the facility is contiguous with regional ground water, was not thoroughly discussed in the HAR. Based on the provided Regional Ground Water Elevations And Depth To Ground Water maps (see Plates 7 and 8), and other information presented in the HAR, we will assume that ground water below the NALCO facility is contiguous with regional ground water. H. The following climatological information: 6 - e I· I NALCO CHEMICAL HAR 26 August 1988 1. A map showing the contours for the mean annual long -term precipitation for the surrounding region w;thin 10 miles of the surface impoundment. The required Mean Annual Precipitation Contour Map is included in the HAR (see Plate 14). The maximum 24 hour precipitation event is 2.06 in. (1941). The minimum and maximum annual precipitation are 1.87 in. (1959) and 10.96 in. (1941) respectively. The above data was calculated and provided by the Meadows Field Airport and Weather station located approximately 7 miles north of the facility. According to USGS maps (1981), the NALCO facility is far removed from the anticipated boundaries for the 100 year flood event for the Kern River. Local flooding is controlled through the use of the recharge/storm runoff basins, and the pumping of runoff into the stine and Farmers. canals. 2. Calculations estimating the maximum 24-hour precipitation and maximum and minimum annual· precipitation at the facility based upon direct measurement at the facility or upon measured values of precipitation from a nearby climatologically similar station. Information pertaining to this subsection is discussed in subsection H-1 above. 3. The projected volume and pattern of runoff for any streams which, in a 100-year interval, could effect the facility, including peak stream discharges associated with storm conditions. Information pertaining to this subsection is discussed in subsection H-l above. I. A description of the composition of the vadose zone beneath the surface impoundment. This description shall include a chemical and hydrogeological characterization of both the consolidated and unconsolidated rock material underlying the surface impoundment. This description shall also include soil moisture readings from a representative number of points around the surface impoundment's perimeter and at the maximum depth of the surface impoundment. The report shall arrange all monitoring data in a tabular form so that the data, the constituents, and the concentrations a~e readily discernable. The upper 30 ft. of the vadose zone typically consist of light brown, moist, silty sand to 10 feet, and grades to a coarser, 7 - e NALCO CHEMICAL lIAR 26 August 1988 well graded, silty sand down to 30 feet. Logs of the soils and the sediments comprised within this 30 foot section, are provided for Bore Hole No. 3 (see Plates 18.12 through 18.14». The moisture content of the 'soils ranged between 2.9% and 1.7 %, and is based on samples collected from four separate borings situated at different locations at the facility. The average moisture content is 9. 6 % . No discussion was made with regards to the chemical and hydrogeological characteristics of the consolidated and unconsolidated lithic material comprised within the vadose zone from 30 ft. to the water table. soil samples were collected at select intervals from 3 borings beneath the impoundment (see L-1, L-2, and L-3 on Plate 10.1). These sample intervals ranged between 5 ft. and 35 ft. below the ground surface. Four samples from these borings were analyzed for inorganic and organic contaminants, and the resul ts were tabulated in the lIAR. The inorganic analytical results revealed concentrations of the pollutant metals arsenic, barium, chromium, lead, and vanadium to be above STLCs. Zinc concentrations exceeded STLCs in Boring Hole L-3. Organic analytical results revealed concentrations of toluene, ethyl benzene, base/neutral and acids, and xylene in the soil beneath the impoundment, but were below STLCs. Also detected in samples collected from borings L-1, L-2, and L-3, were unidentified peaks for base/neutral and acid extractable organics. Due to the fact that sampling was limited to a depth of 35 ft., the maximum vertical extent ,of contamination still remains undefined. I Lysimeter sampling was conducted and sample analysis was based on 6 samples taken from soils in borings L-2 and L-3. The inorganic analytical results detected concentrations of the pollutant metals barium and zinc. These concentrations were below STLCs. The organic analytical results detected concentrations of bis- (2-ethylhexal) phthalate. No purgeable organics were detected. This, however, may be due to the low quantity of liquids collected by the lysimeters. These analytical results are tabulated and provided in the HAR. The analytical results for both the soil and lysimeter samples indicate that contamination of the vadose zone soil below, and in the immediate vicinity of the impoundment has ocurred. The aforementioned contaminants found in the vadose zone, are by- products or components of chemicals used and stored at the NALCO facility. J. A measurement of the chemical characteristics of the soil made by collecting a soil sample upgradient from the impoundment or from an area which has not been affected by seepage from the surface impoundment and uhich is in a 8 e e NALCO CHEMICAL HAR 26 August 1988 hydrogeologic environment similar to the surface impoundment. The measurement shall be analyzed for the same pollutants analyzed pursuant to subdivision (i). . The background boring (L-4) was completed immediately north of the office parking area (see Plate 2). The boring was completed to a depth of 12.5 ft. and was sampled at 6 and 11 ft. The analytical results of these samples detected the inorganic pollutant metals barium, vanadium, lead, arsenic, and chromium, all of which exceeded STLCs. Concentrations of zinc were also present. Background samples were not analyzed for purgeable organics or base/neutrals and acids. Since the inorganic contaminant concentrations are comparable to those detected in soil samples taken beneath the impoundment, the site 'selected for a the background boring deems inadequate. It is recommended that more soil samples be collected and then analyzed, from new borings located in areas unaffected by seepage' from the impoundment, or other possible sources of contamination at the facility. Also, due to the fact that the purgeable organics toluene, ethylbenzene, and xylene were detected in soils beneath the impoundment, background soils samples should likewise be analyzed for these contaminants. This would make possible a better comparison between contaminated and uncontaminated soils. K. A description of the existing monitoring being conducted to detect leachate, including vadose zone monitoring, the number and positioning of the wells, the monitoring wells' distances from the surface impoundment, the monitoring wells' design data, the monitoring wells' installation, the monitoring development procedures, the sampling methodology, the sampling frequency, the chemical constituents analyzed, and the analytical methodology. The design data of the monitoring wells shall include the monitoring wells' depth, the monitoring wells' diameters, the monitoring wells' casing materials, the perforated intervals within the well, the size of the perforations, the gradation of the filter pack, and the extent of the wells' annular seals. Four lysimeters were installed directly beneath, and adjacent to the impoundment and are located in borings L-l, L-2, L-3 and L-4 (see Plate 2). Boring L-1 is located along the immediate southwesterly margin of the impoundment, L-2 along the southern margin, and L-3 along the southeasterly margin. The background lysimeter (L-4) is located approximately 265 ft. northeast of the impoundment. Borings L-l, L-2, and L-3 were drilled at an angle of 40 degrees beneath the impoundment, and the lysimeters installed at depths of 30 ft., 9 ft. and 12 ft. respectively. Installation and development procedures are discussed in Chapter 5, sections 2.1 and 2.2 of the HAR. These procedures appear to be 9 e e NALCO CHEMICAL HAR 26 August 1988 adequa~e. Three ground water monitoring wells (MW-1, MW-2, and MW-3) were completed to approximately 160 ft. beneath the ground surface on the site. They were designed to intercept only the upper portion (upper 20 to 25 ft.) of the unconfined aquifer. Monitoring well MW-1 is located approximately 80 ft. to the southwest of the impoundment,MW-2 is approximately 45 ft. to the northwest, and MW-3 is approximately 120 ft. to the northeast (see Plate 2). All necessary design data for monitoring well installation and development are present in the HAR and appear to be adequate. These data are discussed in Chapter 2, sections 1.2 and 1. 3 . Plate 3 diagrams the design used for construction of the monitoring wells. All three moni toring wells were . developed using compressed air and purged using the EPA (1987)· Technical Enforcement Guidance Document methods. ' A total of eight samples from L-2 and L-3 were collected on September 29, 1987, and October 20th and 28th, 1987. No samples were collected from L-1 and L-4 due to insufficient soil moisture or the vadose strata being too coarse for the lysimeter to function. No set intervals for collecting samples from the Lysimeters were provided. The types of chemical constituents analyzed were priority pollutant metals, purgeable organics, and base/neutrals and acids. A total of 25 samples have been collected from MW-1, MW-2 and MW- 3 on December 8th and 9th, 1987. These samples were tested for inorganic maj or ions and metals, base/neutrals and acids, and purgeable organics. Analytical methodologies for both the lysimeter and monitoring well samples were reviewed and appear adequate. L. Documentation demonstrating that the monitoring system and methods used at the facility can detect any seepage before the hazardous waste constituents enter the waters of the state. This documentation shall include, but is not limited to the following: 1. The monitoring wells are located close enough to the surface impoundment to identify lateral and vertical migration of any constituents discharged to the impoundment. Based on the detection of contaminants from lysimeter samples L-2 and L-3, it can be concluded that the lysimeters were properly located beneath the impoundment. The reliability of the, lysimeters to collect samples, however, does not appear to be appropriate for nioni toring purposes. This is evidenced by the 10 e - NALCO CHEMICAL HAR 26 August 1988 inability of L-1 to collect a sample. The location suitability of monitoring wells MW-1, MW-2 and MW-3 is primarily ~ function of the direction of the ground water gradient. At one time of the year, MW-2 is in a downgradient direction from the impoundment, and at another time, MW-2 and MW- 3 are in a downgradient direction (see Plates 10 and 10.1). Although contaminant concentrations, especially that of zinc, have been detected in samples from MW-1, MW-2 and MW-3, it is necessary for a ground water moni toring well to be constructed immediately adjacent to the impoundment to better identify quantitatively and qualitatively, the contamination that has resulted from impoundment leakage. At present, the locations of the existing ground water monitoring wells are only adequate to determine that leakage has occurred. 2. The monitoring wells are not located within the influence of any adjacent pumping wells which might impair their effectiveness. The effectiveness of the monitoring wells is possibly influenced by local extraction wells, based on the variant ground water gradient directions evidenced at the NALCO facility. This subj ect, however, was not addressed thoroughly in the HAR and merits further detailed attention. 3. The monitoring wells are only screened in the aquifer to be monitored. The monitoring wells are screened at 145 ft. to 160 ft. below the ground surface and penetrates the aquifer to be monitored approximately 20 to 25 feet. 4. The chosen casing material does not interfere with, or react to, the potential contaminants of major concern at the facility. The casing diameter of 4 in. deems appropriate for the development of holes drilled to 160 ft. No glues or solvents were used to construct the monitoring well casing. 5. The casing diameter allows an adequate amount of water to be removed during sampling and allows full development of the monitor well. Matters pertaining to this subsection are addressed in subsection K-4 above. 6. The annular seal prevents pollutants from migrating 11 e - NALCO CHEMICÀL HAR 26 August 1988 down the monitor well. The annular seal method used for the monitoring wells is appropriate and constitutes a bentonite plug and bentonite/cement grout. The annular seal should prevent pollutants from migrating down the monitoring well. A detailed diagram of monitoring well construction is shown in Plate 9 of the HAR. I" 7. The methods of water sample collection require that the sample is collected after at least five well volumes have been removed from the well and that the samples are transported and handled in accordance with the united states Geological survey's "National Handbook of Recommended Methods for Water Data Acquisition", which provides guidelines for collection and analysis of ground water samples for selected unstable constituents. No mention was made as to the removal of 5 well volumes before samples were taken. It was mentioned, however, that the well was jetted dry and allowed to recharge "several" times. This is appropriate for low yielding wells according to the EPA (1987) Technical Enforcement Guidance Document. Also mentioned was that water samples were collected after pH, EC and temperatures were stabilized using the same EPA Guidance Document procedures for low yielding aquifers (see AppendixC of the HAR) . 8. The hazardous waste constituents selected for analysis are specific to the facility, taking into account the chemical composition of hazardous wastes previously placed in the surface impoundment. The monitoring data shall be arranged in tabular form so that the date, constituents, and the concentrations are readily discernible. Based on Table 1 (potential Hazardous Substances Handled At NALCO Bakersfield Facility), Table 2 (Formations Containing Hazardous Substances), and the Material Safety Data sheets provided in Appendix C of the HAR, hazardous waste constituents selected for analysis are specific to the facility. Constituents analyzed for included inorganic pollutant metals and major ions, base/neutrals and acid extractable organics, total extractable hydrocarbons, purgeable hydrocarbons, total organic matter, total dissolved solids, and alkalinity. 9. The frequency of monitoring is sufficient to give timely warning of leachate so that remedial action can be taken prior to any adverse changes in the quality of the ground water. 12 e e NALCO CHEMICAL HAR 26 August 1988 No set intervals or frequencies of monitoring were discussed in the HAR. Sample collection for the HAR was conducted under a detection monitoring program and was sufficient to detect the presence of waste constituents in the vadose and saturated zones beneath, and adjacent to the impoundment. 10. A written statement from the qualified person preparing the report whether any constituents have ' migrated into the vadose zone, surface water bodies, perched water, or water-bearing strata. Hazardous constituents have migrated into the vadose zone and into the ground water. Statements pertaining to this matter are contained within the HAR (see pages 72, 73 and 75). 11. A written statement from the qualified person preparing the report indicating whether any constituents have migrated into the vadose zone, surface water bodies, perched water, or water -bearing strata is likely or not likely to occur within the next five years, and any evidence supporting that statement. These statements are provided in the HAR (see pages 75 and 76) and conclude that waste water from the impoundment is not likely to migrate into surface waters, vadose zone or ground water within the next 5 years. It was stated, however, that impoundment leachates wi thin 8 ft. of the impoundment's base, have the potential to migrate into ground water within the next 5 years. CONCLUSIONS ~ Information provided by Kleinfelder's 29 January 1988 HAR, indicate that the impoundment at the NALCO facility has leaked contaminated water into surrounding soils and ground water. The types of contaminants detected are constituents of equipment rinse water that is specific to the facility's surface impoundment, or "evaporation pond". Results of soil analyses for samples collected from specific borings below and adjacent to the impoundment, detected concentrations of pollutant metals arsenic, zinc, barium, chromi urn, 1 ead, and vanadi um to exceed STLC' s . Organic analytical results detected concentrations of toluene, ethyl benzene, base/neutral and acids, and xylene. On-site, monitoring well water sample analysis 'detected elevated concentrations of total extractable hydrocarbons (TEH), bis-(2- ethylhexyl) phthalate, and zinc. Also detected were concentrations of unidentified base/neutral and acid extractable organics. Zinc concentrations exceeded MCL's for the water 13 .,. e e NALCO CHEMICAL HAR 26 August 1988 sample collected from MW-2 which is approximately 35 ft. northwest of the impoundment. Migration of rinse water constituents from soils directly below and adjacent ~o the impoundment and into on-site ground water, is expected to continue during the next 5 years. Unless the impoundment is kept dry of all discharges and rainwater, there is no present, or future guarantee that the impoundment is suitable to isolate contaminated water from soils and ground water bordering the impoundment. In order to complete the HAR, and fulfill the requirements specified under TPCA, the following items must be addressed and included: 1 - Provide a more detailed descriptiori of past impoundment liner failures, as well as a detailed description of the present liner condition. Of particular interest, is the cracked area along the south gunite wall and the area of the 1979 PVC liner failure. 2 - Tabular data specified in subsection (D) should be provided for the Farmers Canal. 3 - site specific cross sections that show all water~ bearing strata that possibly exist beneath the site, are needéd. The General Geologic Cross section (Plate 6) provided, is not sufficient for our needs. 4 - Background water sampling and chemical analysis must be conducted for all other water-bearing strata that possibly exist beneath the site. This should become possible after item 3 above is completed. since monitoring wells MW~1,~MW-2, and MW-3, and domestic and irrigation wells CBK-11 and Snavely are downgradient of the impoundment during certain times of the year, they are not recommended for use in determina- tion of background water quality. Due to the presence of zinc in the Costa, Snavely, and CWS-4 wells, they too are not recommended for the determination of background water quality. It is recommended that additional background, subsurface water samples be collected from locations which have not been affected by leakage from the impoundment, and then analyzed. 5 - A selection' of new locations for borings necessary to collect samples for background chemical analysis is needed. Present background analysis indicates that soils from the existing bore hole location are contaminated. 14 e e NALCO CHEMICAL HAR 26 August 1988 6 - Due to the fact that ground water flow direction varies from the SQuthwest'" to the':~~orthwest beneath the site , it will _ be i'.necessary to '_address more thoroughly, the possiblè " i.nf~pè:~'?e.'. that adjacent pumping wells impose. 7 - A discussion., ~f'·:f'the"·¡'è:hemical and hydrological characteristiç~¡'~9f ,the "cönsolidated and unconsolidated lithic material comprised within the vadose zone from 30 ft. to the ground water table is needed. 8 - Discuss the reasons for not testing soil samples for TEH contamination, and what' follow-up analysis will be conducted to determine the type and possible toxicity, of the unidentified base/neutral and acid extractable organics detected in ground water monitoring well samples, and those collected beneath the impoundment from borings L-1, L-2, and L-3. 9 - Provide as required in subsection D of the HAR, well logs and/or driller's reports for all water wells wit in a 1 mile radius of the facility. As a result of impoundment leakage, it will be necessary to formulate and then submit, remedial work plans that address the extent of vertical and lateral soil and ground water contamination and the actions to be conducted in its cleanup. VSM 15 e - GEORGE DEUKMEJIAN, Governor STATE OF CALIFORNIA 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 24 November 1987 Mr. K. Odlan:l Nalco Chemical CoIrpany 1 Nalco Center Naperville, Illinois 60566 REVIE.W OF HYDROI.CGICAL ASSESSMENT REFORI' IDRK PIAN FUR '!HE BAKERSFIEID FACILI'IY, 1ŒRN CXXJNIY \ We have reviewed the work plan for the Hydrological Assessment Report (HAR) for your Bakersfield facility. Enclosed is a copy of our comments . Prior to 31 J:ecember 1987, please submit the completed HAR. The completed report will be subject to our review ani approval. If you should have any questions regarding this matter please telephone Chris Chalfant at (209) 445-6191. F. scott Nevins Senior Engineer Enclosures ccc cc: Mr. Geny White, I:'epartment of Health Services, Fresno Kern County Department of Health Services, Bakersfield Mr. Russ carey, Kleinfelder arrl Assoc:iates, Fresno e Memorandumtl I ' 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: F. SOOIT NEVINS SENIOR ENGINEER FROM: æRIS aIALFANT STAFF ENGINEER DATE: 23 NOVEMBER 1987 SIGNATURE: ~~ SUBJECT: NALCD æEMICAL a:::MPANY, HAR IDRK PIAN REVIEW, KERN CXXJNI'Y OOMMENTS : I have reviewed the draft Hydrc:geological Assessment Report (HAR) Work Plan (work plan) prepared by J .H. Kleinfelder am Associates (Kleinfelder) urrler the direction of Nalco Chemical Company (Nalco) for Nalco's Bakersfield facility. The HAR will be submitted to - fulfill the provisions of the Toxic Pits Cleanup Act of 1984 (TPCA). I will incorporate the sections of the "Outline for Hydrc:geologic Assessment Report" (outline) in developing the following comments am will discuss the adequacy or inadequacy of the work plan regarding each section of the outline. I. IDENTIFICATION OF THE FACILI'lY The Bakersfield facility is located at 4851 Stine Road in the Stockdale In:fustrial Park. The facility is CMl1ed am operated by Nalco O1emical Company. The subj ect in1pourrlment is located directly west of the warehouse am directly south of the tank farm at the site. II. PREPARATION OF THE REroRI' The HAR is being prepared by Kleindfelder am Associates. Mr. Russell Carey (R.C.E. # 41868) will be the person responsible for the report. III. WASTE CHARAcrERISTICS A. Identification of individual contaminants contained within the iIrpourrlment. '!he disposal of wastes to the subject in1pourrlment was stopped in early 1986. In the past wash water fram product tanks am trucks was discharged to an oil sJdJmner. Flœ.ting hydrocarbons were collected by the sJdJmner am the urrlerflow was discharged to the subject in1pourrlment. Background infonnation indicates that corrosion an:i scale inhibitors, emulsion breaking A/J ,__ _" e . Nalco BAR Work Plan -2- 23 Novemœr 1987 chemicals, aromatic volatiles, alcohols, am hydrocarbons are stored at the site and may have been discharged to the ~t. 'n1e following analysis have been proposed to characterize ground water, surface water and soils in and arourxi the site: major ions, electrical comuctivity, pH, total dissolved solids, volatile organics, semi -volatile organics, and priority pollutant metals. B. Present chemical nature of the irxlividual constituents contained within the ~t. All sludge and waste residuals were removed from the i1npourrlrnent by Nalco in 1986 and disposed of at Chemical Waste Management's Kettleman Hills Facility. '!he work plan irxlicates that insufficient residual sludge remains to obtain and analyze a representative sample of the original discharge material. IV. PHYSICAL PIAN1' A. A DESCRIPrION OF THE SQRFACE ~ '!he subject surface ~t is described in the work plan as a concrete lined porrl with ciilnension of 84 feet by 44 feet, with a total capacity of about 70,000 gallons. B. æARACI'ERISTICS OF LINER(S) '!he work plan does not irxlicate that the liner char,acteristics will be fully described in the final HAR. '!his must be done pursuant to section 25208.8 (a) of the TPCA. v. CLIMA'IDIOGY Rleinfelder proposeS to use, available data on temperature, precipitation, and evaporation to develop the mean annual precipitation within 10 miles of the facility: the maxinu.nn 24 hour precipitation event: and the estiInated maxiJnum and minimum annual precipitation events at the site. '!he work plan irrlicates that the facility is outside the Ke.m River 100 year flood zone. VI. SURFACE WATER '!he work plan identifies: two canal systems, one large storm water runoff-recharge pond, and several small e e Nalco HAR Work plan -3- 23 November 1987 privately owned earthen SlIIl'pS, as the only surface water bodies within one mile of the site. IG.einfelder proposes to collect samples from all identified surface water bodies, if possible. In addition historical infomation concemin:.J water quality for the identified water bodies will be presented in the f:ina1 HAR. VII. WELIS IG.eirrlfelder proposes to c:orrluct a well sw:vey to lcx:::ate all wells within one mile of the surface Ì1rIpOI..II'rlm. Well recoros will be collected, reviewed, and tabulated to indicate water level, water quality, construction details (if available), and water use. Where pennission can be obtained, water levels and water sanples will be obtained for analysis. VIII. GRaJND WATER A. Perched, unconfined, and confined ground water bodies 1. Identification of each ground water body which could be affected... 2. Hydrogeological analysis of the vertical and lateral extent of each identified ground water body . 'Ihree IOC>nitoring wells will be installed to 20 feet below the first encountered grourrl water, esti1nated to be at a depth of 150 feet. '!bese wells should satisfy the requirements of items number 1 and 2 above. 3. Measured depth, from the ground surface to the potentiometric surface... 4. Slope of the potentiometric surface... 5. Estilnate of the direction of grourrl water movement. . . '!be water levels will be measured in the three IOC>nitoring wells as well as in identified existing wells near the site. '!bese measurements will be used to establish the slope of the piezometric surface and estimate the direction of the grourrlwater flow. e - Nalco HAR Work Plan -4- 23 November 1987 6. Estimate of the rate of movement of gJ:."'OlJIñ water.. . 7. Estimate of the transmissivity... 8. Estimate of the storage coefficient... A purrp test in one of the three monitoring wells is proposed. Data collected from the pLm1p test will be used to determinè the transmissivity of the aquifer. '!he storage coefficient ani rate of grourrlwater movement will be estimated from the data. 9. Determination of background water quality... It is proposed that background grourrlwater samples will be collected from the monitoring well identified as upgradient. '!hese samples will be analyzed for the same parameters as the rest . of the grourrlwater samples. '!his should be adequate. 10. Nature ani extent of hydraulic continuity of identified grourrl. water bcx:lies ani regional g:rourñ water bcx:lies. Data obtained form the Kern County Water Agercy irxlicates that deeper aquifers exist below the first encountered groun::l water. '!he work plan irxlicates that deeper monitoring will not be comucted at this time. '!he final HAR must include the provisions of section 25208.8 (g) of the Act. IX. VAJX)SE ZONE A. Carrposition of the vadose zone tmder the impoundment. B. Soil moisture arourrl the perimeter of the i:mpoundment ani at the maximum depth of the i:mpoundment. c. Bac.kgrourrl soil chemistry. '!he work plan irxlicates that the vadose zone characterization is 80% c:c:mg;>lete. '!he investigation included collection of soil samples from below the impoundment using angle borings ani from a backg:round location not affected by the discharge. '!he samples were analyzed for moisture content, selected metals ani volatile I -- -- Nalco HAR Work Plan -5- 23 November 1987 ani semi -volatile organics. INsimeters were installed in the borings ani were pw:ged, samples were. submitted for analysis. '!be p:rocedures, results, ani firxii.rqs will be presented in the final HAR. x. EXISTING M:>NI'roRING FACILITIES '!here is no existing I'IOnitoring system at the facility. However, the proposed I'IOnitoring system must meet the criteria listed in the outline. It is proposed that three I'IOnitoring wells will be installed. '!he proposed lcx::ation of the wells is not presented in the report, however Mr. Carey has iIxlicated that the wells will be lcx::ated in a triangular pattern within approxilnately 100 feet of the subject i.mpourrlrnent. Monitoring wells used for the detection of any migration of constituents from the impoundment must be lcx::ated down gradient and as near to the ÌIr1pOUrxÈIent as possible. '!be wells will be constructed of 4 inch schedule 40 PVC pipe with 0.02 inch machine slotted well screen ani flush threaded joints. '!he well screens will be 30 feet long, spanning from 20 feet below the first encountered grourx:l water to 10 feet above. '!he filter pack, consisting of number 16 Monterey sam, will ext:errl from 5 feet above the well screen to the bottom of the well. Wells will be air developed following installation. Samples are to be collected after field measurements of pH, temperature, and electrical corxìuctivity stabilize. The TPCA requires that at least 3 to 5 well voltnneS are purged prior to sampling (section 25208.8 (1.7.». Samples will be analyzed for those constituents listed in Section III. B. using EPA methods . B. D:x::urnentation that existing grourrl water and vadose zone I'IOnitoring will detect any seepage from the i.mpourrlrnent. . . 1. SUbstantiation that I'IOnitoring wells are close enough to the i.mpourrlrnent to identify any lateral migration of constituents from the i.mpourrlrnent. 2. SUbstantiation that I'IOnitoring wells are close enough to the impoundment to identify any vertical migration of constituents from the i.mpourrlrnent. ' '!he work plan does not iIxlicate the proposed location of the monitoring wells. Monitoring wells to be used for the detection of any vertical or lateral migration of constituents from the subject impoundment must be located I I e e I Nalco HAR Work Plan -6- 23 November 1987 I' i1nmediately adjacent to the ilrpoundment. '!he final EAR 1ID..1St shCM that the wells are properly located to identify ~ lateral ani vertical migration of constituents from the i1rpourrlment. 3. SUbstantiation that mnitoring wells are not located within the area of influence of ~ pumping well... Mr. carey has indicated that pumping wells are not located adjacent to the facility, the final HAR IInlSt substantiate that. I' I I 4. SUbstantiation that the mnitoring wells are only perforated (screened) in the aquifer or water- bearing zone to be mnitored. '!he work plan indicates that the mnitoring wells will be only located in the first encountered grou:rrl water. '!he use of a 30 foot well screen am 35 foot filter pack may dilute the sample am would therefor be inappropriate for the detection of the constituents of concern. A 10 foot well screen would be preferred. 5. SUbstantiation that the casing material of each monitoring well does not interfere or react with the potential contaminants of major concern in the i1rpourrlment. '1he use of PJC is typically acceptable for the detection of lCM concentrations of volatile organics am metals which are expected in this investigation. However the final HAR IInlSt substantiate PJC' s acceptance. 6. SUbstantiation that the casing diameter for each mnitoring well allows complete development of the mnitoring well. 7. SUbstantiation that the casing diameter for each mnitoring well allows an adequate amount of water to be removed during sampling. '!he use of 4 inch diameter casing is typically adequate. HCMever the required substantiations must be included in the final HAR. 8. SUbstantiation that the annular seal in each grouOO water mnitoring facility prevents dCMl'lWard movement of pollutants... I e .. - Nalco EAR Work Plan -7- 23 November 1987 '!he 'WOrk plan irx:licates that bentonite pellets will be placed above the sam packs ani that the :remai.ni.rç annular seal will be pressure grouted to the surface with a sarrl¡cement sluny. '!he integrity of this seal nn.1St be substantiated in the final EAR. SUch substantiation would include field notes irx:licating the method of placement of the seal, type of mix used, ani arrj field problems encountered. 9. Methodology of grourñ water sampling. 'Ihe proposed method of collecting samples is adequate except that 5 well volumes must be purged prior to collecting the samples. 10. Rationale used for the determination of a frequency of monitoring... 'Ibis ImlSt be presented in the EAR. 11. Harrlling and transportation of samples. All sample hanlling ani transport must confO:t111 with accepted analytical practices with regard to preservation, storage, am holding times. 12. SUbstantiation that the specific hazardous waste constituents selected for analysis are specific to the facility... 'Ihese are adequately addressed in the work plan. XI. l.:l2tl'il·~CATION All the certifications listed in this section ImlSt be included in the EAR. MAPS AND CROSSECI'IONS '!he infornation in this section nnlSt be incorporated as applicable in the HAR. e - e Nalco ,liAR Work Plan -8- 23 November 1987 CDNCIIJSIONS: '!he followin;¡ are items which the work plan does not address fully and must be' included in the liAR in order to complete the requirements of the TPCA: 1. '!he final liAR must include all of the points required in section 25208.8 (a) of the TPCA or "A description of the surface Ì1TpOun:1ment, including its physical size, its age, the presents or absence of a liner, a description of the liner, the liner' s conpatibility with the hazardous wastes discharged to the Í111pOurxìment, and the design specifications of the Í111pOurxìment." 2. '!he final liAR must include the provisions of section 25208.8(g) or "An indication of whether the grourrlwater is contiguous with the regional bodies of groundwater and the depth measured to the groundwater, including the depth measured to perched water and water-bearing strata identified on the maps specified in paragraph (1)." (paragraph 1 of section 25208.8 (f» 3. '!he methods of sample collection must confom with the provisions of section 255208.8 (1. 7 .) or "'!he methods of water sample collection require that the sample is collected after at least five well voluínes have been removed from the well and that the samples are transported and harxiled in accoràanoe with the United states Geological SUJ::vey's "National Harrlbook of Reconm1errled Methods for Water-Data Acquisition," which provides guidelines for the collection and analysis of grourrlwater samples for selected constituents. If the wells are low-yield wells, in that the wells are incapable of yieldirg three well volumes during a twenty-four hour period, the methods of water sample collection shall insure that a representative sample is obtained from the well." 4. 'Ihree Ironitoring wells have been proposed for the site. '!he location of the Ironitoring wells was not indicated in the work plan. If arr:¡ of the wells are to be use to identify arr:¡ migration of constituents from the in'pourxtnent then they must be located down gradient and as near to the Ì1TpOun:1ment as possible. . 5. ,'!he followin;¡ substantiations (section 25208.8 (1) of the TPC'A) must be included in the final liAR: a) 'Ihat the Ironitor wells are located close enough to the surface Í111pOurxìment to identify lateral and vertical migration of arr:¡ constituents discharged to the Ì1TpOun:1ment. e e Nalco lIAR Work Plan -9- 23 November 1987 b) That the mnitoring wells are not located within the ,influence of ~ adjacent pump:in;J wells which might inpair their effectiveness. c) That the mnitoring wells are screened in the aquifer to be monitored. d) That the chosen casing material does not interfere with, or react to, the potential contaminants of major concern at the facility. e) '!hat the cas:in;J diameter allows full development of the lronitor well. f) That the armular seal prevents pollutants fram migrating down the mnitor well. g) That the hazardous waste constituents selected for analysis are specific to the facility, taking into aCCOlU'lt the chemical a:::mp::>sition of hazardous wastes previously placed in the surface impoundment. 6. OUr review of the final BAR will concentrate on the validity of the statements that must be made to satisfy the provisions of section 25208.8(1. 10. am 11.) or: "10) A written statement from the qualify:in;J person prepar:in;J the report indicat:in;J whether ~ constituents have migrated into the vadose zone, surface water bodies, perched water, or water-bearing strata. 11) A written statement from the qualified person preparing the report indicating whether ~ migration of leachate into the vadose zone, surface water bodies, perched water, or water-bearing strata is likely to occur within five years, am any evidence sup¡:x>rt:in;J that statement." ccc .; ..:I. _~~ \_ _"" c¡-. -- <1r 7Jih> -~C-I# Sl :-:==~ ~:;o:~~ ".-'.__- -:~~.--~':'".:' - ..-~ ..;;~~--~~... _.. -- . :;.~ "-'- - ._...-~--=-::.=--~,":" =-=-.~~==-.::.::::----==-~--~.~- Cf\UFORfiIA REGIONAL WATER QUALITY CONTROL· BOARD-- CENTRAL VALLEY REGION ...~, .r.l,:~__. SAN JOAOUIN WATERSHEO BRANCH OFFICE 3614 EAST ASHLAN AVENUE FRESNO. CAll¡;ORNIA 93726 PHONE; 12091445-5116 1 6 November 1986 ,~ If. "it ß~' i/,-~: . '. NOV 0 ""1986 :L KERN CO . UNTY hEAL 11. ' '17 Df:jJT t > I I I ~ ~' Mr. K. Odland' .Na1co Chemical Company 1 Na1co Center - Napervi11e, III inois 60566 -''''h ~~\-':f g,.~_ ,~ _TOXIC PITS CLEANUP ACT Ina recent telephone conversation with Chris Chalfánt of our staff, , you requested that the Bakersfield facility of NalcoChemical ,Company be exempted from the requirements of the Toxic Pits Clea~up Act of 1984. This law sets forth a number of requirements which define applicability of the Act. You have not submitted sufficient informa-- tion to demonstrate that the Act is not applicable to your facility. The enclosed check list indicates those areas where more information is needed. Please provide the required information so that we may evaluate your request. If our evaluation indicates that the Act is not applicable' to your facility, we will request the State Water Resources Control Board to refund all fees submitted in regard to the Act. A copy of the Act may be obtained free of charge from the Office of Legislative and Public Affairs, State Water Resources Control Board, P. O. Box 100, Sacramento, CA 95801. . If you should have any questions regarding this matter, please contact Chris Chalfant of this office at (209) 445-5145. -r~~ F. SCOTT NEVINS Senior Engineer CCC:djb Enclosure cc: Department of Health Services, Fresno Kern County Heal thDepartlTlent, Bakersfield ,:','