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HomeMy WebLinkAboutMINUTES - 09301986 - X.7 X.7 THE BOARD 'OF 'SUPERVISO'RS OF "CONTRA 'COSTA'--COUNTY, -CALIFORNIA Adopted this '-Order on September 30, 1986 , by the following vote: AYES: Supervisors Fanden, Schroder, Torlakson, McPeak NOES: None ABSENT: Supervisor Powers AB'STA'IN: None -------------------------------------------------------------------- -------------------------------------------------------------------- S'UBJECT: IT Corporation's Vine Hill and Baker Class I Disposal Sites, Martinez Harold J . Singer, representative of the State of California Regional Water Quality Control Board, San Francisco Bay Region, provided the Contra Costa County Board of Supervisors this day with a copy of Cleanup and Abatement Order No. 86-014 adopted by the Regional Board earlier this day. The Order is directed against IT Corporations Vine Hill and Baker Class I Disposal Sites in the Martinez area. He commented on the investigative process and pre- sented some historical background relative to the recurring problems at the sites. Mr. Singer commented on the scope of the Order pro- viding for mitigation measures to correct the problems as well as a closure schedule for the Baker and Vine Hill ponds by January 1, 1989 • In response to an inquiry of Supervisor Torlakson, Mark Finucane, Health Services Director, advised that his staff concurs with the action taken by the Regional Board. He further advised that his staff has reviewed the data presented to the Water Quality Control Board and is of the opinion that there is no significant public health hazard as a result of the traces of materials or emissions discovered at the sites. He noted that the action of the Regional Board will hasten the conversion and modernization of the Baker and Vine Hill facilities to a more responsible and technical storage facility in the future. Mr. Finucane advised that his Department will be working closely with the Regional Board in this matter. James Marierro, 1338 Clipper Street, Martinez, spoke about the need for an inspection-monitoring system at the Baker and Vine Hill sites by a government agency. He did not express confidence in the monitoring system of the IT Corporation. Mr. Marierro expressed support for immediate closure of the facility and direction to IT to stop accepting waste at these two facilities. Paul Macchia, 145 Hillside Lane, Martinez, expressed sup- port for mitigative measures and/or closure of the facilities. If the sites are to remain open, he recommended that that be no ponds, that an agency (other an the IT Corporation) be required to monitor the facilities, that inspectors be assigned to monitor air and water quality at the sights at all times, and that a full environmental impact report be. completed on the IT facilities at Baker and Vine Hill. Robert Gabriel, 133 Arkanlander Lane, Martinez, advised that the toxic ponds have been in existence for the last 20 years and expressed concern that IT has been allowed to operate a hazar- dous waste facility without a land use permit or environmental impact report. Board members considered the testimony presented and expressed concern with the timetable proposed in the Cleanup and Abatement Order. Supervisor Fanden suggested that the State Legislature be urged to look at ways for proividing funds to a State Agency to test and monitor hazardous waste being deposited at dispo- sal sites so as to insure and provide for the health and safety of the public. STATE OF CAUKRO A RDGIONAL K,TER QUP,LITY CONTROL BOARD SAN FRANCISCO BAY RDGION CLEANUP AND ABAM24M ORM R NO. 86-014 IT CORPORATION vnm BILL AND BALM CLASS I DISPOSAL SITES MART=, CONI PA COSTA COUNTY FINDINGS The California Regional Water Quality Control Board, San Francisco Bay Region (hereinafter called the Board) finds that: 1. IT Corporation, hereinafter called the Discharger, owns and operates Class I disposal sites called the Baker and Vine Hill facilities. The sites arelocated east of Martinez in Contra Costa County. The locations of the sites are Shawn in Attach wzrt A, which is incorporated herein and made a part of this Order. 2. The Board adopted Waste Discharge Requirements (Order No. 78-76) on September 19, 1978, which prescribe prohibitions, waste disposal specifications, leachate and drainage specifications, and provisions designed to protect waters of the State. 3. Order No. 78-76 states in part: "A. Prohibition The discharge of any waste or polluted runoff from the disposal areas to surface waters or groundwaters of the State is prohibited. B. Waste Disposal Specifications ••3. Waste materials shall be confined to the disposal sites as shown on Attachment A at all times... C. Provisions ••9. This Board considers the owner to have a continuing tirtu.irig responsibility for correcting any problem which may arise in the future as a result of this waste discharge or water applied to this property during subsequent use of the land for other purposes." 4. The Discharger submitted geotechnical information and water quality data on November 8,- 1984 in a report by LeRoy Crandall and Associates. The report showed that waste constituents may have been discharged to groundwaters of the State outside of the designated disposal area at the Baker facility. The resort included a contour map of chloride 1 concentration in groundwater, which showed highest chloride levels directly beneath ponds C and D-1 and decreasing levels towards the boundaries of the site. There also appeared to be a groundwater mound under the ponds that closely corresponds with the chloride contours. 5. This Board adopted Cleamip and Abatement Order No. 85-004 on January 16, 1985 because there was evidence of violations and/or threatened violations of the requirements of Omer No. 78-76 described in Finding 3. The Cleanup and Abatement Order, in part, required the Discharger to identify the extent of contaminant migration in groundwater at the Baker facility, identify at least one upgradient well for both Baker and Vine Hill, and certify the adequacy of the existing groundwater monitoring program at bath Baker and Vine Hill. 6. The Discharger has been cooperative and responded to the Cleanup and Abatement Order. However not all; the tasks proposed by the Discharger as part of the response have been', completed to date. In addition, review of the submitted materials indicates the need for additional investigation and re-examination of existing data. Cleanup and . Abatement Order No. 85-004 is no longer applicable because of the work that has been ccMleted. 7. The groundwater quality assessment program at the Baker facility has been inconclusive. The emphasis thaws far has been on inorganics (simple salts), while the constituents of conloern are more likely. organic coampounds. The Discharger had proposed to analyze the groundwater for numerous organics and heavy metals as-part-of the assessment program The report submitted on September 6, . 1985,, containing the findings of the assessment to date, contains very limited organic data. The assessment program must be oontinued and focused on constituents of concern 8. The Environmental Protection Agency (EPA), on June 4, 1981, awarded to the California Department of Health Services (LHS) Phase I Interim Authorization to administer the Resource Conservation and Recovery Act (RCRA).. The Interim Authorization .required that LHS impose interim status standards as required under RCRA. 9. LHS imposed interim status standards on the Discharger by issuing Interim Status Documents (LSD's) to the Discharger on March 6, 1981 for the Baker site and April 6, 1981 for the Vine Hill site. Section VIII of each ISD specifies that the Discharger must implement a groundwater monitoring program for each site by November 19, 1981. As part of such a groundwater monitoring program, the Discharger was required to perform various task including designation of an upgradient or background well, installation of an adequate number of downgradient wells that could immediately detect hazardous waste migration to the uppermost aquifer, analysis of groundwater samples for specific parameters, assessment of the groundwater quality, establisbrent of an initial background aritb metic mean, and determination of statistically significant changes in certain parameters. 10. The interagency agreement between rHS and the State Water Resources Control Board provides, in part, ithat the Board will inspect, review, and evaluate ISD groundwater monitoring at facilities regulated M%ler 2 RCf2A. 11. On June 21, 1985, an Interim Status meter Monitoring Evaluation by the Board staff for the Vine Hill facility was transmitted to the Discharger. This evaluation was based on review of file material and an inspection on May 1, 1985. The evaluation noted deficiencies in the groundwater monitoring system, the sampling and analysis plan, and the hydrogeological characterization of-the site. 12. The Discharger responded to the specific requests of the evaluation described in Finding 11, except for the submittal of a revised Sampling and Analysis Plan for the Vine Hill facility as promised in a letter dated September 13, 1985 frcm the Discharger. 13. On February 4, 1986, a Omnpliance Evaluation Inspection (CEI) report of an Interim Status Groundwater Monitoring Evaluation by the Board staff for the Vine Hill facility was transmitted to the Discharger. This evaluation was based on review of file material and an inspection on October 30, 1985. As with the 1985 evaluation, this inspection reported inadequate monitoring of the tit aquifer, (e.g. no monitoring of the fill material and lack of support for the placement of wells), incomplete hydrogeologic investigations (e.g. the failure to define the lower limit of the uppermost aquifer and the interconnection between different aquifer materials), and a deficient sampling and analysis plan. This evaluation also noted the lack of vertical gradient data, insufficient static water level data, confusing groundwater monitoring analyses reporting, arra lack of statistical evaluation of the groundwater quality data. 14. The Discharger has responded to the Fd=:ry 1986 CEI. However, the Board's staff and the State Board's geologist have determined that the responses have been inccnplete or inadequate, because the Discharger had not remedied the deficiencies noted in the CEI. 15. On June 30, 1986, a Ccmiplianoe Monitoring Evaluation by Board staff of the Interim Status groundwater monitoring program at the Vine Hill facility was transmitted to the Discharger. This evaluation was based on review of file materials and inspection on May 29, 1986. The evaluation restated all of the findings of the two evaluations described in Findings 11 and 13. In. addition, this Evaluation stated that the placement of the currently proposed background wells, MW-216 and 218, has not been adequately supported by water level data 16. Wells MW-226 and 218 at the Vine Hill facility have been judged by Board staff to be unacceptable as background wells because these wells were not constructed to intercept the full thickness permeable zones. 17. In a June 10, 1985 letter from the Board, the Discharger was instructed to submit an Assessment Monitoring Plan for the Vine Hill Facility. The request was made after the Board staff reviewed a report titled 'Sydrogeologic Data Analysis, Groundwater Monitoring .Program, IT Corporation's Vine Hill Facility - May 1985". This report was submitted as the Proposed Groundwater Monitoring Plan pursuant to Subchapter 15, Chapter 3, Title 23 of the California Administrative Code. The report described elevated levels of TOC, TOX, phenolics, 3 and boron in groundwater samples takers f, well MW-203. 18. The Discharger responded to the .June 10; 1985 letter by citing the long confusing history of the area around MW-203. The confusion arises because well MW-203 is located at the bourkluY between the Discharger's Vine Hill facility and Acme Landfill, and it is not clear . where the apparent contamination originates. The Discharger took the position that an Assessment Program is not justified. The Compliance Monitoring Evaluation described in Finding 15 restates the need for the Discharger to investigate the sources) of boron and phenolics in well MW-203. 19. On November 5, 1981, DuPont Ocanpany submitted a.report to the Board entitled "Lead Report - Boring Program Around Pond 10011. The report presented the results of a boring and lead analyses program,that the DuPont CmTany had conducted around Pond 100 at the Vine Hill site. The report documented apparent tetraethyl-lead (TEL) contamination of soils around and beneath ponds 100, 101, and 104. The Discharger has asserted that the high TEL levels were the result of faulty drilling and sampling methods and not actual contaminated soil. However, this assertion:has not been verified. 20. On June 19, 1985, an Interim Status Groundwater Monitoring Evaluation by the Board staff for the Bakes facility was transmitted to the Discharger. This evaluation was based M review of file material and an inspection on April 19, 1985. The Evaluation noted deficiencies with the Sampling and Analysis Plan and conflicting well construction data. 210 The Discharger responded to the June 1985 evaluation of the Baker facility with a revised Sampling and Analysis Plan and revised well construction data. However, the revised Sampling and Analysis Plan, Appendix H to a report dated September 6, 1985, did not remedy the deficiencies discussed in the evaluation, and therefore the plan is still deficient. 22. On June 30, 1986, a Cmapliance Monitoring Evaluation by Board staff of an Interim Status groundwater monitoring program at the Baker, facility,was transmitted to the Discharger. This evaluation was based on review of file material and an inspection on October 30, 1985. The evaluation cited deficiencies in the hydrogeologic characterization of the Baker facility, deficiencies in the Sampling and Analysis Plan, the lack of statistical analysis of groundwater quality data, and the lack of an adequate background well(s). 23. The currently proposed bad well at the Baker facility,- well MW- 112, has been judged by the Board staff to be unacceptable as a single. background well. 24. The reports and evaluations described in Findings 4, 11, 13, 151 16, 17, 19,20, 22, and 23 are evidence that the Discharger is violating and/or threatening to violate Order No. 78-76 and/or, its Interim Status Document at both the Vine Hill and Baker facilities.. 25. The continued existence of liquid in Class I ponds at the Baker 4 facility creates a hydraulic gradient outward from the pm-ds, which threatens to pollute gr=%Iwaters adjacent to the site. Water level oontours through 1985 continue to show a groundwater mound centered approximately around ponds C and D-1 beneath the site. In addition, several groundwater monitoring wells at the Baker facility have oonsistently shown higher levels of waste constituents than other wells. 26. Based on Findings 4, 6, 7, and 25 for the Baker facility, and Findings 17, 18, and 19 for the Vine Hill facility, it is evident that surface impoundments at both Baker and Vine Hill threaten to pollute State waters. Specifically, the State waters that are threatened are adjacent surface waters and groundwater under the site. the groundwater is not currently being used. 27. Section 25208.6 of the California Health and Safety Code (Toxic Pits Cleanup Act of 1984) requires a Regional Board to order the closure of a surface impoundments) if the Board finds that a surface impoundments) is polluting or threatens to pollute State waters, and if double liners, a leachate collection system, and a groundwater monitoring program will not reasonably assure future protection of State waters. Zhe Board may order the facility to install double liners, a leachate collection system, and a groundwater monitoring program instead of ordering the surface.impourxbwnts to close. 28. Section 25208.5 of the California Health and Safety Code ('Toxic Pits Cleanup Act of 1984) requires that on or after January 1, 1989, no person shall discharge liquid hazardous wastes or hazardous wastes containing free liquids into a surface impotundment unless the surface impoundment is double lined, equipped with a leachate collection system, and groundwater monitoring is conducted. Section 25208.2 (f) of the California Health and Safety Code defines "discharge" to include storage of liquid hazardous wastes or hazardous waste containing free liquids. 29. This action is an order to enforce Waste Discharge Requirements previously adopted by the Board, statues, and other regulations. Therefore, this action is catagorically exempt froom the provisions of the California Environmental Quality Act pursuant to Section 15321 of the Resources Agency Guidelines. IT IS HEREBY ORDERED, pursuant to Section 13304 of the California Water Code, that IT Corporation, Vine Hill and Baker facilities, cleanup and abate the effects described in the above findings as follows: 1. Clarify and remedy the groundwater water level reporting method for both the Vine Hill and Baker facilities as follows: a. Conpile, tabulate, and summarize all the available static water level data by individual well. For each well and each sampling period, the information shall include: 5 i. water levels taken both before p =ging and after sampling; ii. water levels shall be measured to the nearest 0.01 foot, relative to the surveyed reference elevation and mean-sea-level; iii. the date and time the water levels were taken; iv. method used to determine water levels; and V. surveyed reference elevation for each well. Water level contours shall be constructed for each sampling period and each stratigraphic horizon, and submitted with all the above information. Contours are to be constructed from measurements taken in wells screened in the same stratigraphic horizon and have similar screen elevations and screen lengths. The data points and values used to construct each contour shall be shown on each map. A report including all the information listed in this task is due DeomTber 1, 1986. b. All future reporting of water level data shall include the information listed in Task La. 2. Summarize the existing water quality data and establish initial background quality for bath the Baker and Vine Hill facilities as follows: a. Compile, tabulate, and summarize all groundwater chemical data available for both the Baker and Vine Hill facilities by individual well. The detection limit for each constituent shall be listed. A report shall be submitted to the Board by December 1, 1986. b. All future submittal of groundwater quality data shall include the detection limit for each constituent, a list of which constituents were tested for each individual well, and the rationale behind the analysis schedule. 3. Establish initial background groundwater quality levels for both the Baker and Vine Hill facilities as follows: a. Submit a detailed plan and schedule for collecting and statistically analyzing groundwater quality data to establish initial background levels for Executive Officer approval by December 11, 1986. 'The plan shall provide for determining background levels for different aquifer units, and take into account spacial and seasonal variations in .groundwater quality. If existing groundwater monitoring wells are to be used for establishing initial background levels, the Discharger shall provide specific hydrogeologic data to support the placenents of the wells and the selection of the screened intervals. b. Implement the approved plan from Task 3.a according to a schedule specified by the Executive Officer. c. Submit initial background water quality data with the necessary_ statistical analysis by a date to be specified by the Executive Officer. 6 4. Submit.revised Sanpling and Analysis Plans for both the Baker and Vine Hill facilities which address the deficiencies noted in the respective Cmpliance Monitoring Evaluation described in Findings 14 and 20. In addition, the Plans shall include well specific sanpling and analysis schedules, and add turbidity as a parameter for anaysis. The Sampling and Analysis Plans for both facilities shall be submitted by November 1, 1986. 5. Submit the following information or report by November 1, 1986 to complete previous submittals: i. Development logs for wells MW-115 to 119 and 107A at the Baker facility (as promised in Apperrlix E of the Phase I omnpletion report dated September 6, 1985) 6. Investigate and.thoroughly characterize the hydrogeology at the Vine Hill facility as follows: a. Submit a detailed plan and schedule to accomplish the tasks listed below by November 15, 1986 for Executive Officer approval. If the Discharger asserts that the work to acxompl ish the tasks listed below have already been done, then the Discharger shall submit a report(s) documenting the determinations by presenting the specific data which support the conclusions. i. Define vertical gradients across the site with actual depth specific data (as would be gathered from cluster piezometers). Also define vertical hydraulic conductivities for the various hydrogeologic units beneath the site. ii. Clearly identify the various aquifer/aquitard zones across the site and designate which wells are screened in the respective zones. Included in this task are revised crass sections which accurately reflect the lithology registered in the well and boring logs. In addition, discuss and provide specific data that demonstrate the integrity and continuity of all aquitards at the site. iii. Compile or obtain stratigraphic, lithologic, and hydrogeologic information to address the potential of the bedrock 'high' beneath the site (reference Geologic cross sections in report titled "Supplemental Information in Response to Compliance Evaluation Inspecion FY 85-86 - IT Corporation Vine Hill Facility) to act as a pathway for contaminant migration. Included in this tasks shall be constructing a "top of rock" contour for the site. iv. Define the seasonal variations in groundwater levels in all existing wells and present the result in the form of hydrographs. The hydrographs shall depict monthly data through an entire year. b. Irplemesnt the hydrogeologic investigation and characterization program from Task 6.a according to a schedule approved by the 7 Executive Officer. c. Submit a report acceptable to the Bmautive Officer documenting the findings of the hydrogeologic characterization program, signed by a registered civil engineer or certified engineering geologist, by a date to be specified by the Executive Officer. the report shall include all support data, tabulated and presented in a logical and easy to follow format. 7. Investigate the apparent tetraethyl-lead (TEL) contamination of soils around Ponds 100, 101, and 104at the Vine Hill facility as follows: a. Subunit a plan and schedule for a boring and TEL analysis program to confirm or refute the findings of the 1981 DuPont report, described in Finding 19, for Executive Officer approval. The program shall provide for soil sampling at the specific depths and locations where TEL concentrations were found to be greater than 1000 parts per million. The plan and schedule is due December 15, 1986. b. Implement the boring and TEL analysis program according to a schedule approved by the Executive Officer. c. Submit a report acceptable to the Executive Officer d=nenting the findings of the boring and TEL analysis program, signed by a registered civil engineer or certified engineering geologist, by a date specified by the Executive Officer. The report shall include all the specific data used to make the determinations. 8. Determine the source of elevated phenol, boron, TOC, and TOX levels in groundwater monitoring well MW-203 at the Vine Hill facility as follows: a. Submit detailed plan and schedule for determining the source of contaminants found in well MW-203. The plan shall contain provisions for (1) determining the location of well MW-203 with respect to the Discharger's north-south containment dike along Pond 101; (2) determining the location of well MW-203 with respect to the previous gap between Acme Landfill's and the Discharger's north-south dike in the vicinity of the well; (3) determining the relationship between the aquifer unit screened by well MW-203 and the bottom of the containment dike; (4) determining the vertical and horizontal extent of the peat layer screened by well MW-203; (5) sampling and analyzing well MW-203 for all priority pollutants; (6) couparing the analytical results of (5) to the contents of Pond 101; (7) cxrparing the analytical results of (5) to the historical data of constituents found in the leachate collected froom the ditch which used to exist between Acme landfill and the Vine Hill facility; and (8) draw conclusions as to the source of elevated contaminants in well MW-203 based on the above. The plan shall be submitted for Executive Officer approval by December 1, 1986.. b. ?mplement the plan from Task 8.a according to a schedule approved by the Executive Officer. 8 c. Submit a report acceptable to the Executive Officer documenting the findings of the determination, signed by a registered civil engineer or certified engineering geologist, by a date to be specified by the Executive Officer. The report shall include all the specific data used to make the determination, tabulated in a logical format. 9. Augment the groundwater monitoring system at the Vine Hill,facility to monitor the groundwater in the fill material as follows: a. Submit plan and schedule for defining the areal extent of the fill and for installing additional monitoring wells in the fill layer for Executive Officer approval by January 15, 1987. Zhe proposal shall include the rationale behind the various tasks. b. Implement the plan frcmn Task 9.a according to a scheule approved by the Executive Officer. c. Subunit a report acceptable to the Executive Officer documenting the installation of the monitoring system, signed by a registered civil engineer or certified engineering geologist, by a date to be specified by the Executive Officer. The report shall include all relevant data ( eg. well logs, construction details, and developrent logs, presented in a logical and easy to follow format) 10. Investigate and thoroughly characterize the hydrogeology at the Baker facility as follows: a. Submit a detailed plan and schedule to accomplish the tasks listed below by November 15, 1986 for Executive Officer approval. If the Discharger asserts that the work to accomplish the tasks listed below have already been done, then the Discharger shall submit a report(s) documenting the determinations by presenting the specific data which support the conclusions. i. Define vertical gradients across the site with actual depth specific data (as would be gathered fr n cluster piezometers). Also define vertical hydraulic conductivities for the various hydrogeologic units beneath the site. A. Clearly identify the various aquifer/aquitard zones across the site and designate which wells are screened in the respective zones. Included in this task are revised cross sections which accurately reflect the lithology registered in all the well and boring logs. In addition, discuss and provide specific support data that demonstrate the integrity and continuity of the various aquitards at the site. iii. Characterize the structure and permeability of the bedrock underneath the site. Included in this task is at least one borehole, with a m=—mum penetration of 20 feet into the bedrock, in the vicinity of ponds D-3 and E to provide a better definition of aquifer thickrmss in that area. 9 S ' iv. Explore the geology at the southeastern boundaries of Ponds D-1. and D-3. Included in this task are at least two borings in this . area where previous drilling had not been done, developing the boreholes into fully penetrating monitoring wells if a sandy zone is found,- and documenting the drilling with precise and accurate logs. v. Demonstrate, with specific data, the influence of Pacheco Creek and walnut Creek on the groundwater underneath the facility. Included in this task are (1) cross sections showing the relative water 1 evel s of the creeks, the ponds, and the groundwater; and (2) a determination of whether each surface body acts as a recharge or discharge to groundwater. vi. Define the seasonal variations in groundwater levels in all existing wells and present the result in the fora of hydrographs. The hydrographs shall have monthly data over a full year. Vii. Submit a topographic base map that enccmpassess an area extending 2000 feet to both east and west of the facility to aid in the determination of potential of off-site influences. b. Implement the hydrogeologic investigation and characterization program from Task 10.a according to a schedule approved by the Executive Officer. c. Submit a report acceptable to the Executive Officer documenting the findings of the hydrogeologic characterization program, signed by a registered civil engineer or certified engineering geologist, by a date to be specified by the Executive Officer. The report shall include all support data, tabulated and presented in a logical and easy to follow format. 11. Further assess the apparent waste constituent migration into groundwater at the Baker facility as follows: a. Submit a detailed plan and schedule by December 15, 1986, which will identify the vertical and horizontal extent of waste constituent migration. The plan shall be focused towards constituents of concern. b. Implement or continue the assessment program according to a schedule approved by the Executive Officer. c. Submit a report acceptable to the Executive Officer documenting the findings of the assessment characterization program, signed by a registered civil engineer or certified engineering geologist, by a date to be specified by the Executive Officer. All the support data shall be included and presented in a logical and easy to follow format. 12. Analyze the groundwater for the constituents listed in Appendix III, 10 Subchapter 15, Chapter 3, Title 23 of the California AcIninstrative Code in all the monitoring wells on the Baker facility-as follows: a. Submit a detailed plan and detailed schedule, specific to individual wells, for sampling and analyzing the groundwater for Appendix III constituents. - If the program is already underway, submit a list of tasks ccrtipleted and a detailed plan and schedule for accomplishing the remaining tasks. The report and,/or plan shall be submitted by December 1, 1986 for Festive Officer approval. b. Implement or continue the Appendix III sampling and analysis program according to a schedule approved by the Executive Officer. c. Submit the results of the Appendix III sampling and analysis program by a date to be specified by the Executive Officer. 13. Determine the status of both the Baker and Vine Hill facilities with regards to the Toxic Pits Cleanup Act of 1984 as follows: a (i) . Submit a report assessing whether the installation of double liners, a leachate collection system, and a groundwater monitoring system at the Class I ponds could reasonably assure protection of State waters by December 15, 1986. this report shall include a time schedule for the installation of double liners, a leachate collection system, and a groundwater monitoring system if the report determines that these would protect State waters. If the report determines that double liners and a leachate collection system would not reasonably protect State waters, or if the Discharger chooses not to install these, then the Discharger shall submit a closure plan as specified in item (ii) below. (ii) In lieu of the report required in (i) above, the Discharger may submit a closure proposal for the Class I ponds. Pond closure shall meet the definition in Section 25208.2 (d) of the Health and Safety Code and shall proceed forthwith according to the following schedule: e: TASK CC MPMION DATE A. Submit closure proposal and time schedule December 15, 1986. B. Cease accepting wastes To be specified in an amendment to this Order based on the information provided in Task A above. C. Remove or solidify all pond liquids January 1, 1989. D. Final closure of ponds To be specified in an amendment to this Order based 11 (J on the information provided in Task A above. The closure proposal shall contain the following details: .1. .A time schedule for ceasing to accept additional wastes in the ponds. This schedule shall be justified based on the timing and methods used to ccanply with item 2 below. It shall also demonstrate, or contain a separate time schedule for demonstrating, that continued acceptance of wastes for a limited time period will not increase the threat to pollute State waters. 2. A general description of methods and time schdules to remove or solidify pond liquids and time schedules for submittal of detailed removal methods. 3. Time schedules for submittal of detailed plans and for accomplishing the following: (a) Solidification and/or removal of pond sludges. (b) Removal of contaminated subsoils or closure as a landfill. (c) Installation of final cover The closure plan shall c mply with all applicable sections of Subchapter 15, Chapter 3, Title 23 of the California Administrative Code. Individual ponds may be exempted.from provisions (i) and (ii) if the Discharger proves to the satisfaction of the Executive Officer that the individual ponds are not threatening to pollute. b. The Discharger shall submit a Hydrogeologic Assessment Report for the Baker and Vine Hill facilities that meets the requirements contained in Section 25208.8 of the California Health and Safety Code by April 1, 1987. This date may be modified based on submittals for other tasks in this Order. 14. Based on Finding 6, Cleanup and Abatement Order No. 85-004 is hereby rescinded. 15. All submittals mist be made as follows: two copies to the Board, one copy to ME, one copy to EPA, and one copy to the Contra Costa County E nvirornnental Health Department. 12 Pursuant to California Water Code Sections 13304 and 13350, if the Discharger fails to comply with the provisions of this Omer, the Executive Officer may request the Attorney General to take appropriate enforcement action against the Discharger, including injunctive reflief, or the Regional Board may schedule a hearing to consider assessing civil monetary penalties and to consider requesting the Attorney General to take appropriate enforcmwnt action against the Discharger, including injunctive and civil monetary remedies. �- DATE B. J EXECUME OFFICER 13 ACME FILL �< t PROPERTY SAC NTO ... VINE�HII� p 1 BOUNDARY c=7 c r / i tr M&RT1NE2 GUN CLUB A w B C• BAKER SITE •r C v v D w ANT6 ri RAILROAD �� I may-T I I BLUM. COA D �. i . IM90I-F DRIvE _ I 1 To ANTIOCH CONCORD LEGEND 5�--. STATE OF CALIFORNIA �. .. ` PROPERTY BOUNDARY REGIONAL WATER OUALITT CONTROL BOARD BANFRANCISCOBAY REGION D. Ev&B ODEGflATIONAPORATION PAONDS OILTCERPIORRATIENTAL CORPORATION & IT LOCATION OF CLASS I DISPOSAL SITE MARTINEZ, CONTRA COSTA COUNTY ATTACHMENT A ORDER NO: 86-014 DRAWN BY, DATE, DRWG.NO.