HomeMy WebLinkAbout1985-10-02 COUNTY SANITATION DISTRICTS
•=' OF ORANGE COUNTY, CALIFORNIA
P.O. BOX 8127,FOUNTAIN VALLEY.CALIFORNIA 92728-8127
10849 ELL15,FOUNTAIN VALLEY. CALIFORNIA 92708-7018
(714) 5C 2910 (710)962-2411
September 26, 1985
NOTICE OF ADJOURNED REGULAR MEETING
DISTRICTS NOS. 1, 2, 3, 5, 6, 7, 11 & 13
OCTOBER 2, 1985 - 7: 30 P. M..
10844 Ellis Avenue
Fountain Valley, California
Pursuant to adjournment of the adjourned regular meeting of
September 25, 1985, the Boards of Directors of County Sanitation
Districts Nos. 1, 2, 3 , 5 , 6, 7, 11 and 13 of Orange County,
California will meet in an adjourned regular meeting at the above
hour and date for a presentation by the State Department of
Health Services on the Draft Interim Report: Stringfellow
Facility Remedial investigation/Feasibility Study
Secretary
BOARDS OF DIRECTORS
County Sanitation Districts rear orris. Boa 8127
of Orange County, California - 10844 Ellis Avenue
Fountain Valley, Calif., 92708
Taiaphcnn:
Mo Cade 714
-�I JOINT BOARDS 62,2411
AGENDA
ADJOURNED REGULAR MEETING
OCTOBER 2, 1985 - 7 :30 P.M.
(1) Pledge of Allegiance and invocation
(2) Roll call
(3) Appointment of Chairmen pro tem, if necessary
(4) Consideration of motion to receive and minute excerpts, if
any
(5) Presentation by the State Department of Health Services on
the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study
(6) Other business and communications, if any
(7) Consideration of motion to adjourn
10- a -8s
STRINGFELLOW FACILITY R64EUTAL INVESTIGATION/
FEASIBILITY STUDY
DRAFT INTERIIM REPORT ON
DEVELOPMENT AND SCREENING OF REMEDIAL
TECHNOLOGIES AND ALTERNATIVES
Prepared as a Working Document for:
California Department of Health Services
Toxic Substances Control Division
Sacramento , CA 95814
Prepared by:
Science Applications International Corporation
(JRB Associates)
3600 Lime St.
Riverside, California 92501
July 31, 1985
EXECUTIVE SUMMARY
Introduction
The Stringfellow Hazardous Waste Site, located in Riverside County,
California was operated as a hazardous waste disposal facility from 1956 to
1972. About 34 million gallons of liquid industrial wastes were disposed of
at the site, including spent acids, caustics, solvents, pesticides , cyanides ,
and metal compounds.
The Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) establishes a national program for responding to releases
of hazardous substances into the environment. In accordance with Section 105
of CERCLA, EPA has established procedures for determining the appropriate ex-
tent of response, and for assuring that these remedies are cost-effective.
These procedures are in the revised National Oil and Hazardous Substances Pol -
lution Contingency Plan (NCP) (47 FR 31180, July 16, 1982; 40 CFR 300) as
Subpart F (40 CFR 300.61-300.71) . Additional amendments to the NCP regula-
tions were proposed on February 12, 1985 and in anticipation of their adoption
the NCP as amended is being followed for the Stringfellow Site.
The California Department of Health Services (DHS) , with funning
through a cooperative agreement with the U.S. EPA Region IX, contrActed with
JR8/SAIC in March 1984 to comprehensively evaluate the Stringfellow Site,
perform a remedial investigation (RI ) , and conduct a feasibility study (FS) to
investigate the extent of contamination and evaluate methods for mitigating
the spread .of contaminants from the site. The RI and the FS are interdepend-
ent. The RI emphasizes data collection and site characterization while the FS
emphasizes data analysis and evaluation of alternatives.
The report presented here is NOT the FS report, nor is it the RI
report. Rather it is an interim report describing progress through July 1985,
with emphasis on the feasibility study. It is intended as a working document
xviii
to assist with public and agency participation in tre cave' ocme^: ?'
solutions to the Stringfellow site and its associated e",ronm„en:3i es .
1..J
Figure E-1 shows the steps in the FS process scn"- atical '.;. :'. S;
snows are:
o Which sections in this report correspond to specific staos
FS process .
o Which tasks in 'the contract between OHS and JR8/SA[C ccr-esocrc
to specific steps in the FS process .
o An arrow showing the place in the FS process reached at the time
of this interim report.
The FS was begun in May 1985 and the Summarization of ll :ernatives
(Task 14 in Figure E-1) is scheduled for completion in December 1985.
The RI process at the Stringfellow Site includes investigat' )r o'
site geology, hydrology, water quality and air quality. In addition , exter-
sive characterization (e.g ., sampling , analysis) is being made of containrna:ec
groundwater and soil . The field work , including drilling and pump tests , is
nearing completion. Substantial work remains to assess and evaluate tie :a:a
generated from the RI . The RI report is scheduled for completion cur'ng tce
Fa11 , 1985.
A glossary of technical terms is presented as Appendix 3.
Site Descriotion
The Stringfellow Hazardous Waste Site is located five miles northwest
of Riverside, California. The site is situated on the southern slopes of tie
Jurupa Mountains within a box canyon known as Pyrite Canyon . Approximately
one mile southwest of the site lies the community of Glen Avon. The original
disposal site covers approximately 17 acres and is located at the head of
Pyrite Canyon. A contaminated groundwater plume extends downgradient tnrougn-
V
xix
CONTRACT TASK NUMBERS FEASIBILITY STUDY PROCESS SECTIONS IN THIS .REPORT
i Characterize Problem _ nectien 3
and Identify General
Res onse Actions Section 5
ElActions
e and Deve o
ive Specific Section 6.1
ies
Screening Sections 6.2 thru 6.5
c TechnologieTASK Current ---- - - -- -
11/12 statuse Broadive Remedial Section 7
Discusses Approach
Envirarmental and
Public Health Screening
Cost Screening
Identify Remaining
Alternative Remedial
Actions
TASK Treatability
13 Studies
Detailed Evaluation
f Public
Technical Institutional Cost Environmental
Analysis Analysis Analysis Health Analysis
Analysis
Summary Of
fl Alternatives
1; Conceptual Design
TASK Final Feasibility
16 Report
FIGURE E-1. Schematic Diagram of Feasibility Study Process and its Relationship
to Thistnterim Report, and the Project Contract Task Numbers.
xx
• - a
out 2yrite Canyon with contaminant content.-a-ions tecreasirg w' t'
distance from the original disposal site. a plume of contaminatec ,z__. `✓
been located which extends southerly into Glen Avon , and ihrea:ers .
water welts .
During 1981-1982 interim construction was done at the ordinal ;
to reduce pollutant migration , including removal of surface waste , erts' :.r
control , capping , and barrier wall construction . In adcition , artam'rat?c
groundwater has been routinely extracted downgradient of the site fro* to
present. 4s an interim measure a mid-canyon treatment plant for trea:aen: ;
the extracted groundwater is nearing ccmpletion (July 1985) . ?re: ininar.
analysis indicates that these interim steps have reduced , but not el iminatao ,
the migration of pollutants downgradient from the site.
Characterization of Site Environmental Imoacts
The Remedial Investigation (RI ) now in progress will charac'eri :a ire
health and environmental problems associated with the Stringfellow Site , •�_
cluding the canyon and community areas downgradient of the originai sire . -,e
RI field activities are scheduled for completion in August, 1985. Some :ri "-
ing of bedrock wells remains and additional drilling is planned in toe :o^r..❑r_
ity area to further define the contaminant plume.
Interpretation of RI data and analysis of samples is incomplete . It
the present time , however, the available data permits the following loser'/a-
tions concerning the Stringfellow Site:
o Three major lithologic units comprise the geology of oyrita
Canyon: fractured and jointed bedrock of igneous an,, metamorpnic
origin underlies the entire canyon ; a zone of decomposed granite
overlies the bedrock ; and a zone of alluvial deposits overlies
the decomposed granite.
o The thickness of the alluvium and the decomposed granite layers
increase and the elevation of the bedrock surface decreases ih
the southwest direction from the on-site area to the community
id
xxi
�.O area. Alluvial deposits thicken from the canyon margins towards
the canyon floor.
o The general groundwater movement in the Pyrita Canyon Is in the
southwest direction from the on-site area towards the Glen Avon
community area, paralleling the general flow direction of 7yrite
Creek/Channel .
o Preliminary evidence of an old subsurface channel in the bedrock
has been found on the eastern side of the site proper. Ground-
water flow may be affected by the presence of this "channel" .
Furthermore, groundwater flow is probably controlled locally •-y
fractures and joints in the bedrock.
o In general , groundwater is heavily contaminated in the on-site
area and contaminant levels decrease in the dawn-gradient direc-
tion. The contaminants include metals, sulfates, nitrates,
fluoride, chloride, .and a variety of organics, including TCE,
chlorobenzene, chloroform, dichlorobenzene, and phenol . These
contaminants are consistant with the types of wastes disposed at
Stringfellow. An organic material of unknown toxicity (not a
"priority pollutant") , para-chlorobenzenesulfonic acid, is a
dominant, component of the on-site wastes, possibly comprising as
much as 50% of the total organic matter. Although elevated
radiation levels are found in on-s!te groundwater/leachate,
`�►' radiochemical speciation analyses have indicated no relationship
between Stringfellow wastes and detections of gross alpha radio-
activity at just above drinking water standards in some private
community wells.
o Contaminated groundwater seems to be following a relatively
narrow zone in the mid-canyon, lower canyon and community
areas. This premise is supported by the results of soil-gas
sampling and well drilling in the lower canyon and community
areas. However, present data are insufficient to completely
characterize the geometric configuration of the contaminant plume
within and downgradient from Pyrite Canyon, especially in the
area below Hwy 60 where the canyon begins opening into the Glen
Avon basin.
d Because of the potential control of groundwater movement by major
fracture zones, the apparent narrow zone of contamination may
represent only one part of the contamination plume. The possi-
bility exists of other contamination pl,imes in pyrite Canyon.
Installation and monitoring of wells is on-going and should
reveal other contamination plumes if they occur.
o Groundwater from some of the community area monitoring wells is
contaminated with organics, (TCE, chlorobenzene, and chloroform)
at parts per billion ( ug/1 ) concentration levels.
xxii
0 Organic contaminants appear :a :e travel '.nc f-rarer : .. , _ --
than metals. The concentrat'.ons of metal :end tz __- -_--
rapidly with distance from t`e site , ?res..ma^.1 :+:a."
metals begin adhering to soils as toe oa ( acidirr -. .--
neutral away from the site. l*wever , in the facer ,;an ,c- :rya
immediately south of the site, groundwater ccncen:rit4ors - . .
metals have been found at higher levels :han on sire.
0 Based on groundwater elevation information <rown Lrr- ,cr .:re
1985 , the original site is located in an area .mere re
movement of groundwater tends to be uowaMs , not :own.
firmed by final drilling and aquifer studies , the feas4-z" .
specific containment and groundwater recovery tacnnoidgiss
be affected .
o Just below Hoy 60, where contaminants have been fount in :re
alluvial (upper) aquifer but not in deeper OG and bedroc< -
fers, there appears to be an upward water oressure, :ossi07y
great enough to be retarding the migration of contaminants -awn-
ward . The possibility that contaminants are being lar?el , <20t
in the upper groundwater layers is currently 0e'.ng
gated . 1f this is the case, it will presumaoly aid an., ;r-•.nc-
water clean-up efforts.
Environmental Standards and Guidelines
v
Section 4 of this report provides an overview of local , sta:a , ar.!:
federal regulatory requirements and guidelines. Regulatory programs :rcer :-e
Resource Conservation and Recovery Act (RCRA) are most relevant to ryny•a:
action alternatives. All pertinent regulations standards , and guidelines a+tl
be reviewed , since they may significantly affect the design, ooera:ion arc
timing of proposed alternatives.
General Resoonse Actions to Site and Environmental problems
Section 5 of this report provides the identification of or-ad zeneril
response actions to environmental problems without necessarily identi -.14rc :..e
detailed technologies involved in the response action, as required oy :ne =S
process.
xxiii
Treatment actions include treatment processes wnicn ( i ; cetoxify
�.✓
(vendor harmless) contaminants, or (2) 5e perate the hazardous contaminant tram
the media which provides the route of exposure (e.g. remove the contaminant
from water and place it onto activated carbon) . Processes used include de-
gradation, destruction, .detoxification, immobilization, conversion and sepera-
tion.
Removal and disposal actions include removal and transport to an off-
site location or removal and redisposal on-site following treatment. The
hazardous substances removed may include wastes, contaminated .soil , contami-
nated groundwater, and/or contaminated residuals (e.g. sludge , ash) from
treatment processes. Disposal actions include various kinds of land disposal ,
reuse technologies, and disposal to a Publically Owned Treatment Works (POTW)
collection system. A major factor in the feasibility of disposal/redisposal
actions are the regulations/ standards discussed in Section a.
Containment actions generally fall into four types. The first is
based on hydrologic principles and uses wells and pumping to control the
outward flow from , or the potential contact of groundwater with a source of
contamination. The second involves physical barriers such as grout curtains
or slurry walls, which are installed in such a way as to prevent groundwater
from moving into or out of the contaminated mass of soil or the aquifer. The
third group includes conventional interception and drainage systems. The
fourth type of containment system isolates the wastes in containers or highly
impermeable matrices. These four groups of technologies are often utilized in
combination with one another to increase the effectiveness of overall contain-
ment.
Technology Screening
About two-thirds of the volume of this report is Section 6 which
covers technical screening of 86 technologies. Each technology is described ,
and then categorized as applicable, of uncertain applicability, or not appli-
xxiv
• A
cable at the Stringfellow Site . The res.,lts of the sc-eenii; are :r::' :i: .-
'ante c-I On the following pages. 'dhere a tethnplOdy 4s tonsice^ec
cable, areas of possible application - upgradient, on-site ana :owng-ac•ar:are indicatea . Where a technology has been eliminates tre reasomis P. are
indicated in the table. Incompatibility with the wastes , and/or leac'ate , +as
a principle factor in eliminating many technologies .
Me uncertain status of 22 technologies will oe resoliec :Don ::r:ie-
tion of the RI and/or treatability studies. planned treataoilit: st:d 'es
include laboratory and pilot scale studies of biological treatment, so,'.
washing, air stripping, carbon adsorption , bioreclamation , and incineration .
Oevelooment of Remedial Alternatives
At the writing of this draft status report (July i985 ` , is is pre-
mature to describe many of the possible remedial alternatives oecause n•:cn I'
the remedial investigation data and interpretation are not yet available. "-e
primary purpose of this section is to describe the process oeiwg :sad it tre V
development of remedial alternatives, not the remedial alternatives :hen-
selves. if successful , this document will provide a constructive star:C
point for including the public , the involved agencies an tec.inical investiga-
tions into the ultimate development of a successful remedial approach 'o-
Stringfellow.
A three step process for developing remedial alternatives is orese^t-
ed in Section 7.
0 Step One defines the Options available in very oroad terms.
'dater entering the drainage basin containing the StringfW at,
Site is followed . Initially the water is uncontaminated . As the
water then flows downgradient, various options present them-
selves. Some of the water percolates to become groundwater ana
some remains surface water. Options exist to direct groundwater
and surface water away from contact with the existing on-site
contaminated waste/soil mixture. 'dater which does contact con-
taminated waste/soil becomes contaminated and there are broaa
xxv
vtiJ C h~ Q y4 tiJ m v
TECHNOLOGY
NASTE AND CONTAMIUATED SOIL CONTROL
Removal and On-Site Disposal A • •
Removal and Off-Site Disposal A • •
Thermal Destruction
Rotary Kiln Incineration U •
Liquid Injection Incineration U •
x Pyrolysis x •
X Fluidized Bed Incineration X • _
Multiple Hearth Incineration X
Solidification/Stabilization/Fixation
Cement-based U •
Pozzolanics U j
Thermoplastic X • •
Organic Polymer X li— j •
Solidification Materials X • •
Surface Encapsulation X • • _
Vitrification X •
Other Treatments for fit Situ and
Excavated Soils
Uater/Solvent Flushing U • •
U iological Drgrddation U — -- -i —i— -- -- --
Neutral eat inn U • — -- --
Sulfide Precipitation _ X — �-- -- --
IlyducIinn X —•— _� — —
O.iddtlntl X • •
Potymrrital inn X— E — — —;— ..6—
See footnote on page xxix
TABLE E-l. Summary of Technology Screening.
W Qom• tit hW :;
4'`•hH � yti 2 Qcr� J � N
h
TECIIIIOLOGY Qy j a •.`�, tir / y '�� y
GROUNDWATER PROTECTION
Capping
Clay A _• _
Synthetic Membranes A •
Soil Cement/Clay Mixtures A • __ _
Muttilayered Systems A
Concrete % •
Fly Ash Mixture % _0_
X Asphalt X —• — — __-
Containment barriers
Soil-Dentonite Slurry Watts A _ _ • __ _ ___ _•_ _ _ ____ ___
Grout Curtains A _• •
Clay Liners A a a- — — _—
Synthetic Liners A _-•— _• —• — — --
Mutlilayered, Lhwrs A • • • --
Cement/Dentonite Slurry Walls _ % _
Diaphragm Walls % .__•-_ —_ -_. __
Vibrating Beam Slurry Walls % - - .. - - - - - - •
Steel Sheet Pit ilxJ x...._. _._ . ._! _ _ _ a ..
Grout Ilollom Scaling _ $.__ _ ._ _ . • •
Ciroundualer Diver.iun and Collection
Extraction M•11, A • • •
Snbsur 1.1c" Urn III!, A • • •
IIUCCI nm/1 rl r.0 1 i'n, (Re'llargr)
Ilydrolr i.�„r „y Il _ • _
11.1 14.til )
1`'ll 1 - ! . (1••I� i:al.,I '.ee(101.001.e on pe!p: xx ■
h �
V
rw h 1
TECHNOLOGY
SURFACE WATER PROTECTION
Grading A • • •
Revegetation A • • •
Run-On Control A • •
Erosion and Run-Off Control A • •
AIR POLLUTION PREVEI1T10N
x
x Dust Controt
Polymer Sprays A •
Water Sprays A •
Gravel. Cover A •
Revegetation A •
Windbreaks U 0 _
Windscreens % •
Vapor Control
Capping A • _ _ __
Waste Removal A • • __ _
Collection and Treatment U_ • • _ __
Chemical Stabitization of Haste % • _ ..
TABLE E-1. Continued
h /
h
Q�m` �W W �V hmhlu ` ti
J 44 yti O~ 4�� hJ ti� v
y hQ 40 1 � �� hca• Q y
TECIIIIOLO.Y
o �
LEACIUTE AND CONTAMINATED WATER CONTROL
Physical Treatment
Flow Equalization A • • _ __
Flocculation A • •
Sedimentation A • • _
Activated Carbon A 1 1
Filtration A 6 _
Air Stripping A
Ion Exchange U • _
Reverse Osmosis U • _ _ _ _
. X Steam Distillation U _
Oil/Water Separator x _
x Steam Stripping x
Dissolved Air Flotation x • _ _ __
Chemical Treatment
Precipitation A __ • •_ __ __ _
Neutralization A 6 •
Oxidation U —�- -- -- - -
Reductlun
Ultraviolet/Ozone ._ IL__
Diolollical Treatment
PACT 11 • •
Activated Sludge
TricLlinq Filtera 11 _ ._... -,_�.__ — • — _ _ _.
RuldliluJ 111ul uq iLJl fnlll df lul's .__ W_.__... ._.—_ ._•__ _ It-__
API'.11�n1 1 .11b1111 N. .._ A... _____ -- .. • •
TABLE L- I . Continued. See loolnole oil ledge xx x
v
Q` ti yW O by y 1
TECHNOLOGY y W y
LEACIIATE AND CONTAMINATED HATER CONTROL
Disposal (with pretreatment as necessary)
Discharge to publically—owned treatment
Works (POTN) A • • _
Discharge to Surface Waters A • • _
Off—Site Reinjection _
Disposal to Class I or Class II-1
Disposal Site A • •
x Solar Evaporation A • _ _
x Reuse Off—Site as Industrial or
AgricuLtural Water u •
Reuse On—Site for Process
Purposes U • •
FOOTNOTES
1. A = Applicable to Stringfellow at one or more of the 3. Status of, and acceptance of the technology. If the
down9rdient areas-those which passed the screening technology is experimental and has too many unknowns
process Wsed on existing information and data. for near-future large scale applications, then it
t = Not applicable to Stringfellow-those which were was generally rejected.
screened out and eliminated from further consideration. A. Reliability of technology due to inherent construction,
U w Uncertain applicability to Stringfellow-Wore for operation, and/or lainteance prublons.
which existing data are insufficient and tine screening h. Availability in a size scale necessary for We
Process caves[ Ga completed. Stringfellow Site.
2. Incompatibility with waste characteristics, leachate
chdracteristics, site conditions, or other uncon'ectahle
factors at the Stringfellow Site. for examplu, the low fill
and/or concentration of arganies of the Stringfellow waste
Pile is incompatible with the luny-lcly iutegr lty of many
construction materials used In SnbSmrmare wdl1S, CUrl4111S,
or other barriers. Incenymdtibility with sulnurfwre
conditions At the site. for endmpla, mQlllanindted gruwnd- TABLE E-l. Continued.
water may be Lou deep fol use of well paint e.trdclion
methoas.
x R y
options for managing contaminates water. :n adr'.i•-r , _ :
broad options for dealing with the contaminated so`- was:e - _ v
excavate, leave in place, Lreat, etc .' . This eteo or�v- :gs
framework for looking at the broad options avaiiaoie.
o Step Two in the development of remedial alternatives relates t^e
options identified in Step One above to the specific recnnol7c'es
which were selected as applicable, or uncertain , for the Strinc-
fellow Site ( see previous Table E-1) . rcacn broad opt.or ` s
associated with technologies which mignt be applicable .o tre
option.
o Step Three will be the actual development of remedial alterna-
tives; i .e., the compiling of suitable technologies into feasiole
systems to manage and control the source waste material anc
migrating contaminant plume at the Stringfellow Site. -here are
many possible remedial alternatives when one includes each tech-
nology variation of treatment , disposal , etc. For illustration
purposes only, the report describes several remedial alternatives
developed through June 1985 so the reader better unaerstands tie
next phases of the Feasibility Study which will occur during Ju)y
and August.
A public workshop is tentatively planned for August 21st to sisc.ss
remedial alternative development and selection. Interested parties will `.✓
receive formal notice of this meeting.
v
xxxi
Y
REPORT OF THE JOINT CHAIRMAN
OCTOBER 2, 1985
AT THE AUGUST JOINT BOARD MEETING, COPIES OF THE DRAFT
INTERIM REPORT ON THE STRINGFELLOW REMEDIAL
INVESTIGATION/FEASIBILITY STUDY, RECENTLY ISSUED BY THE STATE
DEPARTMENT OF HEALTH SERVICES, WAS DISTRIBUTED TO THE
DIRECTORS. COPIES OF THE EXECUTIVE SUMMARY HAVE ALSO BEEN
PLACED IN YOUR MEETING FOLDERS TONIGHT.
AS YOU KNOW, WE REQUESTED THAT THE STATE GIVE A SEPARATE
BRIEFING TO THE BOARDS. THE STATE AND EPA HAVE KINDLY AGREED
TO A PRESENTATION AND WE ARE PLEASED TO HAVE MR. STAN PHILLIPE,
A PROJECT MANAGER FOR THE DOHS Toxics SUBSTANCES CONTROL
DIVISION, AND MR. KEITH TAKATA, CHIEF OF THE SUPERFUND PROGRAM
BRANCH FROM EPA REGION No. 9 WITH US THIS EVENING.
WE CERTAINLY APPRECIATE YOU COMING TO DISCUSS THIS PROGRAM
WITH THE DIRECTORS. AS YOU KNOW WE PLAY AN IMPORTANT ROLE IN
THE SUCCESS OF THE STRINGFELLOW PROJECT. OUR DISTRICTS STAND
READY TO FULFILL THEIR RESPONSIBILITIES TO PROTECT WATER
QUALITY AND PLAY AN APPROPRIATE ROLE HELPING OTHERS TO DO SO.
TO ACHIEVE THESE OBJECTIVES, I CANNOT OVEREMPHASIZE THE
IMPORTANCE OF OPEN AND ONGOING COMMUNICATION BETWEEN OUR
RESPECTIVE AGENCIES. IN ORDER TO ATTAIN OUR COMMON
ENVIRONMENTAL GOALS, WE MUST HAVE ALL RELEVANT INFORMATION SO
THAT THE DECISION-MAKERS CAN ADEQUATELY EVALUATE THE
ALTERNATIVES AND ARRIVE AT THE BEST OVERALL SOLUTION.
-1-
OUR COOPERATIVE EFFORTS TO PROTECT THE SANTA ANA RIVER
BASIN UNDERGROUND FRESH WATER SUPPLIES HAVE CERTAINLY BEEN
�.: DEMONSTRATED OVER THE YEARS.
(DON--YOU MAY WANT TO COMMENT FURTHER ON THIS OR RELATE
YOUR OBSERVATIONS FROM THE FOUNTAIN VALLEY WORKSHOP. )
AT THIS POINT I WOULD LIKE TO TURN THE PROGRAM OVER TO THE
DEPARTMENT OF HEALTH SERVICES AND EPA REPRESENTATIVES. THEY
WILL INTRODUCE THEIR ASSOCIATES. FOLLOWING THE PRESENTATIONS,
IT WOULD BE APPROPRIATE FOR THE DIRECTORS TO COMMENT OR ASK
QUESTIONS.
-2-
„ OUNTY SANITATION DISTRICTS
OF ORANGE COUNTY, CALIFORNIA
8.e / P.O. BOX 8127, FOUNTAIN VALLEY, CALIFORNIA 92728-8127
10844 ELLIS, FOUNTAIN VALLEY. CALIFORNIA 92706-7018
(714) 540-291D (714) 962-2411
August 20, 1985
Mr. Richard Wilcoxon
Chief of Toxics Substances
Control Division
State Department of Health Services
714 P Street
Sacramento, CA 95814
Dear Mr. Wilcoxon:
Last March, the Boards of Directors of the County Sanitation Districts of Orange
County authorized the Santa Ana Watershed Project Authority to issue a permit to
the Department of Health Services (DOHS) to discharge pretreated groundwater
extracted from the Stringfellow Waste Disposal Site into the Santa Ana River
Interceptor System for conveyance to the Districts' Joint Works for further
treatment and eventual disposal . This authorization is for an interim period
pending completion of a study and evaluation of long-term alternatives. It is
also subject to conditions established by the Boards and strict compliance with
the discharge standards of the Districts and other applicable state and federal
requirements. The Districts' Directors approved this interim plan in a sincere
spirit of cooperation to assist Upper Santa Ana River Basin officials and
regulatory authorities in resolving what is considered to be a serious threat to
the underground fresh water supplies.
It has now been brought to our attention that DOHS has issued a "Stringfellow
Facility Remedial Investigation/Feasibility Study--Draft Interim Report on
Development and Screening of Remedial Technologies and Alternatives” and has
scheduled public briefings and workshops in Glen Avon and Fountain Valley, and
for County of Orange officials.
As you recall, permission for the interim measure to allow DOHS to discharge
pretreated wastewater into the Districts' sewerage system was granted after
considerable public debate and controversy. Given the intimate involvement of
the Sanitation Districts in the temporary Stringfellow solution and the fact
that discharge to the Districts' system is one of the long-term alternatives
being evaluated, we are concerned that your office has not seen fit to give a
briefing to the Sanitation Districts Board members and staff. The Districts
Boards, comprised of thirty-two elected officials (mayors and councilmembers of
twenty-three cities, Directors of three sanitary districts and members of the
County Board of Supervisors) have the ultimate and final decision-making
responsiblity on any alternative that affects the County Sanitation Districts or
proposes to utilize their system. There is no absolute right for the discharge
of Stringfellow wastes into the Districts' sewerage system nor is their any
implied obligation for the Districts to accept it. The decision rests solely in
the discretion of the Districts' Boards of Directors.
Mr. Richard Nilcoxon
August 21, 1985
Page 2
Our Districts stand ready to fulfill their responsibilities to protect water
quality and play an appropriate role helping others to do so. To achieve these
objectives, I cannot overemphasize the importance of open and ongoing
communication between our respective agencies. In order to attain our common
environmental goals, we must have all relevant information so that the
decision-makers can adequately evaluate the alternatives and arrive at the best
overall solution. I would, therefore, respectfully request that your office
present a briefing on the status of the Stringfellow studies and investigations
for the Districts' Board members and staff, and that you contact me at your
earliest convenience in order that we may arrange a mutually convenient date and
time.
Sincerely,
jrY , uV
Don R. Griffin
Joint Chairman
DRG:aa
cc: Board Members
V
MEETING DATE October 2. 1985 TIME 7:30 a.m. DISTRICTS 1.2.3.5.6.7. 11 6 13
DISTRICT 1 JOINT BOARDS
(CRANK)....... .HANSON... ... ✓ (THOMAS/MANDIC)..BAILEY... ..._
(SALTARELLI). . .HOESTEREY... (WISHER)...... ...BEVERAGE....
(LUXEMBOURGER).GRISET... ... _ _ (ZIEGLER)........SUCK. .... ...
(WIEDER).......STANTON.. . ..� (NORSY). . ...... ..CATLIN... . ..
V (NELSON)..... . ...COOPER. . ....
DISTRICT 2 (PERRY)....... ...CULVER.. . . ..
(SALTARELLI).. ...EDGAR.... ...�
(NORBY)..... ...CATLIN...... _ _ (JARRELL)...... ..GRI%FIN.. . ..
(ZIEGLER)......SUCK........i!iE� (LUXEMSOUROEA)...GRISET... . ..�
(NELSON). ......COOPER......JG _ (CRANK)...... ....HANSON.. ... .
(LUXEMSOURGER).GRISET....... (COX)........ ....HART.... ....
(SILZEL).......KAWANAMI.... _ _ (SALTARELLI).....HOESTEREY..._
(WEDELI........MAHONEY..... (SILZEL)...... ...KAWANAMI....—
(SCOTT)........NEAL........ (WEDEL)..........MAHONEY.. ...
(CULVER).......PERRY....... (COX)........ ....MAURER. . ....�
(OVERHOLT).....ROTH........ 4� (SCOTT)...... ....NEAL.... ....
(BEYER)........SMITM...... . (COOPER)..... . ...NELSON. . . ...
(WIEDER).......STANTON..... (FINLAYSON).. ....OLSON.. . . ...�
(BEVERAGE).....WISNER...... (KANEL)..........PARTIN.. . . ..
(CULVER).........PERRY.......
DISTRICT 3 (COX)............PLUMMER.....
(COLLINS)........POLIS... . ...
(OVERHOLT).....ROTH.. .......J e (BROWNELL).... ...RISNER......�
(COOPER).......NELSON...... (OVERHOLT).......ROTH........
(THOMAS).......BAiti!M...... � (SIRIANI).... ....SAPIEN.. ....�
(NORBY)....... .CATLIN......�_ _ (BAKER)...... ....MILLER... ...
(PERRY)........CULVER......J�� _ (BEYER)..........SMITH.......
(JARRELL)..... .GRIFFIN.....,y� _ (WIEDER)...... ...STANTON.. ...�
(LUXEMBOURGER).GRISET..... . (SELVAGG1).... ...SYLVIA... . ..
(WEDEL)........MAHONEY..... (FINLEY).........THOMAS... ...
(SCOTT)........NEAL. .......}C_ (GALLACHER/GREEN)WAHNER......_
(FINLAYSOl (BEVERAGE).......WISNER......
(KANEL)........PARTIN....... _
(COLLINS)......POLIS ...
(BROWNELLI.....RISNER......�
(SIRIANI)......SAPIEN......
(WIEDER).......STANTON.....
(SELVAGGI).....SYLVIA.......Ape_
STAFF:
DISTRICT 5 SYLVESTER...JC
CLARKE. .....JC
(COX)..........HART........ � � "p, DAWES.. .....J.0
(Cox)..........MAURER...... \7Da'',��.� ANDERSON...._ C
(WIEDER).......STANTON..... / 0 BUTLER.... . ..b^
BROWN...... .,{
DISTRICT 6 BAKER
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KYLE....... .JC
(GALLACHER)....WAMNER....... _ _ \ YOUNG.. ....._
(COX)..........PLUMMER.....�_ / VON LANGEN JL
(WIEDER).......STANTON..... / WINSOR. .....
STREED......
DISTRICT 7 CLAWSON. ..
(SALTARELLI)...EDGAR..... ..
( X .. E ...... -_ � OTER : WOODRUFF
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MAURER......
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(BAKER). .... MILLER...... , HO . ....
(BEYER)... . .SMITH....... LL✓ HOWARD......
(WIEDER). .. STANTONSTANTON......ZUJ HUNT........_
(GREEN)........WAHNER......� KE ITH......._
KNOPF.......
DISTRICT 11 LE BLANC....—
LINDSTROM...—
(MANDIC).......BAILEY...... a LYNCH... ...._
(WIEDER).......STANTON..... MARTINSON..._
(FINLEY).......THOMAS......� E.ARCE.. .. . .
DISTRICT 13 ► 1 "
(NELSON).... . ..COOPER... ...✓ tdci/Iw.'L
(WISNER).......BEVERAGE
.. ... ...
.
(BEYER)....... .SMITROTHH
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(NIEDER). ......S7ANTON..... Md
10/02/85
DRAFT
Thank you. Appreciate the opportunity to be here and explain what we're
doing at the Stringfellow site. It think what we'll probably try toedo here is
try to paint a picture of what's going on at Stringfellow, briefly what's gone
in the past and where we're headed in the Superfund program that we and EPA are
carrying at the site. What we want to discuss is the July, 1985 Draft Interim
Report on the Development and Screening of Remedial Technologies and
Alternatives for the Stringfellow site. We can explain a little bit about the
remedial investigation, the feasibility study. We are about 80% through the
remedial investigation at Stringfellow. We are .about 1/3 of the way or so into
the feasibility study. We can tell you what some of the highlights of the Draft
Interim Report. We are not here to present to you a recommended solution. We
are not at the stage in the Stringfellow process where we have narrowed it down
to one alternative or one recommended alternative, or even three recomended
alteratives. We are a ways from that and we can of course respond to any
questions that you have. So briefly just to start off with:
The Stringfellow site is located near the town of Glen Avon in Riverside
County. It's just north of Highway 60, about a mile at Pierite Street in Glen
Avon. It operated from 1956 until 1972. It received about 34 million gallons
of miscellanous industrial waste, mostly solutions, acids, metals,
solvents, pesticides, and the like. The site itself is about 17 acres. There
were approximately 4.2 acres of of ponds on the site, about 20 ponds and we have
some slides we will show. If we can dim the lights we will probably go into
that now. About 200 plus generators disposed of waste at the site. Most of
-1-
those were from the Los Angeles and Orange County area during the period of '56
to '72. The site overflowed due to heavy rains in 1969 and 1978 and a program
" was done after that to try and remedy the problem. This slide shows the Pirite
Canyon in 1953 before the site was developed. I don't have a light pen or a
pointer here. You can use my crutches. You can see the area where the creek is
coming down from the upper end of the canyon here, heading south and I guess
highway 60 would be done here somewhere. Just shortly after the site opened in
1955 you can see Mr. Stringfellow had developed some roads into the area and
around the site and has a couple of ponds going. A couple of years later more
ponds and the site is starting to take the shape that we have come to know and
love now.
Here is a site at about full size, filled out. It was constructed with a
barrier dam, a concrete dam in this general area running from what was thought
to be bed rock to bed rock. It was more like boulder to boulder and it didn't
exactly contain any subservice migration.
I mentioned that a program was undertaken after the overflow period in 1978
to try to stop the problem from Stringfellow. This was before Superfund. There
was limited funding but the State Water Resources Control Board, the Regional
Water Quality Control Board and Federal Government, EPA and others were involved
and funding and interim abatement project and this was what was done in the
interim abatement project. I will run through that real briefly here and tell
you what kind of features were built into the site. The onsite surface liquids
from all the ponds were more or less removed. DDT residues in the northwest
corner of the site were removed. There was partial PH neutralization by
-2
blending in lime kill dust to the material in the subsurfaces as much as they
could do. It is estimated that somewhere like 1/3 to 2/3's of the site might be
PH neutralized. Parameter gunite channels were installed around the edges of
the site to capture surface water that was otherwise running around and into the
area. On the concrete gutters and gravel drains were installed on the surface
of the site. These drains drained to the gunite channels and are routed out of
the site. The site was graded and capped. The capping was a foot of kill dust
on top of the waste material followed by a foot of clay, followed by a foot of
native top soil. Down-gradient in this area where the old concrete dam was,
that was excavated and a clay core barrier dam was installed in this area.
Below the clay core barrier dam silicone jell was injected into the fractured
bed rock. They were also sort of paralleling these surface drainage features,
subsurface french drains which lead to extraction wells on the site to promote
the extraction of the lead shape that is formed into the site because there is
still water running in from the hills. It is too bad you really don't get a
out all the water they have all winter long and it comes down near the
subsurface and into the sides of the site and up from the bottom. So the
drainage system and these extraction systems pull this groundwater out. The
groundwater is less contaminated up here than it is down here and the worst of
the contamination as you might expect is at the lower end which is probably at
the most residence time of the waste material. About 14 monitoring wells were
installed, some in this area and others far down the canyon and up near highway
60. There were three downgrading interceptor wells installed. One was in this
area and two more, I'm not sure how far on this photo, but somewhere down
approximately at the mid-canyon area, two more interceptor wells, also for
-3-
capturing the flow. And, I might add, that the program at that time called for
off-site disposal of the water that was extracted from the on-site wells, three
on-site wells, and the three interceptor wells, and it also recommended a
pretreatment factor. Subsequent to that, this is the site, more or less as it
is today, looking from the top of the canyon in the north end out down the
canyon towards the south and into the community of Glen Avon.
Subsequent to this program which was completed in about 1982, the
Department of Health Services and EPA began the lead responsibility for the
site. We were handed the keys and the Department was in November of 1982 and
the Superfund process began. The Superfund process, just briefly, is that sites
are ranked for inclusion on the national priority list. If they are on the list
and if they are priority sites for funding, then EPA makes funding available
either directly through EPA and EPA's contractors, or through the states and the
site process of remedial action begins, starting remedial investigation to
characterize the nature of the problem, feasibility study, followed by design of
the selected alternative that comes out of the feasibility study, then
implementation of that designed clean-up action and in some cases, and certainly
in the case of Stringfellow, there will be a period of operation and maintenance
of that remedy for sometime. That's the process we are going through now. We
have been operating the interim abatement program, which means extracting
groundwater and maintaining the facility since November of 1982. We have hired
a consulting firm from the San Diego area, Science Applications, Inc. or SAIC
is conducting the remedial investigation feasibility study. We have constructed
the iterim pretreatment plant, which I am sure you are aware, it is about 3+
million dollar advance wastewater treatment plant. We have done monitoring of
-4
the Chino basin, including the Stringfellow canyon and out into the community of
I
Glen Avon and in surrounding area. We've carried out a community relations
program. We have an advisory committee which has Orange County representation
and we fund an information center near Stringfellow. We have also done sampling
for radiation and we supplied bottled water to about 400 residences in the Glen
Avon area because of the concern about the radiation. So how does this interim
report fit into this couple hundred page document?
Well I have an overlay now, Robbie, if you could set that up now I will
talk about the interim report. What this does is that the process is to
identify all applicable or possible alternatives and technologies that might
play a role in the solution of the Stringfellow problem and these are pretty
well defined in literature and in EPA guidance as to what the world of
alternaties that we might look at is, and the process becomes one of screening
out alternatives. You can see on this overlay that that comes in this area,
developed the technologies and screened them down to those that are applicable
to the Stringfellow site. That's the bulk of this report. About two thirds of
this report is a listing and discussion of alternatives and an evaluation of
their applicability or non-applicability to Stringfellow, and some of them are
listed as uncertain applicability requiring additional studying. The other
thing that this report does is that it lays out the process for developing and
screening these alternatives. So you can see that we are not at the point yet
of putting out a final feasibility study, we are in this area, task eleven and
twelve, the public meetings that were held in August in Orange County and
Riverside were to first make the public in both areas aware of the screening
process and the process of developing solutions to the site. We've now gone
-5-
into further evaluation and screening of that and we are expecting the next
thing that will be out for public review will be the task eleven and twelve
report which will bring us up to this point of evaluation the alternatives. We
are also doing some treatability studies--that's another story.
So the next steps are, as I said, further analysis, cost analysis included,
recommend several alternatives, public review at that time, select and final
alternative, design it, implement it and operate it. We have some other
findings of overlays that show what some of the findings and problems of the
site. What this is is a site map. You can see a shaded area here, lightly
shaded area, which depicts the approximate location of the groundwater and the
site itself up here. These extraction wells are currently piped to storage
tanks in this area and we also have these two interceptor wells at the
mid-cayon, in fact there are more interceptor now that are extracting
groundwater from the mid-canyon area and we're transporting that water to--well
that's a good question--to the Casmalia site in Santa Barbara county. The plan
of the pretreatment plant is to take this water and instead of bottling it 200
miles to Casmalia, pretreating it to meet the discharge limits into a publicly
owned treatment works during the interim period while we're developing the
solution to the Stringfellow problem and by treating it make it suitable for
discharge into a publicly owned system. The pumping rates. We have mid-canyon
well pumping rates, 115,000 gallons per day approximately. The on-site wells in
this area, pumping rates of 72,000 gallons a day. The concentrations, for
example, RE trichlorithene is the most notable organic contaminant, the solvant
that is travelling the farthest and fastest and at the highest concentrations.
On-site the concentrations are 7 1/2 milligrams per liter. By the time you get
-6-
down to mid-canyon area the concentration is one and a quarter milligrams per
liter of parts per million. The amount of TCE that is produced at this pumping
rate, and these are maximum design pumping rates by the way. Currently we are
not pumping anywhere near that because we have had such a dry period in the last
year and a half. The TCE production rates, for example from the groundwater
system are 4 1/2 pounds per day or about 1/2 gallon of TCE along the 72,000
gallons of water. As I said, that's the highest concentration of solvant
contaminant in the Stringfellow groundwater. What I want to explain, I hope you
come away with, is a picture that we are not proposing to pump out the liquid
that you saw in those old slides from 1965 and run it directly to the sewers,
obviously. We are pumping contaminated groundwater that has these kinds of
concentrations and in this area down in here even less concentrations. A
combined pumping rate of 187,000 gallons per day going into the treatment plant,
about a little over 1/2 gallon of TCE going into the treatment plant, total
organic carbon removal efficiencies about 97 112 percent and the effluent would
have .015 gallons per day of TCE and about 187,000 gallons of water from this
treatment plant. That's what is being proposed and that is what the treatment
plant has been designed for.
The status of the treatment plant is a long-term part of the Stringfellow
clean-up plan. We haven't reached a point where we have identified the ultimate
i
clean-up plan but because of the economics of treating and disposing of the
contaminated groundwater in this manner, it's at least likely that some form of
pretreatment and discharge from a treatment plant, rather than directly
following the waste to a Class I landfill is in the cards. It's not decided
upon, but it's likely. What happens if we don't is that this plume continues to
i
-7
migrate. The next overlay shows somewhat of how far this pluming has gone out
into the community, new monitor wells that have been installed in the last 6 or
8 months. Here we are at the freeway and the sites back-up here and we have a
very narrow plume. Undetected over here at this monitor well, all of these are
monitor wells, undetected over here this is about a city block wide or less. In
fact, it is less, a couple hundred feet. Low concentrations of trichlorithene
here, 375 parts per billion here. By the time you get down here how far are we
here, about a quarter of a mile, ok. And then another quarter down to the
school and concentrations are in this range and we have monitor wells now that
go a little farther and we have concentrations 500 feet or so south and another
450 feet to the west. We have concentrations of trichlorithene about 50 or 40
down at the bottom of the picture.
IAnd, as I said the reason for controlling this is obvious. These levels,
although they are relatively low in terms of the concentration in the community,
they are above the action level for drinking water so they do present a problem
and pose a threat to the groundwater supply of the Chino Basin. The Chino Basin
flows towards the west and south in this area, more or less parallelling the
Santa Ana River direction of flow. The plume control is necessary to prevent
further degradation of the Chino aquifer.
The alternatives that are in this report that most directly concern you, I
i
think, are those related to the disposal of the contaminated water that's
generated at the Stringfellow site, whether it's directly extracted contaminated
groundwater, treated or untreated, one way or the other, those are the ones I
think have the most possibility for concerning you.
8
The next overlay is something that shows what those alternatives are. One
i
of the sections of the report is a big table that takes all these different
technologies. This maybe in your executive summary, I'm not real sure. Is it?
These options that are listed here relate to the disposal of contaminated water
and leachate, are the ones that you want to pay particular attention to because
the alternatives as you can see are discharged to publicly owned treatment
works, discharged to surface waters, in this case surface water would be Pirate
Creek, which is a tributary to the Santa Ana River, which would have potential
for recharge into groundwater in the Orange County area, if that were the chosen
alternative, for example.
/ Off-site reinjection, probably not so far away as Orange County, more
I likely would be reinjection into the acquifier near the mouth of the canyon, or
I somewhere like that. Continue disposal to the Class I or II-I, but in any event
an approved facility and permitted as this facility. Solar evaporation near the
site was probably reuse in those latter two cases are uncertain as to their
applicability because of the uncertain customer for such water. And that's just
about where we stand right now. The next overlay shows the schematic of the
system. What we have right now is we have the Stringfellow site in the Pyrite
Canyon area with a vertical exageration to scale here. We are intercepting and
propose to continue intercepting and improve the intercepting system to capture
this contaminated groundwater, treat it and discharge it to the publicly-owned
treatment works interceptor line here. It goes through, it says here Plant
No. 1, this is an old slide. That's not the proposal anymore, but a treatment
facility and then discharge to offshore discharge. So it receives treatment at
-9-
this point, and also at the pre-treatment structure. Then in the flip-chart
shows the contamination to be I'm sure years before the contamination got down
that far if it would ever get that far but those are the hydraulic radiants that
connect the Stringfellow site to the ocean. And then also the surface water
discharge would have a potential for impacting the groundwater at some
downstream point as the Santa Ana River recharges in downstream areas. And that
is the presentation that I have. I can answer any questions. We have a couple
of other slides of the pre-treatment plant to give you an idea of what the plant
looks like. Mr. Ravi Shankhar is one of the project engineers on the
Stringfellow site for the Department of Health Services. He is in a position
that's funded by the EPA and has been most involved with the pretreatment plant.
This shows the general schematic of the treatment plant. The most contaminated
water onsite goes through a line neutralization process with rapid mix and _
and polymer for flaculation of metals and metals removal. And then the effluent
from the metals removal blends with the water which we're calling String D which
is the less contaminated water near the mid-canyon where the toxic metals are no
longer at a level. We have to knock them out. And this is primarily an organics
icontamination waste stream. This now is an organics contamination waste stream.
l And both of those blended go to the carbon absorption units and to discharge.
That's the schematic. We have pictures of the plant itself. These are the
influent tanks and behind them you see the clarifier. The rapid-mix unit and
lime addition is between these two clarifiers. This is the lime silo over here.
These are the carbon filters. They are leased from the Calgon Corporation.
We've done treatability studies to select carbon that offers best removal for
the best price. These are the effluent tanks. Utility water and you can see
-10-
that the plant is constructed with containment around it. This has been
asphaulted and there is a nice road around. That's the last one.
Buck Catlin: Can you show the slide that shows the mountains?
Answer: The picutures you show in 1955 of the surface What happened.
What happened was that in 1969 and in 1978 there were real heavy
periods of rain. Alot of that water was washed away from the site
because the efforts to haul it away and before it could wash out were
not completely successful. Alot of the water was hauled away at that
time. Alot of the water has just sunk down into the groundwater and
become plume and mixed in with the fresh uncontaminated groundwater
from the sides of hills caning down from both sides. Some of it's
perculated down and then during the interim of project, I wish
I could tell you how many gallons, I don't know how many gallons were
just pumped and removed from the site. Brian do you happen to know.
..�
Ten or twenty million gallons. BKK and other places. It was either
perculated or hauled away. Yes, then what was left after the free
surface liquids were drawn off was graded and those 20 ponds were
shaped into this basic configuration of two parts of the site and lime
was mixed in as best could be done and then the cap was put on.
9 � Don Roth: The question I had is that it was announced this morning that the
Governor has signed a bill that provides another 25 million dollars for the
r r, clean-up of Stringfellow. Where would those monies be put to in this addition
to those monies coming out
-11-
Answer: Well, the first place, I have heard reports that that bill had been
signed a week too, and they didn't prove true but the bill is Senate
Bill 1063 and it provides 25 million dollars approximately in total,
but something like 16 million of that is for Stringfellow. What is
would do is to provide money for implementation of measures that maybe
necessary in advance of federal funding receipt, for instance,
down-gradient, down-canyon plume control . In that area in Glen Avon
where I showed you the slide of the couple hundred parts per billion to
50 parts per billion area where it's still above the drinking water
levels, there is no program now operating to control that plume. It
maybe that we can demonstrate a need and receive federal funding for
that, but in the event that that can happen, the Governor wanted a
program to be ready just in case the federal funding isn't there to
control the plume in that area, plus another few miscellaneous
features.
Don Roth: They were interviewing Senator Presley in that scenario and on the
radio this morning----
Answer: Good. I'm glad to hear that. We've been waiting for that one. It
contained also a few other provisions. Let me see if I can think of,
there was something like 1.6 million for supply of alternate water in
the Glen Avon area to hook up a safe supply of drinking water is
included in that bill . Some amount over a million dollars and less
than two is available for carbon filtration of water in the San Gabriel
area. At one time there was a provision for four million dollars for
-12-
safe drinking water fund to be used around the state for whenever
something like that comes up in general. I'm not sure if that part
..' stayed in to the very end.
Don Roth: Is there an adequate amount of funding that's going to be provided by
the EPA and so-forth,------ adequate amount of funding ---- critical so that we
can be assured that we don't contaminate the Santa Ana River.
Answer: Well there is a freeze on right now on Circla because of the
reauthorization not going through Congress. Keith Takata from EPA is
the Superfund program manager for the EPA and maybe he can say
something about that.
Keith Takata: The fund is composed of tax on The fund is set
up to last five years. Right now Congress is trying to decide how to
reauthorize Superfund right now. All the groves seem to be behind the
authorization. President Regan . They are having difficulty
deciding how much should be funded over the next five years, how tax is
collected and there are a number of difficulties and unfortunate liabilities.
Right now the Senator has asked the bill for 7.6 billion over the next five
years. That is quite an increase over the orginal of 1.6 million. The House
is working on several bills, some of them offers of 10 million. There are a
number of committes working on facts that the house was taxed on some sort of
bill . In the meantime there has been a freeze placed on further Superfund
funding. Obligations that remain earlier in year offering
Stringfellow with the assumption that the assembly will buy this.
-13-
Dick Edgar: In all the dialogue on Stringfellow there is an identification of
how much material was placed there way back when during the time we didn't
understanding what we were doing, and then there is a period of time when alot
of extractions were placed. Is there any kind of credible estimate of how much
material is presently there. For example you say here is a 6/10 of gallon of
PC8 per day, is there some number.
Answer: Well we do have some records of how much liquid or waste was
disposed in the site. Mr. Stringfellow stored away the records and
kept them right up until the time that the Fed's came knocking at the
door. So that's how we totalled up the 34 million gallons of waste.
It's pretty vague generally about exactly what kind of waste was
disposed of. Just says contamined water or solutions or
wastewater in alot of cases. Sometimes it identifies solvents, in
general, but certainly there were not analysis done on each truck that
.,,�. was brought in where you could do a real mass balance of what went in
there. The estimates could be made on the basis of the known size of
the plume. We have a pretty good handle on how wide and how deep that
plume is and how long it is and you make some calculations. Alot of
that material like the metals, and to some extent the organics get held
up on the soil as it trys to migrate through the groundwater. Some of
it stays in the groundwater and some of it hangs up on the soil. So,
just how much contaminated PCB is down there, I really don't have a
number for that but I guess what I can say is that it will take alot of
water extraction to remove it because at the same time that we're
trying to extract the water, mother nature is keeping it recharged on
-14-
the sides and the bottom so more water is coming in. Another factor
that is going on is that it will take several rinsing of fresh water to
remove the contaminants that are stuck on the soil particles and in the
organic and so forth, it is part of the acquifer. It is
like trying to rinse out a sponge. If you have a soapey sponge you
don't ,just squeeze it out once with clean water and it's not soapy
anymore, you have to rinse it several times. It's the same case here.
Dick Edgar: My concern is that there is a number of estimates, even though they
may be magnitude estimates, nevertheless they would give some kind of visibility
of the magnitude.
Answer: The kinds of estimates we are developing now, as we learn more, and
continuing to put in more monitor wells, deal with how much
contaminated groundwater is there and how long might you have to
extract and operate a treatment plant. That kind of bears on what you
are asking, I think. We don't have that information available right
now, but it will factor into the solution. We are going to have to
know how long we will have to be operating the treatment plant.
Something on the order on 10 to 20 years is not unheard of or
groundwater extraction system. The concentrations and the amounts of
TCE will continue to diminish, especially if we cut off the source.
The source being the bulk contaminants that are left under that cap.
If that can be stopped, the groundwater will clean up more rapidly and
those estimates that were on there about how many pounds or gallons of
TCE are in a daily extraction, you remember from the mid-canyon, I
-15-
believe it was a half a pound a day from the mid-canyon. If the source
is cut off and we aren't extracting the couple of pounds or four pounds
a day from the onsite, then the whole of the extraction and plume
control program starts to look more like the half pound a day being
extracted. I guess you can multiply that by ten years and see how many
pounds of TCE you might have to extract. It's hypothetical because it
starts to get cleaner and cleaner as you go along.
n-
v
-16-
will continue to diminish, especially if we cut off the source.
e sour ing t e bulk ontami ants th aile 1 t under thy t c
th can a ped, , e rou water 1 1 le n up r'e apid y
i
os sii es t w on th r abou w oundi or gal on f
i
PE r i dui y extr c io , o rem r fr m he mil -c yo I
i
li vII i s h if p and d m he d- anyo I >l e s u ce
utl of in e re t x tr g t c u f you s or f r you ds
d y r he, ns to h n t ey w ole 'of he ext ., i and �me
ro ro ra rt ' to loo �or 1 Ike h� half ` o d a d b�i),g
1 \ 1 I
t ac u s y u ca ult#p that ten`,years and ,see how n'
p T ou ht h� a to ez£ract. is oth is 1 beta e t
o get cleave a d cleaner s� you go ng.
Dick Partin:
Answer: Some alternatives would take longer than others. For instance if you
were to instantly somehow shut off the sponge of material that
continues to leak out into the groundwater, if that wasn't happening
anymore, then the clean-up program for the plume takes much less time,
then what you would do is continue to operate the existing system until
all of stuff in the sponge is played out. That would take longer than
any of us will be around to watch, if that were to happen.
Dick Partin: The way of measuring what you could see
will never reach Is there any indcation of tracking more or
less the speed of this thing, again in Orange County.
-16-
Answer: We can measure the rates of the groundwater migration. We can do pump
tests based on the , and the hydraulic gradience and
calculate rates of groundwater movement and that's been done and those
are something on the order of 1,000 per year. The question is how fast
are the contaminants moving. The metals are probably not moving nearly
as fast as that because metals are charged ions and they hang up on the
charged clay particles on the soil and they don't move as fast. The
organics likewise have some retardation as they try to move through the
groundwater, along with the groundwater. The most direct way of
measuring that would be if you could make everything stand still at a
steady state and monitor the same well , same point, for a period of
time. The problem is that it happens so slow and there is so many
natural variations that take place, compounded by the fact that we are
influencing it ourselves as we extract, even though we have been
monitoring the canyon very closely for three years now, we don't have a
I..✓
real good picture of the trend or the rates of contaminant, organic
contaminant migration in the canyon, just because of all the different
influences of the pumping, wet years, dry years that have happended in
the last three years. I really can't answer the question except that
it has to be less than 1,000 feet a year.
Carol Kawanami :
Answer: We are installing monitor wells and wells that can be used as
extraction wells in the area, south of the freeway, we're not currently
-17-
extracting groundwater south of the freeway, we're only controlling the
plume north of the freeway. What's being done is that we are kind of
`./ breaking out the question of that piece of the remedy from the overall
remedy. Our consultants are doing a technical paper on the
alternatives for controlling the plume, the threat of not controlling
the plume and will be presenting that as kind of a separate broken out
piece ahead of waiting for the rest of the study to come through. When
that happens one
Ron Hoesterey: We can see all the open wells and the fact that they overflowed
during the heavy rains. Has there been any monitoring done along the Santa Ana
River to find out if there were high concentrations, low points, or basins.
Answer: Well, just immediately after the overflows in 1978, there was
monitoring done in the river and the results that I have seen didn't
show any contamination dishonorable at any distance from the site. We
also have done some sampling of soil areas in the low points of the
community where the rain water went down Pirite Channel and it ran off
laterally into the streets in the community and we have tracked that as
best we could with the topography and the mapping the area and also
talking to the residents who said in 1979 it was here or whatever.
We've sampled those areas and we couldn't find any residual
Stringfellow contaminants in any of the low spots immediately
down-gradients from the site in the Glen Avon area just south of the
freeway, so I don't think that's a problem. What ever went out in 1979
is long gone and there is two things working to our advantage in that.
-18-
One is that if it were heavy metal contamination it would still be in
those low areas near the site and samplable and we don't find it at
elevated levels. I wouldn't think it would be down farther, but even
if it did that's the kind of stuff that hangs up as it travels through
the soil. The organics are primarily in the leading edge of the plume
at least their the solvants, the organics and they wouldn't be
present very long in the atmosphere. They probably wouldn't have made
it as far as the Santa Ana River.
Dick Edgar: I would imagine that you must have some idea of to
the . It's a losing battle. Fifty percent of that fact that
Answer: Well, the goal is to come up with a solution which adequately protects
the groundwater resource primarily and also in the process of doing
that doesn't mess up the air or whatever else might happen as we open
up the site or as we treat the wastewater. How far along we are is as
I said we are about to complete the remedial investigation meaning that
we are at a point where we think we know about as much as we are going
to know about the length and the width and the depth of the plume and
the contaminated material on site. There are about maybe half a
million cubic yards of contaminated sponge on site, plus another half
million of what could be called diggable bedrock as opposed to not
diggable bedrock, fractured and real crumbled up, decomposed bedrock,
and down-gradient contaminated soil material. Those are recent
estimates of the volume of waste that's there. We have characterized
that. We are about 1/3 of the way through this process of feasibility
study that's outlined in some of the scematics. I would say that
-19-
time-wise by January we should have a report out which narrows it down
to three or four key alternatives as opposed to these little pieces
called technologies that get blended together and create alternatives.
We should be at that point where we are ready to throw out for public
consideration some few number of alternatives for controlling the
problem. Then the selection process and the design and so forth will
take another few months and maybe considering design, another year, and
then implementation, no doubt if the alternative is to excavate or
redispose in some more properly constructed facility like with a bottom
for instance. That's a two or three year project to do that. I hope
that answers some of your questions. One thing we found out along the
line of how effective have we been, we estimate that maybe we're
capturing 60 percent of the plume in the area of the mid-canyon.
Gene Wisner: Do you know what the depth of the contamination is at the site.
Answer: The waste material and the soft stuff goes down maybe 90 feet or so and
then you get into an area of highly weathered bedrock and that is from
10 to 30 feet of weather bedrock and then fractured bedrock of another
50 feet maybe, I don't know roughly. Then below that you get sound
bedrock. The contour, I don't have a slide that does it, but if you
could imagine a cross-section through that lower big area, you would
see that the bottom of the bedrock contour drops off, it's got two
little dents in it and then it drops off. This is the 90 foot part.
That's where the old Pirate Channel Creek used to run through. It's
only 90 feet in the very deepest. Most of the site on the average
would be much less than 90 feet.
-20-
If Congress doesn't reauthorize the Superfund, there is not enough
money left from the original authorization, not only for this site but
for all the sites.
Like I said, we don't have a program going right now to control
down-gradient extraction. The money that the Governor signed in the
law today, would last for awhile. I think that's a two year program.
Yes, it's a two year program. That's just for expansion of the
extraction program.
Norm Culver: I get this feeling, I'm not being facesious. We've been through
this thing about five or six times now, direct opposites I feel
that somewhere along the line This is the most lengthy report
I've ever heard. I feel like we're losing all the time. When the
last gentlemen was here from the treatment plant, what organization is that,
SAWPA, when I walked out of the room I felt, Roger, you're dead wrong,
everything is under control, everything is taken care of. I sure don't feel that
way tonight. Is that the intent of the presentation.
Answer: It certainly wasn't my intent. My intent was to tell you what was
going on at the site and make you aware of where we are in the process.
I certainly didn't intent to paint a negative picture. The negative
site may come from the fact that the plume is now farther down into the
community.
Norm Culver: The presentation that we had was freeway from the
treatment plant. The effluent that goes from there in our minds is no problem.
-21-
We have alot of women here that are very concerned about it. Forget about this.
These people know what they're doing. I'm beginning to wonder what's going on
up there now.
Answer: In particular, what are your areas of concern.
Norm Culver: Everything I've heard tonight has been negative. This report, you
have got some that maybe will work and some that won't work. How long is it
going to take
Answer: The purpose of the report was to identify which ones will work and what
ones won't work at Stringfellow and then throw out and forget about the
ones that won't work and zero in on the ones that will work. That's a
different process, that's a different process. The treatment plant is
one of those ones that was identified as one that will work and so we
built it, that was the idea to identify an early remedy to that part of
�..' the problem. That was a little piece of the feasibility study that was
broken off because it made sense, just common sense to do something
other than follow the wastewater 200 miles to Casmalia. So we decided
that since that makes sense let's design the treatment plant and do it
ahead of everything else like 1988 before we would have built it
otherwise.
Dick Edgar: The question I have, in negative response to Norm, is that as a
Board we took a very strong position to authorize the question of
treated wastewater through our facility and to my knowledge we aren't processing
any wastewater yet, and yet my feeling is that from the standpoint of the
_2p_
�.d
investment that we've made for diversion here at the treatment plant, from the
construction of the plant, from all of the engineering mechanical things that
were comnited by our Board and by SAWPA and DOHS and EPA, it seems to me that
there is some kind of bueracratic kind of hang-up in terms of enabling the
procedure to go forth as we have originally anticipated and directed.
Answer: I think maybe part of the misunderstanding is the focus of the earlier
briefings that you had by SAWPA was on treatment plant itself and what
we were calling the interim solution, otherwords those things that we
can do now.
Dick Edgar: My question is now, it's October, and I fully expected that water
to be coming through our plant back in June or
Answer: I can give you an update on that. What happened is like Stan explained
that the Federal Superfund money is spent, or used in a couple of ways.
One is EPA can take the lead in which case it would use it's own
contractors or the State can take the lead in which case we give the
money the State and the State hires their contractors. Well, that's
how the plant was built. The money was given to the State, and the
State contracted with SAWPA to build the plant and then SAWPA hired
it's own contractors to build it.
We're almost to the point now where we can begin operating it. What
happened in April of this year is the Department had originally planned
to operate the plant themselves, they requested EPA to take over the
lead in operations so EPA and our own contractors to
put together the operating plans and a team to do that. Our operating
-23-
plan and our team is now ready to operate the plant. There are a few
things that we have to take care of. There are a few minor
construction details that haven't been completed by SAWPA yet, and the
State. We haven't negotiated the final language of the permit yet and
we haven't received the monitoring plan from the Sanitation District
and SAWPA. We hope that those three items will be completed this week.
Our goal is to have a final permit and have that permit discussed at
your next Board's meeting, which I believe is October 16th, and if we
can have that discussed then if you folks approve of it, then we're
ready to operate the plant on the 21st.
We haven't had start-up yet. Start-up will occur on the 21st. Then
we'll get through start-up and operations will start after that.
The testing has been started though. It has been going on in terms of
equipment testing, manufacturers, punch list checking of items that are
built into the treatment plant. So that kind of testing has occurred.
Running water through the plant has not started.
Buck Catlin: What I heard, you've seem to be proceeding technically like you
have advertised that you would. I don't see anything different than what you
advertised before. Delays seem to be mostly administrative and financial, than
just delays. There is something that would happen down the line that would
surprise you that would be in development that you didn't anticipate that could
throw your predictions and your esteem compleiaJy
Answer: Nothing surprises me anymore in this program. So I imagine there is
alot of things. Anything from a court order to who knows what could
-24-
put things, off. Well, we are doing testing, like I said, some
treatability testing of wastewater. We are trying to find more
economical ways of treating it. We have a very high carbon demand with
this wastewater. The organics loading is such that it really uses alot
of carbon and if we can find some way through the treatability testing
to use a different carbon or to knock out some of the organics before
it gets to the carbon, that would be a pleasant surprise, and that's
something that could come up during the studies that are going on now.
I don't think it would get any worse.
Buck Catlin: There is a confidence factor, in that you are surrounding the
problem and there may be delays but we are on the wrong track
and we are investing our money and our time in the wrong direction.
Answer: Well the plant is designed from a standpoint of flow and from a
standpoint of carbon loading in consideration of the worst case. The
flow is quite a number of times greater flow than we planned on seeing,
based on recent extraction at the site. The site is nearly dried up
now and it is designed for much more flow than we have had before. So
we are not going to be surprised by not being able to handle the
groundwater, at least from the mid-canyon and the on-site. We've got
more carbon there than we think we'll ever going to be able to use.
Especially if we can knock off some the organics loading ahead of that.
So I don't think they are the design kinds of surprises, but you've got
to consider that this isn't a routine system, it's not something like a
pretreatment plant that might be connected to any number of industries
-25-
around your area that feed into your sewer lines now and they know the
product their manufacturing, they know that there are a limited number
of waste streams, specific kinds of waste. This is a non-homogeneous
kind of waste, it's different in different areas of the plant and it's
gong ':o ':a' e a ' . _i:'e more -:ne `unn'ng I think than some other
treatment plants. That's why the start-up program is so important.
Don Smith: I understood that the treatment plant was an interim situation, but
will it be used in 10 or 20 years.
Answer: It's called interim pretreatment plant because it was shown to be
economically a good idea to build it and operate it over the period of
several years that we were conducting the study and implementing
whatever comes out of the study. If what comes out of the study over
the next couple of months shows that treatment plant is still a
continued long-term economical step measure, it will be done for the
long-term, it will be recommended as a long-term solution. But right
now the treatment plant stands on its own as an interim measure.
Don Smith: You don't have any alternative to that at this point.
Answer: We have other alternatives such as some of those things in the slides
like discharge, continued discharge to some solar evaporation.
Don Smith: What year was it first recommended and closed as a receving
material . Did the flood of 1968 and 1969 bring it to That's what I
thought.
-26-
Answer: Ron, it probably could be estimated that how much fluid was in those
holding basins was based on the area of it prior to the floods of 1969.
If all of that vacated the site down the river with no measurable
ill effects, how big of a problem so we have. I don't know what a half
gallon of TCE a day does to people. Is it something you drink and die
or is it something that would never show up
Well, a gallon of TCE is going to contaminate to the action level, 200
million gallons of water. I think that sounds right. Because if it
were one part per billion it would be a gallon and a billion gallons of
water and the action level is 5 parts per billion so it would be 1/5 of
a billon, 200 million gallons of water. So one gallon of TCE could
contaminate that much water.
Question: I have a problem understanding how much water could escape from the
.� site had no measurable effects all the way down
Answer: Well most of this stuff is volatale, as I said. It just goes off into
the air. We have had other sites where we are channelling water that
we're pumping out of an extraction system, for example the aerojet site
in Sacramento, and the water comes out of the extraction wells and goes
through an open channel about a quarter of a mile or less and by the
time it gets to the air stripping towers, most of the TCE that was in
the water is gone. Well, it undergoes photochemical decomposition in
the air, changes.
Carol Kawanami: That reminds me of the Mexico City earthquake.
consideration is given to the impact or the earthquake on this site.
-27-
Answer: Well, certainly in a design if we were designing some containment or
burns, yes we would design it for earthquake standards. The treatment
plant was designed to withstand design earthquake standard loads in the
area. Robbie might be able to tell us more about that.
Possibly what you're asking is more like you have got a bunch of
fractures under the site but if something shifts and the bottom drops
out and all of that stuff disappears, that would make us all real
happy. It could open up some new pathway, if there were a fault, we
haven't found any faults in the area at this time. The evidence isn't
there for faults right now. We have looked and find that there are no
faults immediately under this site.
Dick Edgar: One of the things you've mentioned a couple of times tonight and I
am kind of curious about, that is it appears as though the amount of rainfall
directly affects the groundwater and affects the amount of extraction taken, so
is that even going to be a limitation in our interim solution or ultimate
solution that we can only take the finite amount of water out of the site at any
particular time. Would that be advantageous in terms of not having the material
go down
Answer: What you say is right. The extraction depends on the amount of
rainfall and we pump some wells until they are dry and then we just
don't have anymore to pump. We had some spring interceptors and we
were capturing some of the clean water before it went into the site.
We could only get a trickle out of them because it's been so dry, so
yes it definitely does effect that. We have running into the site now
-28-
from the up-gradient, something like a garden hose amounts of water,
literally, 50 gallons a minute or thereabouts. We are going to try and
do what we can to eliminate that because in wetter times it's more than
50 gallons a minute.
Jt. Chairman Griffin: Just to mention, I don't know whether Bob Griffins is
with us, he is part of the Stringfellow Advisory Committee, I believe, what
three people. Three people are on that advisory committee and I don't know
whether, is there anything you would like to say this evening, Bob.
Bob, you're with the County of Orange and I forgot what Department.
Bob Griffin: I am Director of the County Hazardous Materials Program and in
fact several months ago people from Orange County were invited to the
Stringfellow Advisory Committee. Myself, representing the Board of Supervisors,
Barbara Brown from the Fountain Valley City Council and Lee Porteright, who is
the President of the League of Voters in Orange County. The three of us have
been working with these people for almost a year now and going to regular
meetings on briefings on what they're doing and what the plans are. Our primary
interest of the Orange County representatives as opposed to the Glen Avon
Riverside representatives, has been the issue of what happens to the
groundwater. Up there were concerned about a lot of other things, like the soil
and other factors. Our primary interest, of course, is the water. I think
one of the key things that needs to be well understood, but I don't think the
public at large understands, is having that tree of wastewater come down through
our sewer lines, absolutely is not the worst thing that could happen to Orange
County in relationship to Stringfellow. In question the worst thing that could
y -29-
happen is that everybody just walk away from the site and let nature take its
course and then we would end up with the contaminated river and our basin is
contaminated. Several of the alternatives that they have discussed are in your
summary and I think have varrying degrees of possibilities of being implemented
in our area. My reading of what they have said and what we have learned so far
about the site is that discharging water to sewer line is far _ from the most
likely thing to happen on a long-term basis. As Stan indicated that decision
has not been made yet and will not be made until it finishes the study and come
through all of the conclusions and details, but just forecasting a little bit, I
think it's very likely to be the solution. Some other things that we
are pushing for and want to be sure that they consider very carefully, frankly
the Glen Avon community are not very enthusiatic about are things like solar
evaporation. If the water could be pumped out of the ground, treated, and then
the treated wastewater evaporated there in Glen Avon, then Orange County is not
affected at all by the wastewater. Those people up in Glen Avon don't want to
do anything to do with solar evaporation, that's what Stringfellow sold them
back in the 50's was that solar evaporation was a waste and they feel like they
are being burned on that. We're talking about a whole different type of solar
evaporation. Stringfellow was evaporating the raw waste materials, and we're
talking about evaporating now the treated wastewater. It's a whole different
situation. That's somewhat lost on some of the residents up there in Glen
Avon. They hear solar evaporation and they go right off the deep end.
Discharging water to surface especially gets into the river,
obviously for at least the highly contaminated water is not a good idea for
Orange County. That gets into the river and perculates into our basin. There
-30-
might be some circumstances or watching this and listening to what the
engineers have to say about it. The heavily contaminated water could be treated
not necessarily through the whole plant but through air stripping and be cleaned
up enough so that it could be surface discharge. The heavily contaminated water
I think is strictly unlikely to be surface discharge. More likely contamined
plume after some sort of treatment is a possibility.
Bob Griffith con't. : The more likely contaminated plume after some sort of
treatment is a possibility. The three of us on the committee are, everytime it
gets mentioned go into a lot of detail. But the major thing
that all of
our citizens in Orange County need to understand is that the fact that the
treated wastewater is coming down through the sewer line, is not that Orange
County is doing a favor to Riverside to take care of the problem. It is to
protect our resources that we're doing, and it is to our advantage here in
Orange County to allow that to happen and what the proper standards, safeguards,
and monitoring, the whole bit, to watch it and let it happen, if that's the
appropriate decision.
Jt. Chairman Griffin: Just a summary of that, that's the essence, I believe of
the working arrangement that we have with SAWPA, is that whether it be a
Stringfellow or whether it be any other kind of treated or treatment process in
the upper watershed. Anything that has any kind of content that could
potentially jeopardize the underground water basin is what we are all working to
avoid. Whether it be a drying solution or any other kind of material. If we
look at the issues that are up there, whether it's a Stringfellow or whether
it's the dairies or whether it's industry, there is a good lot of those issues
floating around that particular area.
✓ -31-
Bob Griffith: One of the critical points, I guess prove to ourselves and
therefore to the public, that we really are doing what these The
" monitoring that is going to be done after the water goes through the treatment
plant and is ready for discharge, presumably to the SARI line, then the plant is
to be developed by the guys here at the Sanitation District with SAWPA and the
rest of them, is that that every holding tank load of that water will be tested
to make sure it meets the standards before one drop of it is discharged into the
SARI line. If it does meet the standards, it goes back to the plant until it
does meet the standards. Not one drop of the treated wastewater gets put into
the SARI line until standards have been verified, not by plant operators
but by independently by Orange County people to verify that the standards are
what they are advertising to be and in fact that the plant is working as it is
suppose to be.
Joyce Wisner: Question of clarification more than anything else. What kind of
operation is going to take water from where--the major basin or the plume.
Answer: It's going to take water from the three on-site wells that are under
the area enclosed by the roads and the gunite channels and the
interceptor wells at the mid-canyon, half way down the Stringfellow
Canyon, about 2,000 feet from the barrier dam.
Joyce Wisner: My additional question is, are you blocking off these areas--is
that what you're saying, an area that is blocked off and the water is then going
to the treatment . Then you said something about well their is
not enough water and you have capacity that you are worried about water and
wondering why you don't flush water into that area to flush out all the residues
that you need to flush out.
-32-
Answer: As I understand the first part of your question, are you blocking it
off. The blocking is just the barrier created by the extraction wells,
in other words you draw the groundwater out, you create a groundwater
depression and any water that would like to go down that canyon and
march towards Glen Avon instead falls into the hole created by these
wells--these line of wells across the canyon from bedrock to
bedrock--that's the barriers. We are looking at other alternatives,
physical barriers--they are on the verge of being screened out as being
inpractical, however. The second part of your question. Could you
rephrase that for me.
Joyce Wisner: Add water--flush out water.
Answer: The possibility of, for instance, taking some of the soil material and
washing it with treated water or lightly contaminated water to flush
out the contaminants from the waste material is being evaluated.
.:
Taking water and putting it into the canyon area, I don't think that's
something that we've been evaluating. Since right now we're only
capturing maybe 60% of the water. Putting more water in would just be
that much more that gets away from us.
R. Chairman Griffin: Well, I think we had an interesting evening. I think it
was very profitable. A couple things I would like to just comment on in
closing. Your staff has been following these public meetings and there has been
an awful lot of interface that way and I would want to thank, of course, our
General Manager Wayne Sylvester and his staff, Bill Butler, and Blake and the
others, and Tom for taking their time and extra effort to represent you and make
-33-
sure we understand and know what's going on. So we appreciate that--to Stan and
Keith and Bob, we appreciate you people being here to keep us updated as you
N..w know we have a strong and important concern about what happens up there and it
is our desire to track this and monitor this as it progresses. So we thank you
for your time evening. Thank you for your courteous and informative responses.
With that is there any other business. I need a motion. Motion to adjourn.
Afourned.
-34-
COUNTY SANITATION
DISTRICTS NOS. 11 22 3, 51 62 72 11, AND 13
OF
ORANGE COUNTY, CALIFORNIA
MINUTES OF THE ADJOURNED REGULAR MEETING
ON
OCTOBER 2, 1985 - 7: 30 P. M.
�r%VrATIO& O
2�y 9.1ima all, Sp
O :tea e �a
'Sine. 195�
y
GR'9NGE C013,
ADMINISTRATIVE OFFICES
10844 ELLL3 AVENUE
FOUNTAIN VALLEY, CALIFORNLk
ROLL CALL
An adjourned regular meeting of the Boards of Directors of County Sanitation Districts
Noe. 1, 2, 3, 5, 6, 7, 11 and 13 of Orange County, California, was held on October 2, 1985, at
7:30 p.m., in the Districts' Administrative Offices. Following the 'Pledge of Allegiance and
invocation the roll was called and the Secretary reported a quorum present for Districts Noe. 1,
2, 3 and 13 as follows:
ACTIVE DIRECTORS ALTERNATE DIRECTORS
DISTRICT NO. 1: x Robert Hanson, Chairman Orma Crank
x Ronald B. Hoesteray, Chairman pro tam _Donald J. Saltarelli
—7—Dan Griaet Robert Luxembourger
_1._Roger Stanton _Harriett Wieder
DISTRICT NO. 2: x Buck Catlin, Chairman Chris Norby
a Richard Buck, Chairman pro tam _George Ziegler
x Sam Cooper Carrey Nelson
x Dan Orient Robert Luxembourger
—x—Carol Rawanami Wayne Silzel
a William D. Mahoney _Dorothy Wedel
x James Neal _George Scott
—x'—Bob Perry Norman Culver
x Don Roth _E. Llewellyn Overholt, Jr.
x Don Smith _Gene Beyer
_A_Roger Stanton Harriett Wieder
x Gene Wisner Michael J. Beverage
DISTRICT NO. 3: x Don Roth, Chairman H. Llewellyn Overholt
x Carrey Nelson, Chairmen pro tam Sam Cooper
Ruth Bailey x John Thomas
_
x Buck Catlin —BobChris Norby
x Norman Culver _Jams
Perry
x Don Griffin —Robert
T. Jarrell
x Dan Griaet _Robert Luxembourger
a William D. Mahoney Dorothy Nadel
x James Neal _George Scott
Richard Olson x Bruce Finlayson
x Richard Partin _John Ranel
x Richard Polls _Dan Collins
x Joyce Risner _Oscar Brownell
_!_Sal Sapien _Jean Siriani
_A___Roger Stanton Harriett Wieder
x Charles Sylvia _Anthony Selvaggi
DISTRICT NO. 5: x Evelyn Hart, Chairman _John Cox, Jr.
_1._Philip Maurer, Chairman pro tam _John Cox, Jr.
a Roger Stanton _Harriett Wieder
DISTRICT NO. 6: a James Wahner, Chairman _James Gallacher
x Ruthelyn Plummer, Chairman pro tam John Cox, Jr.
_a_Roger Stanton _Harriett Wieder
DISTRICT NO. 7: x Richard Edgar, Chairman _Donald J. Saltarelli
a David Sills, Chairman pro tam _Dave Baker
x Dan Griaet Robert Luxembourger
a Philip Maurer _John Cox, Jr.
x Don Smith _Gene Beyer
_1 Roger Stanton _Harriett Wieder
a James Wahner _Harry Green
DISTRICT NO. 11: a Ruth Bailey, Chairman _Robert P. Mandic, Jr.
a ma
Roger Stanton, Chairman pro tam Harriett Wieder
x John Thomas _Ruth Finley
DISTRICT N0. 13: x Sam Cooper, Chairman _Carrey Nelson
x Michael J. Beverage, Chairman pro tam Gene Wisner
—;—Don Roth —Gene Beyer
__a,__Roger Stanton _Harriet Wieder
-2-
lU/ UL/0>
STAFF MEMBERS PRESENT: J. Wayne Sylvester, General Manager, Rita '
Brown, Board Secretary, William N. Clarke, _
Thomas M. Dawes, Blake P. Anderson, William
H. Butler, Penny Kyle, Rich von Langan,
Gary Streed, Corrine Clawson, Charles Jacks
OTHERS PRESENT: Thomas L. Woodruff, General Counsel,
Suzanne Atkins, Ray Lewis, Scott Morgan,
Stan Phillips, Keith Takata, Bob Griffith
x acerr * * � * traa
DISTRICT 5 This 2nd day of October, 1985 at 7:30 p.m.,
Adjournment being the time and place for the Adjourned
Regular Meeting of County Sanitation
District No. 5 of Orange County, California, and there not being a quorum of the
Board present, the meeting of District No. 5 was thereupon adjourned by the
Secretary.'
DISTRICT 6 This 2nd day of October, 1985 at 7:30 p.m. ,
Adjournment being the time and place for the Adjourned
Regular Meeting of County Sanitation
District No. 6 of Orange County, California, and there not being a quorum of the
Board present, the meeting of District No. 6 was thereupon adjourned by the
Secretary.
DISTRICT 7 This 2nd day of October, 1985 at 7:30 p.m. ,
Adjournment being the time and place for the Adjourned
Regular Meeting of County Sanitation
District No. 7 of Orange County, California, and there not being a quorum of the
Board present, the meeting of District No. 7 was thereupon adjourned by the
Secretary.
DISTRICT 11 This 2nd day of October, 1985 at 7:30 p.m. ,
Adjournment being the time and place for the Adjourned
Regular Meeting of County Sanitation
District No. 11 of Orange County, California, and there not being a quorum of the
Board present, the meeting of District No. 11 was thereupon adjourned by the
Secretary.
DISTRICTS 1, 2, 3 S 13 Joint Chairman Griffin stated that the
Review of Draft Interim Report on California Department of Health Services
the Stringfellow Remedial (DOHS) and the U.S. Environmental
Investigation/Feasibility Study Protection Agency (EPA) had agreed to
brief the Directors on the Draft Interim
Report on the Stringfellow Remedial Investigation/Feasibility Study which had
recently been issued by DORS. Copies of the full report were distributed to Board
members in August.
Mr. Griffin noted that the Districts play an important role in the success of the
Stringfellow clean—up project and are prepared to fulfill their responsibilities
to protect water quality and play an appropriate role helping others to do the
same. He emphasized that in order to achieve the water quality objectives, open
and on—going communication between the respective agencies and exchange of all
relevant information was necessary so that the decision makers could adequately k..It
—3—
iV/J[/oJ
evaluate the alternatives and arrive at the best overall solution. The Joint
Chairman also observed that the Districts' cooperative efforts to protect the
Santa Ana River Basin underground fresh water supplies have certainly been
demonstrated over the years.
v Joint Chairman Griffin then introduced Mr. Stan Phillippe, Project Manager for
the DOSS Toxics Substances Control Division, and Mr. Keith Takata, Chief of the
Superfund Program Branch, EPA Region IX.
The state and federal officials then reviewed the history of the Stringfellow
waste site, the interim cleanup measures being taken and the long-term solutions
being studied. The work is being financed under federal Superfund legislation.
Under Superfund, sites requiring cleanup are identified for inclusion on the
national priority list, a remedial investigation to characterize the nature of
the problem and study the feasibility of alternative solutions is conducted and
then the selected alternative is designed, followed by implementation of that
designed clean-up action, and a period of operation and maintenance.
The purpose of the Stringfellow project is to prevent contamination of the
underground fresh water supplies in the Chino Basin and Orange County. The
interim pre-treatment facility has been constructed for the short-term solution
and it is anticipated that discharge of pre-treated wastewater to the Santa Ana
River Interceptor System will commence in the near future.
The Draft Interim Report on the Stringfellow Remedial Investigation/Feasibility
Study identifies technologies that may be applicable to the Stringfellow site for
the long-term solution. The report evaluates the feasibility of the different
alternatives. The report also sets forth the process used in developing and
screening the alternatives and the schedule for completing the work and
v submitting the recommendations for public review.
The officials pointed out that although the best ultimate clean-up plan is yet to
be identified, the following appeared to be most feasible:
Discharge to publicly owned treatment works (POTW)
Discharge to surface waters
Offsite reinjection
Disposal to Class I or Class II/I disposal site
Solar evaporation
Reuse offsite as industrial or agricultural water
Reuse onsite for process purposes
The officials pointed out that the long-term alternative to discharge to a POTW
(i.e. , the Orange County Sanitation Districts Treatment and Disposal System),
although not decided, is a very likely choice because of the interim pretreatment
facility that has already been constructed and the economics of that disposal
method.
v
-4-
10/02/85
The Directors then entered into a lengthy question and answer period during which 1
the current disposal method to a Class I landfill was reviewed and the proposed
start-up and operation of the interim pre-treatment facility was discussed. The
availability of federal and state financing for the clean-up effort was reviewed.
In addition, the amount of materials deposited at Stringfellow and how long it
would take to eventually complete the long-range cleanup program; further detail
on the present Stringfellow site condition and the extent of the existing
groundwater contamination; short and long term cleanup efforts and methods and
the cleanup timetable; the effect of surface waters on the site conditions; and
the extensive monitoring that will be done on the treated groundwaters prior to
discharge into the sewerage system were reviewed.
The state and federal officials also explained the transfer of regulatory
responsibility for operating the interim Stringfellow treatment facility from the
Department of Health Services to EPA.
The Chair also recognized Mr. Bob Griffith, Director of the County of Orange
Hazardous Materials Program and a member of the Stringfellow Advisory Committee,
representing Orange County. He observed that the Orange County representatives
on the Advisory Committee are primarily concerned with the impact of Stringfellow
on Orange County's groundwater. He spoke in support of the interim Stringfellow
program to protect the groundwater supply and stated that pretreatment of
extracted water and disposal at a POTW is the very likely long-term solution.
DISTRICT 1 Moved, seconded and duly carried:
Adjournment
That this meeting of the Board of
Directors of County Sanitation District No. 1 be adjourned. The Chairman then
declared the meeting so adjourned at 9:00 p.m. , October 2, 1985.
DISTRICT 2 Moved, seconded and duly carried:
Adjournment
That this meeting of the Board of
Directors of County Sanitation District No. 2 be adjourned. The Chairman then
declared the meeting so adjourned at 9:00 p.m. , October 2, 1985.
DISTRICT 3 Moved, seconded and duly carried:
Adjournment
That this meeting of the Board of
Directors of County Sanitation District No. 3 be adjourned. The Chairman then
declared the meeting so adjourned at 9:00 p.m. , October 2, 1985.
DISTRICT 13 Moved, seconded and duly carried:
Adjournment
That this meeting of the Board of
Directors of County Sanitation District No. 13 be adjourned. The Chairman then
declared the meeting so adjourned at 9:00 p.m. , October 2, 1985.
Secre-- tary, Surds os
County Sanitation Districts Nos. 1, 2, 3,
5, 6, 7, 11 6 13
-5-
(:a:*..-.
COUNTY SANITATION DISTRICTS
OF ORANGE COUNTY, CALIFORNIA
�t P.O. BOX 8127, FOUNTAIN VALLEY,CALIFORNIA 92728-8127
10844 ELLIS. FOUNTAIN VALLEY, CALIFORNIA 92708-7018
1714) 540-2910 (714) 962-2411
September 19, 1985
NOTICE
FINAL SELECTED DATE FOR ADJOURNED BOARD MEETING
FOR
PRESENTATION BY THE STATE DEPARTMENT OF HEALTH SERVICES
ON THE DRAFT INTERIM REPORT: STRINGFELLOW FACILITY REMEDIAL
INVESTIGATION/FEASIBILITY STUDY
WEDNESDAY, OCTOBER 2, 1985 - 7 : 30 P. M.
At the last regular Board meeting the Directors selected
alternative dates of September 25th and October 2nd for an
adjourned meeting for a presentation on the Draft Interim Report:
Stringfellow Facility Remedial Investigation/Feasibility Study
and tentatively adjourned to September 25th, with the
understanding that the preferred date was October 2nd.
We have confirmed with the State Department of Health Services
that they will give their presentation on Wednesday, October 2nd
at 7 :30 p.m. Therefore, the Boards will not meet on
September 25th; rather, the Secretary will adjourn that meeting
to October 2nd at 7:30 p.m.
An agenda for the October 2nd meeting will be mailed later under
separate cover.
�' Secretary Yl"'"'
DISTRICT NO. 1 ADJOURNED MEETING NOTES - 9/25/85
#2(a) Verbal staff report
The General Manager introduced Rich von Iangen, Chief of Industrial Waste
Division, who addressed the Board. He advised that he is in charge Of enforcing
and administering the Industrial Waste ordinance. The Industrial Waste
Department routinely samples industries four times per year. He indicated that
Universal Circuits contends that the sample on which the non-compliance fee was
based was not representative of the samples from their facility. Universal
Circuits has been permitted since 1981. He added that it is a privilege for
industries to discharge into the Districts' system, not a right.
He then recognized Kelly Christensen, the Districts' inspector in charge of
Universal Circuits. Kelly reported on the standard procedures used by the
District to collect the wastewater sample in question. SEE ATTACHED REPORT.
#2(c) Response by Universal Circuits
Gary Ryan of Universal Circuits addressed the Board. He mentioned that intially
he had presented the members of the Board with copies of every piece of
correspondence on the appeal and a copy of the Ordinance. He referred to the
appeal procedure on page 40. He claimed he didn't understand why he wasn't
granted an appeal hearing in a timely manner. He indicated that rather than go
over the correspondence, he had decided to respond to Kelly's statements. He
disagreed with his statement re "likely source" of the excess discharge. He
referred to page 39 of the ordinance which mentioned that any person who
violates any portion of the ordinance could be guilty of a misdemeanor. He
stated he could not accept the phrase "likely source" and felt he was being
accused of a misdemeanor. With regard to the cleaning of the sample box. All
sample boxes contain an accumulation of copper.
%W He referred to the 24-hour sampling and said there was not continuous flow
during the entire 24-hour period. He also stated that he did not recall ever
being told they had the option of installing a flow proportional system. He
then referred to charts showing the maximum flow rates suggested by IA County
Sanitation Districts and ISOO where a flow proportional system would be
beneficial. He indicated the OCSD didn't give him a percentage figure.
#2(d) - Discussion
Rich von Langen addressed the question re what percentage figure makes the time
coiposit incompatible. The percentage doesn't have anything to do with design
of the system. It has to be designed by a professional engineer and calibrated
on an annual basis. He then reviewed the reasons why the Districts use flow
proportional versus time composit sampling, as follows:
ADVANTAGES
TIME COMPOSITE FLOW PROPORTIONAL
- Can detect batch dumps - More representative for highly
- Samples at regular intervals variable flogs
- Inexpensive, simple
DISADVANTAGES
- Less representative - Expensive, complex
- Highly variable flows - Difficult re detection of
of batch dumps
He added that since 1976 the Districts have used time apposite sampling.
Universal Circuits has been aware of this since 1981.
Rich stated that he was not accusing Universal of a criminal act. TLW added
that it is true that the ordinance has a section allowing for the prosecution of
a criminal omplaint and fine upon conviction, but that is just one of the
v remedies available. The case before the Directors is simply a dispute over an
unpaid bill and the Districts were, at no tine, pursuing criminal proceedings.
There is probably nothing that would warrant it. There is some basis to think
that maybe the tank is leaking and causing this. Not every violation
necessarily equates to a criminal act. He reiterated that this is just a
dispute over an unpaid bill. Mr. Ryan doesn't agree with the methodology of
determining the bill.
Director Griset said he has had his staff working with Mr. Ryan to help him
understand the issues here. It seemed to him that there is a difference in
methodologies. If flow propotional system had been used, they wouldn't have the
bill. He stated that what he was wrestling with is if, in fact, we may be wrong
based on our methodology. Shouldn't we step back and find out a way to agree on
the methodology? Asked what the cost would be to do this, slake Anderson
replied that our position has been that by taking 96 samples during a 24-hour
period, it is exte ely likely we will have a representative sample. Unless you
take the entire quantity, you can only have a very goad estimate. Installation
of a flow proportional system is estimated at $10,000. It costs about $100 for
installation of a sample box for the time conposite sampling. Griset asked if a
company wished to install this other method, would the staff object. He was
told no, we would have no objection. We do have industries that do monitor that
way.
Mr. Ryan stated that if there are inaccuracies, he didn't intend to pay the
bill. Griset asked him if his company wished to install the flow proportional
system at their expense. He said yes, he would consider it. With 96 samples
there are a variety of flows. Griset asked how 96 samples would be inaccurate
re variety of flows. Ryan explained how one pound of copper per shift could
appear to be more.??
Director Hoesterey camrnted re different rates of production during different
shifts. Asked if we know when there is a fluctuation by records we have? Ryan
said we oculd maybe read the water meter between each shift, but currently we
have no idea. Rich added that there are two problems—the staff cannot
determine what those numbers are and the other is the concept behind the flow
proportional sampling which does have a flow chart. Hoesterey added that there
are so many pounds of copper that are allowed to be put into the system, right?
Staff replied that that is correct. He stated further that close to twice the
amount of copper went into the system so why do we care when it went in? Rich
commuted that it could have actually been more than that rather than less.
Director Stanton asked if a sample was taken every 15 minutes for 24 hours? Was
told that is correct. He indicated that a "representative sample" is not a term
that has an onerous conitation. You have representative samples in every part
of life. A lot of conclusions are based on representative samples. Unless
there is a production cycle that is as short as 15 minutes, then every 15-minute
sample has got to be a very representative sample. Asked if there is any
evidence whatsovever that there is a 15 minute cycle and sonehw hit the peak or
the valley? Kelly said there is no evidence and from our experience there is
not a 15-minute cycle.
os
-2-
Griset asked what the argument would be against a proposal to waive this fee
subject to installation of a flow proportional system? The General Manager
replied that it is purely at the discretion of the Board. The General Counsel
nay want to comment further on this. Blake Anderson added that if flow
proportional sampling was allowed at Universal, this would give us no better
representative sample of what happened prior to this. .Would need to compare the
..i two systems at the same time to draw some conclusions. Tom Woodruff commuted
that Mr. Ryan didn't own Universal Circuits so probably couldn't commit to the
decision to go to flow proportional sampling. These will be a time lag to
design and construct the system also. He added that the Districts have always
taken the position that we do not design a system. We provide assistance in
the form of some informational manner but it is not up to the District to design.
Griset asked how long it would take to design and install the system. Rich
estimated 2-3 months total.
Director Hanson stated that the purpose of this meeting is to decide whether
Universal Circuits should pay the bill levied against them. The District has
for the past many years used this method in dealing with other companies and has
levied fines. The purpose of this meeting is to decide to continue with the
fine or rescind it. Said he thought we should continue with the fine and should
decide which method of testing to use in the future.
Director Hoesterey added that he thought we are using industry's standard
measurement for sampling discharge. If the company wants to go to flow
monitoring, they should do that. We are talking about an incident last October.
He didn't see that there was a variation of discharge that shows any lack of
credibility re sampling standards. Just aren't any facts that say that the
sample was inaccurate.
Hoesterey MXM to let the fine stand as it is. Stanton SECONDED the motion.
Griset opposed the motion. Said he would prefer a motion that makes the company
v install a new system with 90 days. Would argue that there is enough doubt
without taking anything away from our standards. He thought this type of motion
would provide an incentive to get a system that is scud. Should waive fee
subject to installation within 90 days. ROLL CALL. VOTE on motion. KriTON
CARRIED.
v
-3-
S w.rn Z.a Sr.L.
A waSTe oarer sa.r`? te oa-s ccaeereed ar omvers4l
Crec'j ` cs $ I or. oct. 2A , A Sy. _Tkl�s sample
ar\d� f.( e n.on - cam? Cianee. Fee of 1Ifo , —
( S T6 SA'ecl of -N,i%s appeaa
u ni 4cesa.L kas been mu, ✓'e.spoms b CiTi
ty, recJard -10 (rmspecTi on I so rnp CI•r\I
�51nce .�Jnt , Iq $ 2 .
anol e46rceme► t . �e "ptcTor wino
coUttXeA the sw-^p(e wS under w.I
SuPtrJision . _,f{e used --Eke- DtSTricZs
STO.md,Wd� cau ro w\os%-r_ S o v^ p U v 5 e j �?me nT
wkee-h c.oCCecTed outmost 100 &-\aq'vidLj&K
so.rnp(es djrir� -tow_ 24- hour period .
?ri o r To "e. , -t�e er& p mernT L v z ?✓o ?.e✓ I
C(ear% et& 0.C.co rcU r\,S t,6 2sTobCished pro cedo re s .
ONr' LI)o.-S Se-1 0? QT 0. Sa e\ � le boX
� ' roJided b� UniJcrSaL s?ec F'ic-a((L, For Sam? U^
c }aSTec.�aTer. Cln�ver5cl's rePresermav ne, Mr. RLIow ,
oJaS accorded a.LC rl' Ks ands pry%ri leys due k;m
our es'Cabl�shed Feld �rocedores . Mr.
ha.d� ►tio ob�eaTi'en 'to our �rac.edur•e5 e.
t t:�5�tcTor re.Tu rn e d a F'rtrr 284 h Dots
_- -- - ------------
._ _
-Eo CaC(e.c.,T -tV►e Saw.plc�. and_ u5,ed aC� o..��r-o�r�`aXe
���cr�� �ro��res. Ne. dcTcrM�ned the c,�e�SaT'er c�as
F(otsi�q GOrtT�hJOJS�y �raJgll �t Sample bex
durirv� -t #- ire 24- hour geHaJd- Me cerhpa^ Is
re�resen�a'r�de 5'CaTe.d � aT fl.� t�1�te, Eho�' producTibn had
bean torMmvouS o1Jr 'rt The saxAe. per ool .
l�Sir� -Ehjs Cr\Form &Ttbr� , `tie CnspecTor
mi x,e-A o-CL or fhe CV%.To
o, Sir�le C.om posiTe. sornple. which c,-)as
50 b m ttrea -to o o r (aborCori for a^4ns�s -
7�e analysis sh.aczeol -tkC Uvv%tiersal w&.S
( r\ von-cow\ pli once . 7V\e cal.co L41-to, cUse-karJce��
W&$ H -H lbs of copper - vnore `tko ^ double
-TAt'S nori-cornpUm\ce rtsoltfa �n a- Pee
Op 0 I(08 . -) uAre \ i s b ta'v�c� a-pPto.Led rto r%kT.
S �.or-l1� aFter `tfe Sa,h�l e r��l-Cs Gams L h �
mr� Nov. I°►sy ) I mode o_ ro((OL3- up c:nspecTion .
`J 1. rwAtfsa..l �s 0. Fairly -t1Ol,c4j crrcuY- board,
W\0.11J Fa.GTJ ✓L✓ ` kOT they �r•oclJGe
�o�roe q�ar.T�'ties o� non-se�,ae✓able wasTa
p✓od�cTs . In Jn�Jersa.�'s case. , mos'r of -f'h�'S
wasTe eS hcwled awa� ortrecLTe-ol . g-T
Spills �d S�S�ew� Leeks c�enerolL� go
to a^ unde✓younoL koldir5Tonk cik"c.k
77
ou- eA -Lht f(oor boards o P
s ko p , `Me t&v\k. c,)as eV% ppedl Li iTk
�J VA pIJ ►hb i no, and val vrs srT up -to o lloci
tke e.MpT..li nc� of 1��`5 tank olire.ctl,,l to
flat cla.ri'Piu and. sojo% ple- bo)k . :..
I 'Yh Complote^r) Prom v"%, tv�JesTic�a4� bn ,
t�&T a C%'ke.Ly source of -11 e- v on-coJJ,n �� ance
Was a do schar f- 'Pro M file urAev�yourcL 'ra►,k.
SubseVer,-T `t�,i5 O�iscOJ�fy 17�STrtGTs
CnS�rJGCeoL Uni"/ersal to CVS$ Am4r tke ao'k.
'rkc company Cn ti aUvi obiecTed b vT
u (VrAaTtl%, comp e& w iT . 'tie. croL.e.r.
Jh discossl'ons (it-ck vh;Jersal "OUT rti,is
aPpeai j t e i-srricTs sTaeukarcL prac'rte-e_ of
timt - coMpost`re so, ?( en j has beer �uesToohed.
-TT�t 17�s�r rcTS sTar,F response- I\aS beev. `tfie' -
— 1�e -Ci wl2- C.oM'�oS�T2 ►+�eT4.od � why c� w�5
JouJ s t.`sed o.T om *-,rtrsal is represe ,-To-rive o�
tl�e �asie ��tr d�setiar�e i ar.d 's o-
GoST- e�FecT,'Je o.not e4v .Table w\eT6.od t^or
Sc�w\�le collecT,•or� . Ivy Ig83 � 'th�s w�,e�od
Was -tke sjbjec'f of disctjss,ov\ b� tke
I4usrre'ol (.Jas(e- AcUjtsorj Co► mitree. ) of
cJh�ek C.;rtims, represerkToT, e ,
Mr, &or ��av\ , Ws-S an o•tTtve. member.
Al-ttrno-i des ) f C-10cLC r.5 �'(a,,J-�ro�orT,br�gl me Gas)
(o erc oUs e. u ss eA . $,J`T -H\c com M l'ree!s cor\c.l os i o r\
w s 1-6T 14 -ex,)STir j f,_nt - cc p4sMe rn od
c-\,as re� reser�T�T,'Je 2Conorn �ca.l and dQ.s�rec\hle
over o`f er mtT ods.
—fhe 17 sQr�js sTo.PP has opFered to Uv%,versai ,
o A to aL.0 p e-rm tTe e s , the opTeovi to irsTa.L(
an ePPluertT F(ou3-monMrrrst s1s:em .7his
Would aU.oeJ E'or Flow - properTi`or�al Saw��(iv�.
To dare UnI /le.Irsa t homes e.(,ec.Ted ►1oT to "TaC(
`tk(As ev �p m evxT
Cn su mvno..r',-) , 'Eke Sample of OcT 24 j IgSH
aJ c,S Ca((ecTed Cv\ 0- m o n per ConS is rertr'
w ilix 47lsir�cTs Po (rcn . Uv,;versol haul po objeIrior�
-to `the procedure uA ( von-cnr"p(�ante Was dzTev-�n Heal
Ti I itTrt'Js. 0rdir Ae-e prav4es ire See.Tibr\ 501, 2a
1laT .� Sa.nn�le taker\ Prom a. Scn^ple boX cr-
-' o'Tl�er repreSen'CaQ"�vie t,o "T'i`o h CS pre.5�vKed
-to be d%s c.1,\n r,nn -to 'the �o b G`c Ste per• .
VesTi oA w&s cower-Ted,
Lr\ Such a M o v\ m e.r .
Fihc�ll� , CPkel� source of -(ire v�or\-corl�l�al�c
c�a5 a ko(dir\A� rte.^k haVl*rt COhnecTOOKS
Ev tl\.e seti•er tjk&h Were CVO vi olaT�l9r ol=
'tf e 17. ,3trr;cTs o-rck%^o rice ) secgb r\ 3_,. 1 A
cP DilCr�cls sToPP t6T -{6 ? oa rck de►-,
Un►%WS&L crew I cs' a�PtA.t of *t .e
t;►��o i ce �ro-r � 116� , —
Fottot.. i rAn 1Z�a�w'S ?ft5ehtotior\ , cJL cOM b,
P P'1 to pro v 40- :-EO 'tl a OieecTars a.r`i deTw t
Op our F'ie.td,_.�roe edurt and SpecF�t. eX per i encesr
0.T Unit SG.I Gt�c��TS• 7T-, k..le�
COUNTY SANITATION
DISTRICTS NOS. 12 27 32 5162 71112 AND 13
OF
ORANGE COUNTY, CALIFORNIA
ADJOURNED REGULAR MEETING
ON
SEPTEMBER 25, 1985 - 7: 30 P.M.
01TATIC V
A.
'rrnc� 195a �{
ORq'�/G8 co%3
ADMINISTRATIVE OFFICES
10844 ELT, AVENUE
FOUNTAIN VALLEY, CALIFORNIA
,,/joint Adjourned Meeting
9/25/85
DISTRICT 1 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 1 of
Orange County, California, and there not being a quorum of said Board
present, the meeting of District No. 1 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
DISTRICT 2 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 2 of
Orange County, California, and there not being a quorum of said Board
present, the meeting of District No. 2 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
DISTRICT 3 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 3 of
Orange County, California, and there not being a quorum of said Board
1.r present, the meeting of District No. 3 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
DISTRICT 5 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 5 of
Orange County, California, and there not being a quorum of said Board
present, the meeting of District No. 5 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Invevtigation/Feasibility Study.
DISTRICT 6 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 6 of
Orange County, California, and there not being a quorum of said Board
present, the meeting of District No. 6 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
�..r on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
Joint Adjourned Meeting � ✓
9/25/85
DISTRICT 7 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 7 of
Orange County, California, and there not being a quorum of said Hoard
present, the meeting of District No. 7 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
DIS'1RICr ll This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 11 of
Orange County, California, and there not being a quorum of said Hoard
Present, the meeting of District No. 11 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
DISIRICr 13 This 25th day of September, 1985, at
Adjournment of meeting by 7:30 p.m, being the time and place for
Secretary the Adjourned Regular Meeting of
County Sanitation District No. 13 of
Orange County, California, and there not being a quorum of said Hoard
present, the no-sting of District No. 13 was thereupon adjourned by the
Secretary to 7:30 p.m., Wednesday, October 2, 1985, at the Districts'
administrative office for a presentation by Department of Health Services
on the Draft Interim Report: Stringfellow Facility Remedial
Investigation/Feasibility Study.
Secretary, Boffifds of Directors
County Sanitation Districts Nos. 1,
2, 3, 5, 6, 7, 11 and 13
-2-
Q °-
" " COUNTY SANITATION DISTRICTS
OF ORANGE COUNTY, CALIFORNIA
a P.O. BOX 8127,FOUNTAIN VALLEY,CALIFORNIA 92728-8127
10844 ELLIB,FOUNTAIN VALLEY, CALIFORNIA 92708-7018
(714) 54P2910 (714)882-2411
SEPTEMBER 19, 1985
NOTICE OF ADJOURNED REGULAR MEETING
COUNTY SANITATION DISTRICT NO. 1
WEDNESDAY, SEPTEMBER 25, 1985 - 4:00 P.M.
10844 ELLIS AVENUE
FOUNTAIN VALLEY, CALIFORNIA
PURSUANT TO ADJOURNMENT OF THE REGULAR MEETING OF SEPTEMBER 11,
1985, THE BOARD OF DIRECTORS OF COUNTY SANITATION DISTRICT N0. 1
WILL MEET IN AN ADJOURNED MEETING AT THE ABOVE HOUR AND DATE.
E ETARY
BOARDS OF DIRECTORS
County Sanitation Districts vest orem Be. e127
OF Orange County, California 10844 Ellis Avenue
Fountain Valley, Calif., 92708
Tekol -
Am Cede 714
DISTRICT No. 1 962_24;0
AGENDA
ADJOURNED REGULAR MEETING
WEDNESDAY, SEPTEMBER 25, 1985 - 4:00 P.M.
(1) Roll call
(2) Consideration of appeal of Universal Circuits, Inc. re General Manager's
denial of their request for waiver of Invoice No. 819709 for non-compliance
fees in the amount of $1,168.00 re Industrial Waste Permit No. 1-346):
(Separate Staff Report enclosed with Directors' agenda material)
(a) Verbal staff report
(b) Consideration of motion to receive and file Staff Report dated
September 19, 1985, re appeal of Universal Circuits, Inc.
(c) Response by Universal Circuits, Inc.
(d) Discussion
(a) Consideration of action on appeal of Universal Circuits, Inc. re General
Manager's denial of their request for waiver of Invoice No. 819709 for
non-compliance fees in the amount of $1,168.00
(3) Other business or communications, if any
(4) Consideration of motion to adjourn
I
MANAGER'S AGENDA REPORT
County Sanitation Districts Post Office Box 8127
of Orange County, California 10844 Ellis AvenueFountain Valley, Calif., 92708
T AmC Codde o . 714
DISTRICT NO. 1 9622411
MANAGER'S REPORT TO DISTRICT NO. 1 DIRECTORS
MEETING DATE: SEPTEMBER 25, 1985 - 4:00 P.M.
Item No. 1. Consideration of Universal Circuits Inc. 's Request for Waiver
of Non-Compliance Fees, Industrial Waste Permit No. -346.
Universal Circuits, Inc. has appealed the General Manager's denial of
their request to waive non-compliance fees in the amount of $1,168.00.
At the last Board Meeting the Directors deferred consideration of
Universal 's request to an Adjourned Meeting on September 25, 1985 at 4:00 p.m.
immediately preceding the Executive Committee Meeting.
Enclosed with the Directors Agenda is a summary staff report concerning
the non-compliance fees assessed against Universal Circuits, Inc.
COUNTY SANITATION DISTRICTS
of ORANGE COUNTY.CALIFORNIA
September 19, 1985 P.O.BOx8127
REFS173 IOW ELLIS AVENUE
FOUNTAIN VALLEY.CAUFORNIA92708
p14I8162910
STAFF REPORT (714)9622411
UNIVERSAL CIRCUITS INC. , t1
REQUEST FOR APPEAL
Invoice R819709 ($1,168.00)
BACKGROUND
Universal Circuits, Inc. is a printed circuit board manufacturer operating under
Permit No. 1-346, located at 1800 Newport Circle Drive, Santa Ana, Ca 92705.
During October 23 and 24, 1984 a routine sample was taken from a sample box as
shown in Figure 1. The sample probe was positioned below the minimum water
level inside the sample box, and withdrew a sample every 15 minutes. The sample
was collected and composited after 24 hours in the presence of a company repre-
sentative, in accordance with District's procedures. A flow of 108,000 gallons
per day (GPD) was recorded for the 24-hour sampling period. This flow is
greater than Universal 's 1984 average flow of 103,000 GPD; indicating production
and continuous discharge had occurred during the entire sampling period.
Therefore, the inspector appropriately used all 24 samples in the composite.
There was no objection from the company representative. The sample analyses
showed a concentration of 8.8 milligrams per liter copper and a calculated 7.9
pounds per day which is 4.4 pounds per day over Universal 's limit.
The discharge was in violation of the firm's permit limitations for copper and
lead and the firm was assessed non-compliance charges in the amount of $1,168.00
(Attachment A).
During a follow-up inspection on November 20, 1984, the company representative
stated that the non-compliance may have been caused by a discharge from an
underground holding tank which had pumps, plumbing, and valves configured to
allow such a discharge. On December 3, 1984, the Districts notified Universal
that access to the sewer from the underground tank would not be allowed, and
that all connections were to be terminated. Mr. Gary Ryan, Universal 's repre-
sentative, argued that the system was acceptable because of the presence of a
manual valve which .gave them the option of sending non-sewerable waste into
another holding tank and that all wastewater discharged from the tank was tested
prior to discharge. When asked if a District's representative could see the
test records, Mr. Ryan said he had no obligation to do so, and declined. When
questioned further, he admitted that there were no test records. On January 7,
1985. Universal complied with the Districts order to terminate connections from
the underground tank.
Between November 26, 1984 and Janurary 25, 1985, Universal filed a formal appeal
(Attachment B) with Districts' General Manager regarding the sample in question,
contending that:
1. The sampling probe placement during this sample (see Figure 1) is dif-
ferent. than what had been used previously (see Figure 2) , thus yielding
. i two different results.
-1-
Staff Report
Universal Circuits
September 19, 1985 v
Page 2
2. There was limited production during the third shift using two spray
rinses and two running rinses such that wastewater was flowing only 10
minutes out of every hour and the sample probe would have sampled a
static solution.
3. Because the flow was variable a flow proportioned sample should have
been used, thus the time proportional sample is not representative.
Following an extensive review of Universal 's contentions, on May 20, 1985
(Attachment C) the Districts' General Manager denied Universal 's appeal for the
following reasons:
1. The sample was collected in a proper manner and in accordance with
Districts' sampling procedures. Article 501.2E of the Districts'
"Regulations for Use of District Sewerage Facilities" provides that
"Any sample taken from a sample box or other representative location is
presumed to be discharging to the public sewer."
Both methods of placing the sampling probe in the sample box have been
used at Universal , and both are within guidelines for collecting a
representative sample.
2. Time proportional sampling is representative of industrial wastewater
discharges and is a cost-effective and equitable method of collecting
samples to determine compliance with discharge regulations. The capi-
tal equipment required by industry to allow the Districts' staff to
collect a flow proportional sample is estimated to be $10,000 per
industry and $500 per year in calibration and maintenance cost.
Further investigation by Industrial Waste Division has found that Universal 's
standard practice is to use running rinses continually such that there would be
a continuous flow (estimated to be 10 gallons per minute) through the sample
point. Thus, the sample box would not be static and a time proportional sample
would be representative of Universal 's discharge.
On May 30, 1985, by form of a check in the amount of the appeal filing fee
(Attachment D) , Universal filed a formal appeal to the Board of Directors of
District No. 1 for a final ruling on the appeal . Universal has paid invoice
#819709 in the amount of $1,168.00.
Since August 14, 1985, the District's staff have been in contact with Universal
several times to discuss the technical concerns of the sampling method. No
resolution to the differences was found.
-2-
� r
Staff Report
Universal Circuits
September 19, 1985
Page 3
DISCUSSION
The District has required that each permittee shall provide a sampling loca-
tion. Many permittees have a sample box similar to that shown in Figure 1, have
been sampled using time proportional samples, and have used both methods- (Figure
1 and Figure 2) for sample probe placement. Samples taken by either method have
been accepted by the Districts, and by other permittees.
It could be argued that time proportional sampling will not be as representative
as flow proportional sampling under conditions of widely fluctuating flows.
However, flow proportional sampling is less likely to detect a batch dump
discharge during low flow periods. The Districts' staff had previously offerred
Universal (and all industries) the option to install an effluent flow monitoring
system for flow proportional sampling. To date Universal has not installed a
flow monitoring system.
Time proportional sampling is an EPA recognized method of sampling wastewater
effluents. Because of the expense to industry required for flow proportional
sampling, the Districts will continue to view the time composite sample as
representative of the actual discharge from industries within the District as a
v cost effective and equitable method of administering the Districts' discharge
regulations.
ALTERNATE BOARD ACTIONS
Three options available to the Board of Directors are:
1. Deny the appeal sustaining the staff's findings that the sample was
representative and the non-compliance fees should be paid.
2. Uphold the appeal and declare that the sample was not representative
and the non-compliance fees should be waived.
3. Determine that the non-compliance fees should be modified to a reduced
amount.
STAFF RECOMMENDATION
It is the recommendation of the Districts' staff that the Board deny Universal
Circuits' appeal on the grounds that:
1. The sample was collected in a proper manner as specified by the
Districts' procedures.
-3-
Staff Report
Universal Circuits
September 19, 1985
Page 4
2. The Districts' Ordinance provides in Section 501.2B that any sample
taken from a sample box or other representative sample location is pre-
sumed to be discharging to the public sewer. This sample in question
was collected from the sample site provided by Universal Circuits.
3. Subsequent data collected by Districts' staff confirms that the sample
was representative.
The staff will make a formal presentation to the Directors at the Board Meeting
and representatives of Universal Circuits will have an opportunity to present
their case before the Board considers a decision based on the above options.
4-
Figure 1 . Universal Circuits , Inc .
Standard Sampling Method
flow
to OCSO sewer
Approx.
water level
Sample unit
Figure 2 . Universal Circuits, Inc.
Alternate Sampling Method
flow to OCSD sewer
Approx. Sample unit
water level
COUNTY SANITATION DISTRICTS `� `' :AEA 11.0;
s;rL �;
OF ORANGE COUNTY, CALIFORNIA 54D-2BI1
���` 540-241
P. O. BOX 8127, FOUNTAIN VALLEY. CALIFORNIA 9270B
10844 ELLIS AVENUE (EUCLID OFF-RAMP, SAN DIECO FREEWAY)
Noveter 8, 1984 Attachment "A"
REF# 262
Universal circuits #1
1800 Newport Circle Dr.
Santa Ana, CA 92705
Permit NO: 1-346
Attention: Gary Ryan
Subject: Non-Ccupliance with Discharge Requirenents
As'shown on the attached Wastewater Analysis Report(s) , your company was
discharging copper & lead in excess of your permit limitations.
An invoice in the amount of $ 1.168.00 is being prepared and will be sent in
the near fuhare for non-compliance fees applicable to this discharge. Please
advise your accounts payable office to process this invoice promptly when
received to avoid penalties.
Should you have any questions regarding this invoice, please feel free to con-
tact me or James Benzie at extension 252.
7
Richard W. von Langen, P.E.
Chief of Industrial Waste
RVL/JPB/g1
Enclosure
cc: Acccunts Receivable
IQWNI 1 j^141 I r I IU14 U JI n V
010 RANGE COUNTY,CALIFORNIA
RO.8OX812T
108"E W S AVENUE
FOUNTAIN VALLEY,CAUFORNIA 927C8
plat 54C 2910
p14)962-2411
Attachment "A" (cont'd)
WASTEWATER ANALYSIS INVOICE REPORT
R
INDUSTRY: 1'AWCV SA1 I DATE; lI
PERMIT NO: 1- 3'46 CONTACT: GrAy 1\ ^ VN
Your wastewater discharge has been sampled. The results are as follows:
Total Suspended Solids W. mg/l.
81Pchemical Oxygen Demand mg/l.
Condentrati on Discharge Permit Liml is Pounds Over Rate Per
Constituents W/1 Ibs/day lbs/day Limitation Pound Charge
CAGMIUM
CHROMIUM _
COPPER Q.8 7.11 3.S 4.y 200' 22oo �—
NICXEL _
LEAD Z.`d Z.S �_' � .8 IWO Z99
ZINC _
ON Q.S
Other _
Discharge Calculated in Permit .1140 MEG
w
Actual Discharge . q_2 MGO YITOTAL CHARGE I' (*S
Sample Oate(s): (O IZ3-Z4 jqY (Samples for
non-working
Time: G`Ia0 hours were
Sn� eliminated)
Location: 4+�+
Please address any Questions concerning this report to Mr. James Senzle, or myself in the
Industrial 'Waste Division at extension'2�2552..'f�`''��
Richard L. van Langan, P.E�.
Chief of Industrial 'Waste
RVL/de
Lab. so. p. New y
mil
Inspector r,.n
JNIVERSAL CIRL JITS INC .
(714) 640-3936'441W1800 EAST NEWPORT CIRCLE • SANTA ANA, CALIFORNIA 92705
Attachment "6-1"
November 26, 1984
Richard von Langan P.E.
Chief of Industrial Waste
Industrial Waste Division
County Sanitation Districts of Orange County
10844 Ellis Avenue
Fountain Valley, CA 92708
RE: Wastewater Analysis Invoice Report #819709
Dear Mr, von Langan,
The composite sample taken at Universal Circuits #1 facility on
October 23, 24 1984 is most likely not representative of our
wastewater discharge. It is believed that our third shift did
little or no production in our wet process area during this
24 hour period. The sampling device then received 7 hours of the same
contaminated wastewater which when composited produced the
unusually high concentrations.
Please consider this information and inform us if you agree ,
that we may disregard invoice number#819709.
Should you have any questions, please do not hesitate
to contact me at (714) 540-3936.
Yours t Irupl�Uy;'``
Gayan
Enviromental Manager
GR/mc
r
COUNTY SANITATION DISTRICTS [`��� A.E ZOO.
OF ORANGE COUNTY, CALIFORNIA \� 962.291-a411
9s21
�s
P. 0. BOX B127. FOUNTAIN VALLEY, CALIFORNIA 92708 Attachment 11B-211
10844 ELLIS AVENUE (EUCLID OFF-RAMP. BAN DIEGO FREEWAY)
January 21, 1985
REFS 410.
Certified Mail - P710597231
Return Recgipt Requested
Universal Circuits b1
1720 Newport Circle
Santa Ana, CA 92705
Permit No.: 1-346
Attention: Mr. Gary Ryan, Environmental Manager
Subject: Request for Appeal
The Districts are in receipt of your letter dated January 2, 1985 requesting
appeal of Invoice #819709. This invoice, in the amount of $1,168.00, was
for non-compliance with permit limitations resulting from a routine sample
taken on October 23-24, 1984.
In order to substantiate your appeal and to form the basis upon which an
appeal can be considered, it is necessary for you to submit additional
written information to support your position. The information provided
in your letter of November 26th is incomplete and, thus, inadequate.
Once this requested information is received, a meeting to consider your
appeal can be set. If we do not receive the requested information within
15 days of the date of this letter, we will assume that you do not wish
to appeal Invoice #819709.
irkaanager
ester
JWS:RvL/jb
■gam. UNIVERSAL CIRCUITS INC .
(714) 540-3936 1800 EAST NEWPORT CIRCLE • SANTA ANA, CALIFORNIA 92705~
January 25 , 1985 Attachment "B-3"
J. Wayne Sylvester
General Manager
County Sanitation Districts of Orange County
10844 Ellis Avenue
Fountain Valley, CA 92708
RE: Request for Appeal
Dear Mr. Sylvester,
In response to your request in a letter dated January 21, 1985 ,
I am submitting additional written information in regards to the
appeal of Invoice #819709. The appeal is based upon the composite
sample not being representative of our wastewater discharge on .
October 23 to October 24, 1984. Please consider the following
points:
1) The sample probe was placed in an area that would be
static during periods of time when we used no water.
Dale Roverman of I.W.D. was told prior to leaving the
.. probe in this position that his Supervisor (Kelly
Christansen) always placed the probe in the outfall
ine which would be empty during periods of time when
we used no water. Therefore, two representatives of
the Districts would have obtained samples that would
vary greatly even when sampling the same waste stream
during the same time period.
2) Third shift (12AM to 7AM) informed me that on the
morning of October 24, 1984 only copper and solder
electroplating was operated. Under these conditions
only 2 spray rinses and 2 overflow rinses would operate
r ) for perhaps 10 minutes each hour. The wastewater
r from these rinses would be much higher in concentration
than our normal effluent due to the lack of other process
rinse water that normally dilute the concentration.
Therefore, it is estimated that 50 minutes out of each j
hour during this morning the wasterwater was static.
3) The following is copied from the United States
Enviromental Protection Agency, Monitoring Industrial
Wastewater, Chapter 6 Sampling. ' There are several
pit a s which can occur if sampling is performed in
a careless or naive manner. Obtaining a sample which
is truly representative of the wastestream, may be the
... source of significant errors. It must be remembered
that waste flows can vary widely both in magnitude and
composition over a 24-hour period.
Page 2 Cont,— Attachment "B-3" (cont'd)
The amount of the individual sample that may be added
to the total mixture depends on the flow at the time
the sample was taken. When the flow is nearly constant,
the non-proportional sampler is sufficient for collecting
a composite sample. " Therefore, the sampling methods
used by the Districts is not in accordance to E.P.A.
guidelines and the sample taken October 23 to October
24, 1984 is not representative of our wastewater discharge.
• Should you have any questions or need additional information
please do not hesitate to contact me at (714) 540-3936.
Your truly,
V
Gary4 yan
Enviromental Manager
GR/mc
COUNTY SANI . ATION DISTRICTS
OF ORANGE COUNTY, CALIFORNIA 962 2411
�.a P. 0. BOX 8127, FOUNTAIN VALLEY. CALIFORNIA 92728-8127
10844 ELLIS AVENUE(EUCUO OFF-RAMP. SAN OIEGO FREEWAY)
May 20, 1985 Attachment "C"
Universal Circuits, Inc. i1
1800 East Newport Circle
Santa Ana, CA 92705
Attention: Gary Ryan
Re: Permit No. 1-346--Request for Appeal
Gentlemen:
County Sanitation District No. 1 of Orange County, California ("District") has
:onsidered the facts giving rise to Universal Circuits, Inc. K ' s ("UCI") appeal
of Invoice No. 819709. Invoice No. 819709 pertains to noncompliance fees
applicable to routine sampling conducted at UCI on October 24-24, 1984. The
appeal of the aforementioned invoice is denied on the following grounds :
1. Article 501.28 of the District' s "Regulations for Use of District
Sewerage Facilities" (hereinafter the "District' s Ordinance") provides
that:
"Any sample taken from a sample box or other representative sampling
location is presumed to be discharging to the public sewer."
The sample which gave rise to Invoice No. 819709 was taken from the
sample box located at UCI 's facility and is therefore presumed to be a
representative sample of UCI ' s discharge into the District' s sewerage
facilities.
2. The Districts' Industrial Waste Division utilizes time composite
samples collected in the performance of routine sampling duties as
required by the District' s industrial pretreatment program, approved by
the Environmental Protection Agency on January 4, 1984. The District
will continue to view the time composite sample as representative of
the actual discharge of industrial dischargers within the District as
it is a cost-effective and equitable method of administering the
District's discharge regulations.
Universal Circuits, Inc.#1 Attachment "C" (cont'd)
May. 20, 1985
Page 2
Flow-proportioned sampling is available for those industries that elect
to install flow meters. A flow metering system must include a primary
flow element, a flow metering device and an electronic totalized flow
pulse to signal the District' s sampler. All plans for a
flow-proportioned sampling system must be reviewed by the District' s
staff prior to installation. The estimated capital cost of such a
system is approximately. $10,000 with an annual maintenance and
calibration cost of $500.00. If UCI chooses to install a flow metering
system, the District' s Industrial Waste Division staff will collect
flow proportional samples from your facility.
Please be advised that Invoice No. 819709 should be processed promptly to avoid
the imposition of penalties. Should you have any questions regarding this
matter, please do not hesitate to contact Jim Benzie at extension 252.
Very truly yours,
COUNTY NITATION DISTRICTS OF
ORANG OUNT CALIFORNIA
J W eM
TW:JWS:aa
r
• Attachment "D"
_ DETACH AND RETwIN THI$`Sf.TEMEWW
Uq/ERSAL CIRCUITS. INC. - -'T'
' - e CELUXE FORM WVC4 vV-R
DATC ' - - ocociiPTI.m ZZi 4a�wt��
5/30/85 "Appeal of Invoice n819.709 $1000'06'_ v
_ .. .. !�/�%� ✓ /' .-\ice
MEETING DATE SEp[. 25, 1985 TIME 4:00 P.m. DISTRICTS I
DISTRICT 1 JOINT BOARDS
(CRANK).. .. .. ..HANSON.. .... ✓ (THOMAS/MANDIC). .BAILEY..... .
(SALTARELLI)...HOESTEREV... (WISNER).. .......BEVERAGE...._
(LUXEMSOURGER).GRISET.. .... (2iEGLER)........DUCK........
_
pit (WIEDER).. . ....STANTON..... (NORBV)..........CATLIN......�
(NELSON).........COOPER. .....
DISTRICT 2 (PERRY)..........CULVER...... _
(SALTARELLI).....EDGAR.......
(NORSY)........CATLIN......� (JARRELL)... .....GRIFFIN.....
(ZIEGLER)......BUCK........ _ _ (LUXEMBOURGER)...GRISET.. ....
(NELSON).......COOPER. ..... _ (CRANK)......... .HANSON......
(LUXEMBOURGER).GRISET......_ _ _ (COX)............HART. .......
(SILZEL')...... .KAWANAMI...._ _ _ (SALTARELLI).....HOESTEREY..._
(WEDEL)........MAHONEY.....� _ _ (SILZEL).........KAWANAMI...._
(SCOTT)........NEAL...... .. _ _ (WEDEL)..........MAHONEY.....
(CULVER).i.....PERRV.......� _ _ (COX)............MAURER. ..... _
(OVERHOLT).....ROTH........ (SCOTT)..........NEAL........
(BEYER)........SMITH....... _ _ (COOPER).... .....NELSON. .....
(WIEDER)...... .STANTON.....� _ _ (FINLAYSON)......OLSON.......
(BEVERAGE).....WISNER......_ _ _ (KANEL)..........PARTIN......�
(CULVER).........PERRY.......
DISTRICT 3 (COX)........... .PLUMMER.....
(COLLINS)........POLIS.......
(OVERHOLT).....ROTH........ (BROWNELL).......RISHER......
(COOPER).......NELSON...... _ _ (OVERHOLT).......ROTH.. ......
(THOMAS).......BAILEY...... (SIRIANI)........SAPIEN. .....�
(NORBV)........CATLIN....... _ (BAKER)..........SILLS.......
(PERRY)........CULVER......� (BEYER)..........SMITH.......
(JARRELL)..... .GRIFFIN..... _ _ (WIEDER).........STANTON. ....
(LUXEMBOURGER).GRISET......_ _ _ (SELVAGGI).......SYLVIA...... _
(WEDEL)........MAHONEY..... (FINLEY)........ .THOMAS......
(SCOTT).. ......NEAL........ _ _ (GALLACHER/GREEN)WAHNER......_
(FINLAYSON)....OLSON......._ _ _ (BEVERAGE).......WISHER......
(HANEL)........PARTIN......�
(COLLINS). .....POLIS . .....
(BROWNELL).....RISHER...... _
(SIRIANI)......SAPIEN......_
V' (NIECE R).......STANTON.....
(SELVAGGI).... .SYLVIA......
DISTRICT 5 STAFF. SYLVESTER...✓
CLARKE. .....
(COX)..........HART........_ — _ DAWES.......5
(COX)..........MAURER...... ANDERSON...._
(WIEDER).......STANTON..... _ _ BUTLER.. ....
BROWN......
DISTRICT 6 BAKER.......
KYLE........
(GALLACHER)....WAHNER.... .._ — _ YOUNG.......
(COX)..........PLUMMER..... _ _ VON LANGEN _L✓
(WIEDER).......STANTON.....� _ _ NINSOR.. ....
STREED......�
DISTRICT 7 CLAWJ,,aL. 0444%1�_—
(SALTARELLI).. .EDGAR.......
_ ��aAAf�C�
(BAKER)........SILLS....... _ _ OTHERS: WOODRUFF....✓
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(COX).. . .......MAURER......_ _ _ HOHENER.... .
(BEYER)........SMITH....... _ _ HOWARD......
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9/11/85 (REVISED)
COUNTY SANITATION DISTRICT NO. 1
OF ORANGE COUNTY, CALIFORNIA
MINUTES OF ADJOURNED REGULAR MEETING
September 25, 1985 - 4:00 P.M.
10844 Ellis Avenue
e.d Fountain Valley, California
Pursuant to the adjournment of the regular meeting of September 11, 1985, the Board of
Directors of County Sanitation District No. 1 of Orange County, California met in an
adjourned regular meeting at the above hour and date in the Districts' Administrative
Offices.
The Chairman called the meeting to order at 4:00 p.m. The roll was called and the
Secretary reported a quorum present.
DIRECTORS PRESENT: Robert Hanson, Dan Griset, Ronald B.
Hoesterey, Roger Stanton
DIRECTORS ABSENT: None
STAFF MEMBERS PRESENT: J. Wayne Sylvester, General Manager, Rita
Brown, Secretary, Blake Anderson, Rich von
Langan, Gary Streed, Kelly Christensen
OTHERS PRESENT: Thomas L. Woodruff, General Counsel, Suzanne
Atkins, Gary Ryan, Paul Torres
t sr a + r. + a a s ,r a ,r
Denial of appeal of Universal The Chairman declared that this was the
Circuits, Inc. re request for time and place fixed by the Board to
waiver of invoice for non- consider Universal Circuits' appeal of
compliance fees re Industrial the General Manager's denial of the
Waste Permit No. 1-346 firm's request for waiver of Invoice
No. 819709 for non-compliance fees in
the amount of $1,168.00 regarding Industrial Waste Permit No. 1-346. Chairman
Hanson then called for a staff report.
Verbal staff report Mr. Kelly Christensen, the District's
Industrial Waste Inspector, reviewed
and summarized the written staff report dated September 19, 1985. He
reported that the wastewater sample collected at Universal Circuits No. 1 on
October 24, 1984, had been collected in accordance with standard sampling
procedures in effect since 1976. The Industrial Waste Department routinely
samples industries approximately four times a year. Samples are taken every
15 minutes for a 24-hour period. The non-compliance fee of $1,168.00 was
based on a calculated discharge of 4.4 lbs. of copper over their permit
limitation which is more than double the allowable limit. He indicated that
he believed an underground holding tank to be a likely source of the excess
copper discharged into the sewerage system.
Universal Circuits has contended that the samples taken from their facility
were not representative. Mr. Christensen explained the time composite
sampling method. The District's Industrial Waste Ordinance states that any
sample taken from a sample box or other representative location is presumed
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9/25/85
to be discharging into the public sewer. In 1983 this sampling method was
discussed by the Industrial Waste Advisory Committee, of which Mr. Ryan of
Universal Circuits was an active member. Alternatives, including the
flow-proportional method of sampling, were discussed but the Committee
concluded that the time-composite method was representative, economical and
the most desirable method of sampling. However, all permittees have the
option of installing an effluent flow-monitoring system so that
flow-proportional sampling can be conducted by the Districts. To date
Universal has elected not to install this equipment.
The staff recommended that the Board deny the appeal of Universal Circuits,
Inc. re Invoice No. 819709 for non-compliance fees in the amount of
$1,168.00.
Receive and file Staff Report Moved, seconded and duly carried:
That the Staff Report dated September 19, 1985, relative to the appeal of
Universal Circuits, Inc. , be, and is hereby, received and ordered filed.
Response by Universal Circuits The Chair recognized Mr. Gary Ryan,
representing Universal Circuits, who
addressed the Board. He disagreed that the likely source of the excess
discharge was the underground holding tank and indicated he believed he was
being criminally accused. Mr. Ryan stated that in his opinion a
flow-proportional sampling system would be the only way to accurately measure
effluent discharged, and that the non-compliance charges should not have been
levied against Universal Circuits based on the time-composite method of
sampling. He reviewed maximum flow rate variances that other agencies
suggest be used in determining whether a firm should be sampled on a
flow-proportional system rather than the time-composite method. He alleged 1,../
that the Universal's flow rates varied substantially and therefore the
flow-proportional method of sampling should be used. He stated that he had
requested information relative to the flow-proportional method from
District's staff. Mr. Ryan also expressed concern that he did not feel that
his appeal had been processed in a timely manner.
Discussion In response to Directors' questions
Mr. Rich von Langan, the Districts'
Chief of Industrial Waste, addressed the Board and reviewed the advantages
and disadvantages of using a flow-proportional sampling method versus the
time-composite method currently being used by the Districts, as follows:
TIME COMPOSITE FLOW PROPORTIONAL
ADVANTAGES
- Can detect batch dumps - More representative for highly
- Samples taken at regular intervals variable flows
- Inexpensive, simple
DISADVANTAGES
- Less representative for - Expensive, complex
highly variable flows - Difficult to detect batch dumps
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9/25/85
Mr. von Langan added that the Districts have been using time-composite
sampling at Universal Circuits since 1981.
The Districts' General Counsel assured Mr. Ryan that the case before the
\/ Directors was simply a dispute over an unpaid invoice and the District has in
no way implied that he was being criminally charged.
Director Dan Griset questioned the methodology used in obtaining the sample
from Universal Circuits and whether Universal should be sampled on a
flow-proportional basis. It was reiterated by staff that the cost of
installing a flow-proportional system was estimated at $10,000 per firm
versus about $100 for installation of a sample box for the time-composite
method. In either case, the cost is borne by the discharger, and it is the
firm's decision. The staff indicated that they would not object to Universal
Circuits designing and installing a flow-proportional system for future
sampling.
The Board then entered into a lengthy discussion relative to the sampling
procedure used at Universal Circuits and the accuracy of the representative
sample obtained over a 24-hour period on October 24, 1984. It was reiterated
that the composite sampler took samples at fifteen minute intervals over a
24-hour period. Unless there is a production cycle that is as short as 15
minutes, then every sample would appear to be representative. There was no
evidence that the firm has a 15 minute cycle, neither is it the norm for
production in the industry. Thus it could be concluded that the samples of
Universal's flow were at neither peak or low flow and therefore are
representative. Director Griset stated that the variables of sampling
accuracies can be argued and asked that consideration be given to waiving the
non-compliance fee if Universal Circuits agreed to install a
v flow-proportional sampling system within 90 days.
The Chairman then stated that the purpose of the meeting was to determine
whether to grant or deny the request of Universal Circuits for waiver of
Invoice No. 819709 for non-compliance fees in the amount of $1,168.00, not to
determine the method to be used in sampling.
It was then moved, seconded and duly carried by roll call vote:
That the Board of Directors do hereby deny the appeal of Universal Circuits,
Inc. relative to the General Manager's denial of their request for waiver of
Invoice No. 819709 for non-compliance fees in the amount of $1,168.00 re
Industrial haste Permit No. 1-346.
Director Dan Griset asked that his vote in opposition to the motion be made a
matter of record.
Adjournment Moved, seconded and duly carried:
That this meeting of the Board of Directors of County Sanitation District No. 1 be
adjourned to 7:30 p.m., September 25, 1985, for a presentation by the State
Department of Health Services on the Draft Interim Report: Stringfellow Facility
Remedial Investigation/Feasibility Study. The Chairman then declared the meeting
so adjourned at 5:16 p.a., September 25, 1985,
r.0
Secretary, BosYrd of Directors
County Sanitation District No. I of
Orange County, California
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