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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 .. .... ._ KYLE....... .JC (GALLACHER)....WAMNER....... _ _ \ YOUNG.. ....._ (COX)..........PLUMMER.....�_ / VON LANGEN JL (WIEDER).......STANTON..... / WINSOR. ..... STREED...... DISTRICT 7 CLAWSON. .. (SALTARELLI)...EDGAR..... .. ( X .. E ...... -_ � OTER : WOODRUFF (CO )... ....... MAURER...... = ATKINS...... = (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 . .... ... (BEYER)........STANTO .....may` (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....✓ (LUXEMSOURGER).GRISET......— _ — ATKINS..... .JG (COX).. . .......MAURER......_ _ _ HOHENER.... . (BEYER)........SMITH....... _ _ HOWARD...... (WIEDER).......STANTON..... _ _ HUNT........ (GREEN)........WAHNER.. ....— _ _ KEITH....... KNOPF....... DISTRICT 11 LE BLANC...._ LINDSTROM..._ (MANDIC).... .. .BAILEY...... _ _ LYNCH......._ (WIEDER).......STANTON.... . _ _ MARTINSON..._ (FINLEY). ......THOMAS......— _ _ PEARCE......� DISTRICT (NELSON)..... ....COOPER... ..._ (WIENER).......BEVERAGE. ..._ (OVERHOLT).... .ROTH........ _ (BEYER)... .....SMITH... . ..._ (WIEDER).......STANTON....._ 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 -1- 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 -2- 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 -3-