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HomeMy WebLinkAboutSP 144A; SDG&E Wastwater Facility; Specific Plan (SP)APPLICATION FOR COASTAL DEVELOPMENT PERMIT "'$& '* , f APPENDIX B' £'*'' V ' 'f< ,% '- LOCAL AGENCY REVIEW FORM tv k"<r'r f Pi y • ft [SECTION A (To be completed by-applicant)! \ J^O A°^^ Appl leant -SDG&E I • >j.^i-v--:--.^ '.- •••'•'•. -• V . ' Project description Demolition (grading) of existing Wastewater Treatment Ponds Location • Encina Power Plant ~- *t600 Carlsbad Boulevard • >l "Assessor's Parcel Number 210-010-33 .SECTION B (To be completed by local planning or building inspection department)! .Zoning designation : •••••' l/Uj&'JjfaJj&j ftj/'tf du/ac .' •. ' •: . . . ••-,,,, .,- ..( .. ;- ,, ,,;. ~~Q ~~ ^j ~~ General or Communi ,ty PI an desi gna ti on ' /AJ^i&w Mfl du/ac. ,.;, .,..;V- , ..__ . .-••:! ..^{ :•:.-, $ : -• . Local Discretionary Approvals . ' ; development meets all zoning requirements and needs no local permits other than building permits.- -/ Q'P'roposed development needs local discretionary approvals noted below. Needed Received ' . , " ''••".' DO Design/Architectural review. D D Variance for _ . ,_>-; ,.."-. ••\~ _ ,-^, '; • . _ • . •'-'; - ' -•-- ";; •. .-;.. ; -,..., ,.j& ; , " ""•" '- ~""--. ' ' ;O : D Rezone from • D 3- D . Tentative'Subdivision/Parcel Map No. _ _ ' [D^~ O Grading/Land "Development Permit No. _ _ O -D Planned Residential /Commercial Development D ft " Si te, PI an; Review , D: ' D Condominium Conversion Permit O \ . CU Conditional , Special , or Major Use Permit No. D:" "D ; -Other CEQA Status . ' .:" -•' ', '• Categorically Exempt - Class Item D Negative Declaration Granted .^ _____ _ __ Q Environmental .Impact Report Required, Final Report certified _ Prepared for the(pty)c.ounty of C0^^H^ byI / N^, ___ y —"* •' ........ •' ....... •...•^ " ..- . ^-^ Date i Title DATE: April 8, 1991 TO: File FROM: Adrienne Landers SUBJECT: Wastewater Ponds Removal; Environmental Review It has been determined by staff that the environmental review necessary for removal of the wastewater treatment pond removal is exempt from CEQA per Section 21000 et. seq. Public Resources Code, in accordance with Section 15321, Chapter 3, Title 14, California Code of Regulations. In addition, it was determined pursuant to Section 15051(b) of CEQA that the California Water Regional Quality Board was the Lead Agency and would obtain a Coastal Development Permit from the Coastal Commission. The only approval necessary from the City of Carlsbad is approval of a grading permit. CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN DIEGO REGION CEASE AND DESIST ORDER NO. 88-81 FOR SAN DIEGO GAS & ELECTRIC COMPANY ENCINA POWER PLANT CLASS I SURFACE IMPOUNDMENTS SAN DIEGO COUNTY The California Regional Water Quality Control Board, San Diego Region, (hereinafter Regional .Board) finds that: 1. On December 21, 1987. the Regional Board adopted Cease and Desist Order No. 87-138 for violations of Waste Discharge Requirement Order No. 87-137. 2. Subsequent to adoption of Orders Ncs. 87-137 and 87-138, the discharger decided to close the existing surface impoundments rather than upgrade the impoundments to meet the requirements of the Toxic Pits Cleanup Act of 1984 and Subchapter 15, Chapter 3, Title 23 of the California Code of Regulations (Subchapter 15). By letter dated May 9, 1988, the discharger reported to staff its intent to replace the impoundments with above-ground tanks (for the metal cleaning and treated wastes) and an in-line treatment system (for the low volume nonhazardous wastes). This decision was based on a cost and feasibility analysis of retrofitting the surface impoundments to current standards, notably the seismic design criteria as prescribed in Subchapter 15. 3. SDG&E's decision caused several discharge specifications contained in Order No. 87-137 to become obsolete. Therefore, Order No. 88-80 reflects necessary modifications to Order No. 87-137, "Waste Discharge Requirements for San Diego Gas & Electric Company, Encina Power Plant, Class I Surface Impoundments, San Diego". 4. TPCA prohibits any person, after June 30, 1988, from discharging liquid hazardous wastes or hazardous wastes containing free liquids into a surface impoundment if the surface impoundment contains hazardous waste and is within one-half mile of a potential source of drinking water, and requires the person in that event to close the surface impoundment or be granted an exemption with specific restrictions. 5. Waste Discharge Requirements Order No. 88-80 contains the following Prohibitions: "A.2. The discharge of liquid hazardous wastes or hazardous wastes containing free liquids to the existing surface impoundments after June 30, 1988 is prohibited.", and "A.3. The discharge of restricted hazardous waste into the surface impoundments is prohibited." CAD Order No. 88-81 -2- 6. The discharger intends to discharge wastes to the present surface impoundments until the above-ground tanks are operational. Therefore, the discharger threatens to violate Prohibitions A.2 and A.3 of Order No. 88-80 by the discharge of restricted hazardous and/or liquid hazardous waste or hazardous wastes containing free liquids into the surface impoundments after June 30, 1988. Documentation of the threatened violations are contained in the August 22, 1988 Regional Board staff report and oral testimony presented to the Board at a Public Hearing on August 29, 1988. 7. The discharger intends to comply with Order No. 88-80 by installing above-ground tanks for the discharge and storage of restricted hazardous wastes, liquid hazardous wastes, and/or hazardous wastes containing free liquids. The discharger has provided a schedule for implementation of the above-ground tanks and for cease discharge to the surface impoundments. The time schedule and Cease Discharge Order are based on the schedule provided by the discharger, 8. Cease and Desist Order No. 87-138 was issued by the Board on December 21, 1987 for violations of Waste Discharge Requirements Order No. 87-137. The directives contained in Cease and Desist Order No. 88-81 replace those established in Cease and Desist Order No. 87-138. 9. SDG&E has been informed of the threatened violations through correspondence, by- meetings with Regional Board staff, and from the August 22, 19S8 Staff Cease and Desist report. 10. On August 29, 1988 in Room B-109 of the State Office Building, 1350 Front Street, San Diego, after due notice to the discharger and all other interested persons, the Regional Board conducted a public hearing at which evidence was received concerning the aforementioned threatened violations of Order No. 88-80. 11. This enforcement action is exempt from the provisions of the California Environmental Quality Act in accordance with the California Code of Regulations. Title 14. Section 15308." IT IS HEREBY ORDERED, that San Diego Gas & Electric Company (SDG&E) shall comply with the following: 1. SDG&E shall cease and desist from violating Prohibitions A.2. and A.3. of Order No. 88-80 for the Encina Power Plant. 2. Compliance by SDG&E with Prohibition A.2. and A.3. of Order No. 88-80 shall be achieved in accordance with the following time schedule: Compliance Report Due Task Date Date (a). Submittal of a preliminary closure plan. 12,31/88 12/31,88 (b). Submittal of a detailed closure plan. 5.31 89 5 31/89 CAD Order No. 88-81 -3- (c). Cease discharge of liquid hazardous waste or hazardous waste containing free liquids into existing surface impoundments. 7/31/90 8/15/90 (d). Initiate closure and cleanup. 8/01/90 9/15/90 (e). Finish closure and cleanup. 8/01/91 9/15/91 3. The discharger shall submit to the Regional Board quarterly progress reports detailing progress made toward cease discharge, closure, and cleanup. These reports shall be due 30 days following the end of each quarter (January 30, April 30. July 30, and October 30). 4. The discharger shall submit to the Regional Board, on or before each compliance report date, a report of compliance or noncompliance with the specific task. If noncompliance is being reported, the reasons for such noncompiiance shall be stated, plus an estimate of the date of compliance. The discharger shall notify the Regional Board by letter upon return to compliance with the time schedule. 5. The discharger shall suspend and, or limit discharge of any liquid hazardous waste (or restricted hazardous waste if produced) into the present surface impoundments until new above-ground tank construction is complete or unless a vita! power plant cleaning operation is required to prevent damage. 6. Until the new above-ground tank construction is complete, any restricted hazardous wastes, liquid hazardous wastes, or hazardous wastes containing free liquid discharged to the surface impoundments shall be removed within 30 days. Documentation of the approximate liquid volume removed, disposal destination (chemical analyses if necessary to determine disposal method), and the duration liquid was in the surface impoundment(s) shall be submitted to the Regional-Board. 7. The discharger shall submit documentation and/or "as-builts" of completion of the above- ground tanks and in-line treatment facilities upon completion. 8. The discharger shall submit documentation that cease discharge has been achieved. PROVISIONS 1. Nothing in this Order shall be construed to preclude SDG&E from civil or criminal penalties resulting from violations of Order No. 88-80. 2. The California Water Code provides that any person who intentionally or negligently violates a Cease and Desist Order issued, reissued or amended by a Regional Board is subject to a civil monetary remedy of discharge, up to $10,000 per day of violation or some combination thereof. 3. The requirements prescribed by this Order supersede the requirements prescribed by Cease and Desist Order No. 87-138. Cease and Desist Order No. 87-138 is hereby rescinded upon issuance of this Order. C&D Order No. 88-81 -4- 1, Ladin H. Delaney, Executive Officer, do hereby certify the foregoing is a full, true, and correct copy of an Order adopted by the California Regional Water Quality Control Board, on August 29, 1988. LADIN H. DELANEY Executive Officer CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN DIEGO REGION ADDENDUM NO. 1 TO CEASE AND DESIST ORDER NO. 88-81 FOR SAN DIEGO GAS & ELECTRIC COMPANY ENCINA POWER PLANT CLASS I SURFACE IMPOUNDMENTS California Regional Water Quality Control Board, San Diego Region (hereinafter Regional Board) finds that: 1. 2. 3. On August 29, 1988, the Regional Board adopted Cease and Desist Order No. 88-81 for San Diego Gas & Electric Company (SDG&E) for threatened violations of Prohibitions A. 2 and A. 3 of Waste Discharge Requirements (WDR) Order No. 88-80. Directive No. 2 of Cease and Desist Order No. 88-81 established the following schedule for compliance with Prohibition A. 2 and A. 3 of WDR Order No. 88-80: Task (a) Submittal of a preliminary closure plan. (b) Submittal of a detailed closure plan. (c) Cease discharge of liquid hazardous waste or hazardous waste containing free liquids into existing surface impoundments. (d) Initiate closure and cleanup. (e) Finish closure and cleanup. Compliance Date 12/31/88 5/31/89 7/31/90 Report Due Date 12/31/88 5/31/89 8/15/90 8/01/90 8/01/91 9/15/90 9/15/91 By letter dated March 21, 1990, SDG&E notified staff that they would not be able to meet the order schedule and closure dates of Directives Nos. 2(c), 2 (d), and 2(e) due to delays in receiving the required local permits from the City of Carlsbad (City). SDG&E stated that they requested a determination of this issue in August 1988. In January 1989, the City determined that an amendment was required, but the amendment was not approved by the City until July .~«WJ- *? ',-_•• Addendum No. 1 to -2- June 4, 1990 CtD Order No. 88-81 SDG&E Encina Plant 1989. 8DG&E has requested an extension of the remaining applicable compliance dates in the Cease and Desist order compliance schedule due to these delays. 4. By letter dated April 10, 1990, the City confirmed that the construction of above-ground storage tanks to replace the existing surface impoundments required an amendment of the specific plan regulating the Encina Power Plant. The amendment was not approved by the City until July 1989. 5. This enforcement action is exempt from the provisions of the California Environmental Quality Act (Public Resources Code, Section 21000 et. seq.) in accordance with Section 15321, Chapter 3, Title 14, California Code of Regulations. IT IS HEREBY ORDERED, that Directive No. 2(c), (d) , and (e) of Cease and Desist Order No. 88-81 is revised as follows: Compliance Report Due 1. Task Date Date (c) Cease discharge of liquid 6/30/91 7/15/91 hazardous waste or hazardous waste containing free liquids into existing surface impoundments. (d) Initiate closure and cleanup. 7/01/91 8/15/91 (e) Finish closure and cleanup. 7/01/92 8/15/92 Ordered by:. Dated: June 4, 1990 JPAienc C&D.amd Arthur L. Coe Acting Executive Officer SDG&E C&D Add. Transmittal -2- June 14, 1990 Encina Power Plant Enclosure cc: Mr. Fred Jacobsen, Environmental Analyst, SDG&E Mr. James Parsons, TPCA Program Manager, State Water Resources Control Board, Division of Clean Water Programs, Sacramento, California Ms. Sheila Vassey, Senior Staff Counsel, Office of Chief Counsel, State Water Resources Control Board, Sacramento, California San Diego Gas & Electric P.O. BOX 1831 • SAN DIEGO, CA 92112 • 619/696-2000 April 2, 1991 FILENO. Ms. Adrienne Landers City of Carlsbad 2075 Las Palmas Drive San Diego, CA 92009-4859 SUBJECT: WASTEWATER PONDS REMOVAL: ENVIRONMENTAL REVIEW Dear Dee: This letter follows the Planning Department's review and concurrence that project environmental review per CEQA is the responsibility of the California Regional Water Quality Control Board (RWQCB). Per your request, copies of the Waste Discharge Requirements (Order No. 88-80), Monitoring and Reporting Program No. 88-80, Cease & Desist Order 88-81 plus an addendum, and the Encina Power Plant Wastewater Ponds Closure Plan as approved by the Board are attached for your files. The RWQCB will notice the City of Carlsbad when it takes action to certify that the closure process has been completed in compliance with the approved closure plan and amends or rescinds the existing water discharge requirement and cease and desist order. A coastal development permit is required for the removal of the wastewater ponds. This permit requirement will be processed concurrently with the city grading permit requirement. Attached is the LOCAL AGENCY REVIEW FORM that must be completed by the city and submitted as part of the coastal permit application filing. Your attention to the completion of the form and its return to my attention would be greatly appreciated. Please call me at 696-2410 if you have questions about this matter. David S. Siino Senior Land Planner DSS:kmd Attachments cc: Paul O'Neal, SDG&E John Anderson, RWQCB [LANDALTR.D02] CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN DIEGO REGION MONITORING AND REPORTING PROGRAM NO. 88-80 FOR SAN DIEGO GAS & ELECTRIC COMPANY ENCINA POWER PLANT CLASS I SURFACE IMPOUNDMENTS SAN DIEGO COUNTY Site Location: Section 18, T12S, R4W, SBB&M A. MONITORING PROVISIONS 1. Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. All samples shall be taken at the monitoring points specified in this Order. Monitoring points shall not be changed without notification to and the approval of the Executive Officer. 2. The discharger shall develop and follow a ground-water monitoring program which includes consistent and appropriate sampling and analytical procedures that accurately measure indicator parameters and waste constituents and would provide a reliable indication of ground and surface water quality. 3. Sample collection, storage, and analyses shall be performed according to the most recent version of "Test Methods for Evaluating Solid Waste" (EPA/SW-846), "Methods for Chemical Analysis of Water and Waste" (EPA/600/4-79-020), "Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater" (EPA-600/4-82-057), and/or "Standard Methods for the Examination of Water and Wastewater." 4. All analyses shall be preformed in a laboratory certified to perform such analyses by the California Department of Health Services or a laboratory approved by the Executive Officer. The director of the laboratory whose name appears on the certification shall supervise all analytical work in his/her laboratory and shall sign all reports of such work submitted to the Regional Board. 5. Monitoring results must be reported on discharge monitoring report forms approved by the Executive Officer. 6. The discharger shall retain records of all monitoring information, including all calibration and maintenance records, copies of all reports required by this Order, and records of all data used to complete the application for this Order. Records shall be maintained for a minimum of five years from the date of the sample, measurement, report, or application. This period may be extended during the course of any unresolved litigation regarding this discharge or when requested by the Regional Board Executive Officer. 7. Records of monitoring information shall include: (a). The date, exact place, and time of sampling or measurements; (b). The individual(s) who performed the sampling or measurements; (c). The date(s) analyses were performed; ORDER NO. 88-80 -2- (d). The individual(s) who performed the analyses; (e). The analytical techniques or method used; and (f). The results of such analyses. 8. Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean unless otherwise specified by the Executive Officer or in this Order. 9. All monitoring instruments and devices used by the discharger to fulfill the prescribed monitoring program shall be properly maintained and calibrated as necessary to ensure their continued accuracy. 10. The discharger shall have, and implement, an acceptable written quality assurance/quality control (QA/QC) plan for laboratory analyses. An annual report shall be submitted by February 28 of each year which summarizes the QA/QC activities for the previous year. Duplicate chemical analyses must be conducted on a minimum of ten percent of the samples or at least one sample per quarter, whichever is greater. A similar frequency shall be maintained for analyzing spiked samples. 11. The monitoring reports shall be signed by an authorized person as required by Reporting Program E.I. 12. A composite sample is defined as a combination of at least 8 sample aliquots of at least JOO milHliters, collected at periodic intervals during the operating hours of the facility over a 24-hour period. The composite must be flow proportional; either the time interval between each aliquot or the volume of each aliquot must be proportional to either the stream flow at the time of sampling or the total stream flow since the collection of the previous aliquot. Aliquots may be collected manually or automatically. 13. A grab sample is an individual sample of at least 100 milliliters collected at a randomly selected time over a period not exceeding 15 minutes. B. GROUND-WATER MONITORING 1. The discharger shall continue a detection and background monitoring program for one year (four quarters). The Board may require additional monitoring following the completion and evaluation of this data. Surface water monitoring is established in "Monitoring and Reporting Program No. 85-10" pursuant to Waste Discharge Requirements Order No. 85-10 (NPDES Permit No. CA0001350). 2. Ground-water sampling for the detection and background ground-water monitoring program shall include the constituents listed under interim Water Quality Protection Standards. C.I. of Board Order No. 88-80 and shall include general ground-water chemistry. The general ground-water chemical constituents shall include calcium (Ca), magnesium (Mg). sodium (Na). potassium (K). chloride (CD, sulfate (804), carbonate (CO3). and bicarbonate (HCO3). The quarterly monitoring reports shall include a cation, anion balance for each well. ORDER NO. 88-80 -3- 3. New monitoring weiis shall be designed and certified as adequate pursuant to Section 2555 of Subchapter 15 by a registered geologist or a registered civil engineer in the State of California. 4. All monitoring wells shall be constructed in a manner that maintains the integrity of the drill hole and prevents cross-contamination of saturated zones. The casing shall be a minimum of two inches in diameter. The annular space shall be packed with appropriate filter material that is sized to match the formation. The annular space above the screened depth shall be appropriately sealed to prevent contamination of samples and ground water from surface pollution. The well shall be adequately developed to prevent the movement of sediment into the casing and to produce the highest yield possible from the formation. Each well shall be marked permanently so as to readily identify it and shall have a reference point tied into mean sea level elevation by a licensed surveyor. All monitoring wells shall be logged during drilling under the direct supervision of a California registered geologist. All monitoring well logs submitted to the Board shall be signed by the registered geologist. All monitoring well logs shall be filed with the Department of Water Resources (DW'R) on forms provided by DWR, pursuant to Water Code Section 13751. Soil shall be described according to the Unified Soil Classification System. Copies of the logs and as-built specifications of the wells shall be submitted to the Regional Board. 5. Prior to sampling the wells, the presence of a floating immiscible layer in all wells shall be determined at the beginning of each sampling event. If an immiscible layer is found, the Regional Board shall be notified within 24 hours. 6. Prior to pumping the wells for sampling, the static water level shall be measured in each well. 7. Prior to sampling the wells, the water standing in the casing shall be pumped using a step-down purging method until the water chemistry has stabilized with respect to pH and specific conductance. Water chemistry can be considered stable when in-line specific conductance and pH readings are within +_10% and +_0.1 pH units respectively over 2 successive well volumes. Samples shall be obtained that are representative of the fresh aquifer formation water. 8. After purging, if 80% recovery of the initial water level exceeds three hours, a sample should be collected as soon as the water level is sufficient to recover a representative sample. 9. For each parameter specified, the discharger shall calculate the arithmetic mean and variance of the samples obtained yearly and shall be included in the annual report. C. REPORTING PROGRAM AND SCHEDULE 1. A letter of transmittal shall accompany each submitted monitoring report. The letter should discuss the essential points in each monitoring report. Such a letter shall include a discussion of any significant findings and violation(s) of requirements found during the monitoring period and actions taken or planned for correcting the violation(s). If the discharger has previously submitted a detailed time schedule for ORDER NO. 88-80 -4- correcting violation(s) a reference to the correspondence transmitting such schedule will suffice. If no violations have occurred in the last monitoring period, it shall be stated in the letter of transmittal. Monitoring reports and the letter of transmittal shall be signed by a principal executive officer at the level of vice president or his/her duly authorized representative, if such representative is responsible for the overall operation of the facility from which the discharge originates. The letter shall contain a statement by the official, under penalty of perjury, that to the best of the signer's knowledge the report is true, complete, and correct. 2. Field logs for each ground-water well shall be included in the ground-water monitoring reports. The information contained in these logs shall include: the name of the person actually taking the sample, well number, date, time of sampling, method of purging and sampling (if a pump is used, include, the type of pump used, pump placement, and pumping rate), date each well was purged, well recovery time, method of disposal of the purged water, an estimate of volume of water purged from each well, the results of all field analyses, the method of monitoring the field parameters, sampling procedure, depth to ground water, method of measuring the water level, number of field blanks, presence of travel blanks, well number where duplicate samples are taken, type of sample containers and preservatives, any observations of the quality of the sample water (color, odors, immiscible phases, etc.), chain of custody record, and any problems encountered during sampling. 3. All laboratory reports shall include QA/QC procedures. This shall include recovery rates, results from blanks, spikes, and duplicate samples. An explanation for any recovery rate which is less than the standard recovery rate for that particular constituent shall be included. 4. The discharger shall submit a compliance evaluation summary of the ground-water chemical data obtained for the quarter. The summary shall contain a table which includes the following information: (a). Monitoring parameters; (b). Detection limit of monitoring equipment; (c). Water quality protection standards for each parameter; (d). Average concentration for each parameter over the previous four quarterly monitoring events; (e). Measured concentrations found in the current sampling event; and (f). Whether a significant difference was found for each parameter. The measured concentrations shall be reported with a "<" symbol only if the value listed after the symbol is the detection limit achieved by the laboratory. 5. The discharger shall submit an annual report summarizing the previous year's ground- water monitoring results. This report shall include the following: (a). A summary of the QA/QC activities for the previous year(s); (b). A summary of the previous year's water quality data results, which shall include a graphical representation of the data. ORDER NO. 88-80 -5- The discharger shall submit a graphical illustration of the direction of ground-water flow beneath the surface impoundments. The time of day at which each well's water level is determined shall be included with the graphical presentation of the direction of ground-water flow. Any wells subject to tidal influence should include tide tables for that sampling period and a determination of in-coming or out-going tides. The monitoring reports shall be submitted to the Executive Officer in accordance with the following schedule: Report Report Period Due Date Quarterly January, February, March April, May, June July, August, September October, November, December Annual January - December April 30 July 30 October 30 January 30 February 28 Forward monitoring reports to: California Regional Water Quality Control Board San Diego Region 9771 Clairemont Mesa Boulevard, Suite B San Diego, CA 92124-1331 Ordered by: LADIN H. DELANEY Executive Officer -5 rn CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN DIEGO REGION ORDER NO. 88-80 WASTE DISCHARGE REQUIREMENTS FOR SAN DIEGO GAS & ELECTRIC COMPANY ENCINA POWER PLANT CLASS I SLTRFACE IMPOUNDMENTS SAN DIEGO COUNTY The California Regional Water Quality Control Board (hereinafter referred to as the Board), San Diego Region, finds that: •••• 1. Mr. Gary D. Cotton, Senior Vice President of Engineering & Operations for San Diego Gas & Electric Company (hereinafter referred to as the discharger), P.O. Box 1831, San Diego, California, 92112, submitted a complete Report of Waste Discharge dated October 7, 1987 for operation of six surface impoundments at the Encina Power Plant. The report includes a hydrogeologic assessment report (HAR), dated December 31, 1985, pursuant to provisions of the Toxic Pits Cleanup Act of 1984 (TPCA), Section 25208 of the California Health and Safety Code (CHSC) and additional information pursuant to Subchapter 15, Chapter 3, Title 23 of the California Code of Regulations (Subchapter 15). 2. The discharger owns and operates a power plant at 4600 Carlsbad Boulevard, in the southwest sector of the City of Carlsbad, California, adjacent to and immediately south of the Agua Hedionda Lagoon on the Pacific Ocean. The power plant is in Section 18, T12S, R4W, SBB&M. A site map is shown in Attachment A appended hereto as a part of this Order. 3. The Encina Power Plant has five steam turbine generators and one gas turbine generator. All five units burn gas or fuel oil depending on economic conditions. All units operate independently, or in conjunction with, one another; but share the once-through cooling water system. The table below summarizes each unit's capacity and start up date. Unit Date on Line Capacity 1 1954 105 MW 2 1956 104 MW 3 1958 110MW 4 1973 287 MW 5 1978 315 MW Gas Turbine 1968 20 MW Total Plant Capacity 941 MW The total rated net generating capability of the Encina Power Plant is 941 megawatts (MW). and there are no pians for major modifications in the capacity of the plant in the near future. ORDER NO. 88-80 -2- 4. At full capacity the total estimated water usage at the Encina Power Plant is 858.7 million gallons per day (MGD) of which 99.81 percent is once through cooling water obtained from the Pacific Ocean. The balance of the service water is obtained from the municipal water supply. Seepage and ground-water pumping account for over 1.6 MGD in additional plant flow. Cooling water is withdrawn from the Pacific Ocean via the Agua Hedionda Lagoon. After passing through the intake structure, trash racks and traveling screens; the water is pumped through the condensers. The amount of cooling water required is dependent upon the number of units in operation. The heated water is discharged to the Pacific Ocean after passing through a discharge pond. 5. A breakdown of the estimated maximum wastewater discharged to the surface impoundments at the Encina Power Plant is tabulated below. How Nonhazardous Waste Stream (Gallons Per Day) (a) Low Volume Wastewater 125,000 (1) Condensate boiler blowdown (2) Evaporator blowdown (3) Sample drains (4) Floor drains (5) Demineralizer (6) Softeners (7) Dealkalizer (8) Condenser cleaning (9) Reverse osmosis (10) Purged ground water from monitoring wells (11) Treated low volume waste Estimated Annual Maximum Hazardous Waste Stream Volume in gallons * (a) Metal Cleaning Wastewater 5,375,000 (1) Boiler chemical cleaning (2) Hypochlorinator chemical cleaning (3) Evaporator chemical cleaning (4) Air heater wash (5) Boiler fireside wash (6) Condenser chemical cleaning (7) Reverse osmosis cleaning (8) Treated metal cleaning waste ** * Based on two boiler chemical cleanings per year and three boiler fireside washes per unit per year per facility. ** Occasionally, the treated metal cleaning wastewater contains hazardous waste constituents and will be handled as a hazardous waste. ORDER NO. 88-80 -3- 6. The Board issued "Waste Discharge Requirements For San Diego Gas & Electric Company, Encina Power Plant" for discharge to the Pacific Ocean under the National Pollutant Discharge Elimination System pursuant to Section 402 of the Clean Water Act. Order No. 85-10 (NPDES Permit No. CA0001350) was reissued January 28, 1985. 7. The Encina Power Plant has six surface impoundments which are used for temporary storage of wastewater. Wastewaters which require treatment are treated in an adjacent physical/chemical treatment facility. The treated wastewater is then discharged to the Pacific Ocean in accordance with Order No. 85-10 (see Finding No. 6). 8. The six surface impoundments at the power plant were constructed in 1978 and are located in two separate areas. Impoundments Nos. 1, 2, 3, and 4 are located north of the power plant. From west to east, they consist of two low-volume waste impoundments (Nos. 1 and 2, with a maximum storage capacity of 300,000 and 590,000 gallons each respectively) and two metai-cleaning waste impoundments (Nos. 3 and 4, with a maximum storage capacity of 750,000 and 330,000 gallons each respectively). Treated wastewater impoundments (Nos. 5 and 6, with a maximum storage capacity of 220,000 and 270,000 gallons each respectively) are located northeast of the plant, approximately 540 feet from the low-volume and metal-cleaning waste impoundments. Impoundment No. 1 is approximately 60 feet south of Agua Hedionda Lagoon. 9. Boiler fireside washes are needed to remove soot and accumulated combustion by- products from metal surfaces in order to maintain efficient heat transfer. Frequency again depends on the fuel being burned. These washes are accomplished by spraying high-pressure water against the surfaces to be cleaned. The wastewaters generated contain an assortment of dissolved and suspended solids with loadings and constituents dependent upon the fuel used. 10. Metal cleaning waste waters undergo neutralization, floccuiation, and chemical precipitation at an on-site waste water treatment plant. For low volume wastes that are treated, the facility provides physical-chemical treatment (neutralization, floccuiation, and chemical precipitation) if required; otherwise the waste is discharged from the primary treatment tank, or the physical-chemical treatment plant to the condenser cooling water flow. 11. The power plant site area consists of low, rolling hills of Eocene sediments bounded on the west by a coastal plain where the Eocene sediments are overlain by Pleistocene and Holocene sediments. Fill soils consist of silty to clayey sands and range in thickness from 6 to 32 feet. Lagoonal deposits underlie the fill (surface impoundments 1-4 area) and consist of silty sands and sands with occasional ciayey sand imerbeds. The lagoonal sediments range in thickness from 0 to about 65 feet. Underlying the lagoonal deposits is the Santiago Formation which consist of very dense, silty to clayey sands with occasional clay interbeds. Beneath the fill (under surface impoundments 5 and 6) is the Pleistocene coastal terrace deposits. These terrace deposits consist of medium dense sands with intermittent gravels. This unit is up to 15 feet thick. ORDER NO. 88-80 -4- 12. The surface impoundments are subject to regulations under the State Board's land disposal regulations (Subchapter 15) and TPCA. On December 21, 1987, the Regional Board adopted Order No. 87-137, which prescribed waste discharge requirements for the 6 surface impoundments. The requirements contain specifications and provisions to bring the discharger into full compliance with Subchapter 15 and TPCA. 13. Board Order No. 87-137 also granted the discharger several exemptions from the requirements of TPCA which would enable the discharger to retrofit its present surface impoundments and to continue uninterrupted operation. In particular, Order No. 87-137 granted the discharger an exemption from the TPCA prohibition against discharge of liquid hazardous waste or hazardous waste containing free liquids into a surface impoundment after June 30, 1988 if the impoundment is located within 1/2 mile upgradient of a drinking water source. Order No. 87-137 also granted the discharger a temporary exemption, until December 21, 1988, from the TPCA prohibition against discharge of liquid hazardous wastes or hazardous wastes containing free liquids into a surface impoundment. 14. Concurrently with adoption of Order No. 87-137, the Board issued Cease and Desist Order No. 87-138 pursuant to Section 13301 of the California Water Code, requiring the owner/operator to retrofit the surface impoundments and to clean up any pollution which had occurred. 15. Subsequent to adoption of Order Nos. 87-137 and 87-138, the discharger decided to close the existing surface impoundments rather than upgrade the impoundments to meet TPCA and Subchapter 15 requirements. By letter dated May 9, 1988, the discharger reported to staff its intent to replace the impoundments with above-ground tanks (for the metal cleaning and treated wastes) and an in-line treatment system (for the low volume nonhazardous wastes). This decision was based on a cost and feasibility analysis of retrofitting the surface impoundments to current standards, notably the seismic design criteria as prescribed in Subchapter 15. 16. SDG&E's decision caused several discharge specifications contained in Order No. 87-137 to become obsolete. Therefore, Order No. 88-80 reflects necessary modifications to Order No. 87-137. "Waste Discharge Requirements for San Diego Gas & Electric Company, Encina Power Plant, Class I Surface Impoundments, San Diego". 17. Order No. 88-80 rescinds the three exemptions granted by Order No. 87-137 and prescribes standards for closure of the impoundments. In addition, Order No. 88-80 implements TPCA prohibitions contained in CHSC Sections 25208.4(a) and (cX2) against the discharge of hazardous and restricted hazardous wastes into surface impoundments. 18. The discharger intends to discharge low volume nonhazardous wastes into some of the impoundments after December 1988 for temporary storage until the in-line treatment system is operational. 19. The discharger has demonstrated that all sludges have been removed from all of the impoundments and that all of the impoundment liners have been tested and are nonhazardous. ORDER NO. 88-80 -5- 20. Under TPCA, exemptions from the discharge prohibitions contained in CHSC Sections 25208.4(a) and (cX2) may be granted by a Regional Board only if a surface impoundment complies with TPCA requirements regarding liners, leachate collection and ground-water monitoring. A temporary exemption from the liner requirements may-be -granted in some. cases, under Section 25208.5(c), to enable a discharger to bring a facility into compliance with these requirements. Since the discharger in this case no longer intends to retrofit its impoundments, the basis for the exemptions granted in Order No. 87-137 are no longer applicable. 21. Additionally, a revised Cease and Desist Order No. 88-81 has been drafted for adoption by the Regional Board. Cease and Desist Order No. 88-81 replaces Cease and Desist Order No. 87-138. 22. The discharger has submitted results from four quarters of ground-water monitoring data. The first two quarters of data are results of analyses performed by a contract laboratory and the last two quarters of data are results of analyses performed by the discharger's laboratory. There are significant discrepancies between the two sets of data. Therefore, the Board has concluded that interim water quality protection standards will be established until additional ground-water monitoring results have been evaluated. The Board will require the discharger to continue background and detection monitoring for another year. At the end of this period, the Board will establish final water quality protection standards, based on the additional information, for the facility. In the interim, the discharger will not be required to implement or initiate verification monitoring until the final water quality protection standards have been established. 23. The Comprehensive Water Quality Control Plan Report, San Diego Basin (9) (Basin Plan) was adopted by this Regional Board on March 17, 1975; approved by the State Water Resources Control Board (State Board) on March 20, 1975; with subsequent updates by the Regional Board which were also approved by the State Board. The Basin Plan establishes water quality objectives for the San Diego Basin. 24. The Basin Plan established the following as potential and existing beneficial uses for the_ Agua Hedionda Lagoon coastal area; (a). Industrial Service Supply (b). Water Contact Recreation (c). Non-Contact Water Recreation (d). Ocean Commercial and Sport Fishing (e). Saline Water Habitat (f). Preservation of Rare and Endangered Species (g). Marine Habitat (h). Shellfish Harvesting 25. This facility is exempt from provisions of the California Environmental Quality Act (Section 15301, Title 14 of the California Code of Regulations) as an existing facility with minor modifications and having no anticipated expansion of use. The Regional Board finds that no adverse water quality impacts will result if the discharger complies with the terms of this Order. ORDER NO. 88-SO -6- 26. The Regional Board has notified the discharger and all known interested agencies and persons of its intent to prescribe waste discharge requirements for this discharge. 27. The Regional Board has, in a public meeting, heard and considered all comments pertaining to the discharge. IT IS HEREBY ORDERED, based on the record, that the Regional Board take the following actions: 1. The following exemptions, which were granted on December 21, 1987, are hereby rescinded upon adoption of this Order: (a). Exemption from Section 25208.4(a) pursuant to Section 25208.4(b)(l) for the continued discharge of liquid hazardous wastes or hazardous wastes containing free liquids into surface impoundments Nos. 1 through 6 which are within one-half mile upgradient from a potential source of drinking water. (b). Exemption from Section 25208.4(c)(2) pursuant to Section 25208.16(a) as described in Finding No. 31 of Order No. 87-137 for surface impoundments Nos. 1 through 6. (c). The temporary exemption from Section 25208.5(a) for up to one year from the effective date of Order No. 87-137 (December 21, 1988), for the sole purpose of bringing surface impoundments Nos. 1 through 6 into compliance with Section 25208.5(a). IT IS FURTHER ORDERED, that San Diego Gas & Electric Company shall comply with the following: A. PROHIBITIONS 1. Neither the treatment nor the discharge of wastes shall create a pollution or a nuisance as defined in Section 13050, Division 7 of the California Water Code. 2. The discharge of liquid hazardous wastes or hazardous wastes containing free liquids to the existing surface impoundments after June 30, 1988 is prohibited. 3. The discharge of restricted hazardous waste into the surface impoundments is prohibited. 4. The discharge of any low volume nonhazardous wastes or waste constituents from the surface impoundments or associated piping to any surface waters of the State or to surface drainage courses is prohibited unless the discharge is permitted under the National Pollutant Discharge Elimination System by issuance of Waste Discharge Requirements by the Regional Board. ORDER NO. 88-80 -7- B. DISCHARGE SPECIFICATIONS 1. Prior to final closure of the surface impoundments, the discharger shall submit a closure and post-closure maintenance plan for approval by the Executive Officer. The plan shall provide for continued compliance with all applicable standards pursuant to Subchapter 15 and future revisions thereto, throughout the closure and post-closure maintenance period. 2. The discharge of any low volume nonhazardous wastes or waste constituents from the surface impoundments or associated piping to ground waters of the State or to the vadose zone surrounding the surface impoundments shall not cause a pollution, nuisance, or cause the Basin Plan objectives to be exceeded. 3. The discharge of low volume nonhazardous wastes to the existing surface impoundments shall be continued only until the proposed in-line low volume waste treatment system is complete and functional. Upon completion of the in-line treatment system, discharge to the impoundments shall terminate and the discharger shall notify the Executive Officer, in writing, to that effect. C. WATER QUALITY PROTECTION STANDARDS 1. At present, interim water quality protection standards have been developed for indicator parameters and for waste constituents which are reasonably expected to be in or derived from wastes discharged into the surface impoundments. They are based on the current background water quality. The interim water quality protection standards include the following: Water Quality Protection Constituents Standard (mg'!) pH (pH Units) 7.0 - 8.3 Arsenic (As) 0.008 Cadmium (Cd) 0.1 Copper (Cu) 0.3 Chromium (Total Cr) 0.16 Lead (Pb) 0.2 Molybdenum (Mo) 0.37 Nickel (Ni) 1.6 Vanadium (V) 0.1 Zinc (Zn) 0.41 Oil & Grease 34 2. The discharger shall continue a ground-water detection and background monitoring program at points of compliance for one year (four quarters) as set forth in "Monitoring and Reporting Program No. 88-80." 3. Until final water quality protection standards are established, pursuant to C.I. of this Order, the discharger shall not be required to implement or initiate a verification monitoring program pursuant to Subchapter 15. ORDER NO. 88-80 -8- D. PROVISIONS 1. Ground-water monitoring shall apply during the active life of the surface impoundments (including the closure period unless all waste, waste residues, contaminated containment system components, and contaminated geologic materials have been removed or decontaminated at closure). 2. The discharger shall comply with "Monitoring and Reporting Program No. 88-80" and future revisions thereto, as specified by the Executive Officer. Monitoring results shall be reported at the intervals specified in Monitoring and Reporting Program No. 88-80. 3. Prior to any change in ownership of these facilities/operations, the discharger shall transmit a copy of this Order to the succeeding owner/operator, and forward a copy of the transmittal letter to this Board. 4. This Qrder does not authorize violation of any federal, state, or local laws or regulations. 5. The discharger shall maintain a copy of this Order at the site to be available at all times to site operating personnel. 6. The discharger shall notify the Regional Board (in writing) seven days prior to any vital power plant cleaning operation that could possibly generate restricted hazardous waste. E. NOTIFICATIONS 1. These requirements have not been officially reviewed by the United States Environmental Protection Agency and are not issued pursuant to Section 402 of the Clean Water Act. 2. The California Water Code provides that any person who intentionally or negligently violates any waste discharge requirements issued, reissued, or amended by this Regional Board is subject to a civil monetary remedy of up to 20 dollars per gallon of waste discharged or, if a cleanup and abatement order is issued, up to 15,000 dollars per day of violation or some combination thereof. 3. The California Water Code provides that any person failing or refusing to furnish technical or monitoring program reports, as required under this Order, or falsifying any information provided in the monitoring reports is guilty of a misdemeanor. 4. The requirements prescribed by this Order supersede the requirements prescribed by Board Order No. 87-137. Order No. 87-137 is hereby rescinded upon adoption of this Order. ORDER NO. 88-80 -9- I, Ladin H. Delaney, Executive Officer, do hereby certify, the foregoing is a full, true, and correct copy of an Order adopted by the California Regional Water Quality Control Board, on August 29, 1988. LADIN H. DELANEY Executive Officer CLOSURE PLAN ENCINA POWER PLANT Prepared for: SAN DIEGO GAS & ELECTRIC COMPANY CARLSBAD, CALIFORNIA Prepared by: MITTELHAUSER CORPORATION LAGUNA HILLS, CALIFORNIA /V1ITTELH>1USER Lcorpora hon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RJ TABLE OF CONTENTS Page No, 1. 0 INTRODUCTION 1-1 2.0 FACILITY INFORMATION 2-1 2.1 General Facility Description 2-1 2.2 Waste Management Unit Being Closed 2-1 2 . 3 Owner/Operator Information 2-3 2 . 4 Power Plant Contact 2-3 3 . 0 WASTE MANAGEMENT FACILITY 3-1 3.1 Impoundment Design 3-1 3.1.1 Impoundment Operation 3-5 3.2 Maximum Extent of Operations and Maximum Inventory 3-9 3.3 Waste Identification 3-9 4 . 0 CLOSURE PROCEDURES 4-1 4 .1 Closure Performance Standards 4-1 4 . 2 Site Cleanup Strategy 4-1 4.2.1 Introduction 4-1 4.2.2 Analysis Parameters 4-2 4.2.3 Cleanup Levels 4-6 4 . 3 Approach to Closure 4-8 4.3.1 Existing Analytical Data 4-9 4.3.2 Summary of Closure Activities 4-12 4 . 4 Final Closure Activities 4-15 4.5 Schedule for Closure 4-18 4.6 Post-Closure Plan 4-19 5.0 SAMPLE CONTROL 5-1 6. 0 DECONTAMINATION OF FACILITY EQUIPMENT 6-1 7.0 CLOSURE COST ESTIMATE 7-1 7.1 Contingent Closure and Post-Closure Plan and Cost Estimate 7-3 8 . 0 FINANCIAL ASSURANCE AND LIABILITY COVERAGE 8-1 8.1 Financial Assurance for Closure/Post-Closure 8-1 8.2 Liability Coverage for Sudden and Non-Sudden Accidental Occurrence 8-2 (i) /V1ITTELH/1USER vcorporation SDG&E Encina Power Plant Closure Plan December 1988 Rev: 0 P1080RJ LIST OF TABLES AND FIGURES Figures 2-1 3-1 3-2 3-3 3-4 4-5-1 Tables 3-1 3-2 3-3 3-4 3-5 Page No, Site Location Map 2-2 Site Plan 3-2 Plan View of Surface Impoundments 3-3 Schematic Cross Section of Typical Impoundment... 3-5 Groundwater Subdrain and Leachate Collection Systems 3-7 Proposed Locations of Soil Borings for LVW 1 and 2 4-5-5 Impoundment Characteristics 3-8 Chemical Constituents of Metal-Cleaning Operations 3-12 Chemical Constituents of Low-Volume Waste 3-13 Impoundment Waste Stream Characteristics - 1985.. 3-14 Impoundment Waste Characteristics - 1986 3-15 LIST OF ATTACHMENTS 4-1 Analytical Data from RI 4-2 Establishment of Background Levels 4-3 Deionized Water Waste Extraction Test Rationale 4-4 Closure Step Decision Diagram 4-5 Sampling and Analysis Plan 4-6 Letter Regarding Remedial Investigation Report 8-1 Draft Letter by Financial Officer 8-2 Special Report from SDG&E's Independent Certified Accountant 8-3 Opinion of Independent Certified Public Accountants 8-4 Fourth Quarter of 1987 Financial Summary (ii) /MITTELKMUSERcorpora hon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RA SECTION 1.0 INTRODUCTION /HITTELH/4USER t^corporation SDG&E 1-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RA 1.0 INTRODUCTION San Diego Gas and Electric Company (SDG&E) hereby submits this Closure Plan for the Wastewater Ponds located at the Encina Power Plant. The Plan is submitted to California San Diego Regional Water Quality Control Board (RWQCB) and the California Department of Health Services (DHS). This Closure Plan meets the requirements of 40 CFR265 for an Interim Status RCRA facility and of Title 22 and Title 23 of the California Code of Regulations (CCR). The plant will continue operating the wastewater ponds and the groundwater monitoring system under Title 23 until final closure is approved by the regulatory agencies. The closure approach presented in Section 4.0 has been developed on data presented to the RWQCB in two reports. These reports are: 1. Hydrogeologic Assessment Report (HAR) for the Encina Power Plant, September 1986, and 2. Remedial Investigation (RI) for the Encina Power Plant/ February 1988. /MITTELHMUSER .corpora hon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RB SECTION 2.0 FACILITY INFORMATION /MITTELH/1USER t.corporation SDG&E 2-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RB 2.0 FACILITY INFORMATION 2.1 GENERAL FACILITY DESCRIPTION San Diego Gas and Electric is a privately owned public utility providing electric service in SDG&E's California service territory. Encina Power Plant is owned and operated by the San Diego Gas and Electric Company (SDG&E). The plant is located in Carlsbad, California; on the coast line of the Pacific Ocean. A site location map is presented in Figure 2-1. 2.2 WASTE MANAGEMENT UNIT BEING CLOSED This Closure Plan is for six surface impoundments located at the SDG&E Encina Power Plant. The surface impoundments are used for the temporary collection of wastewater prior to treatment and/or discharge to the Pacific Ocean in accordance with NPDES Permit Number CA0001350. Sediment that accumulates in the impoundments is analyzed and disposed of in accordance with Federal and State regulations. SDG&E has decided to replace the existing six surface impoundments with a new wastewater system consisting of aboveground tanks. When the new system is in operation, SDG&E will implement this closure plan. Oceanside SDG&E ENCINA POWER PLANT Cardiff by the Sea N GRAPHIC SCALE (miles) Del Mar Pacific Ocean 3AA 'KYM **" 12/oe/aa """AS SHOWN *•"• "PIDBO FIGURE 2-1 SITE LOCATION MAP soue ENONA POVEK PLANT 1080-00-006 /HITTELH/IUSERcorporation SDG&E 2-3 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RB 2.3 OWNER/OPERATOR INFORMATION The name, address and telephone number for the owner/ operator of the facility, the type of facility and SIC code are as follows: Owner/Operator: San Diego Gas and Electric Company 101 Ash Street P. 0. Box 1831 San Diego, CA 92112 (619) 696-2000 Facility: San Diego Gas and Electric Company Encina Power Plant 4600 Carlsbad Blvd. Carlsbad, CA 92008 (619) 235-7777 Type of Facility: Electric Power Generation - SIC: 4911 2.4 CONTACT The SDG&E contact with regard to the Closure Plan is: Name: Mr. Lee R. McDonald, P.E. Environmental Programs Administrator - Address: 101 Ash Street P. 0. Box 1831 San Diego, California 92112 - Phone: (619) 696-4391 /MITTELH>1USER tcorpora hon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC SECTION 3.0 WASTE MANAGEMENT FACILITY /MITTELH/1USERcorporation SDG&E 3-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC 3.0 WASTE MANAGEMENT FACILITY The six surface impoundments at the Encina Power Plant are grouped in two separate areas as shown on the site plan, Figure 3-1. Impoundments No. 1, 2, 3 and 4 are located north of power plant. From west to east, there are two low-volume waste impoundments (Nos. 1 and 2) and two metal-cleaning waste impoundments (Nos. 3 and 4) . Treated wastewater impoundments, Nos. 5 and 6, are located adjacent to the water treatment plant which is located approximately 540 feet southeast from the other impoundment cluster. The impoundments are shown on Figure 3-2. 3.1 IMPOUNDMENT DESIGN The surface impoundments were constructed in 1978. The low-volume and metal-cleaning waste impoundments (Nos. 1 through 4) are built on an engineered pad of compacted fill. The elevation of the top of the impoundments is approximately +27 feet mean sea level (MSL) and the base elevation is approximately +6 to +17 feet MSL. The elevation of the lower liners of the impoundments vary between approximately +10 to +14 feet MSL. Impoundments No. 5 and 6 are also on an engineered fill pad with a crest elevation of approximately +38 feet MSL. The lower liner of these impoundments is at an elevation of approximately +30 feet MSL. The west face of the berm at Impoundments No. 5 and 6 is covered by concrete, and slopes steeply toward a drainage channel. AGUA HEDIONDA LAGOON LOW-VOLUME WASTE IMPOUNDMENTS BT2 PACIFIC OCEAN METAL-CLEANING WASTE IMPOUNDMENTS- DRAINAGE CHANNEL POWER PLANT MW-12 \MW-6 \ Jl MW-10 B11 i TREATED WASTEWATER ..... ,, \ IMPOUNDMENTSMW-ll . -f \ \ LEGEND: Indicates approximate location of monitoring well. Indicates approximate location of background boring. (^ Indicates number of impoundment. | [ Indicates approximate location of generalized geologic cross section. CSX KYU 12/M AS SHOWN MB »» 10*00706 200 400 Graohic Scale (Feet) FIGURE 3-1 SITE PLAN SDCJC ENONA POWER PLANT Ion.10BO-00-005 LEGEND A A Slope in direction of arrow •~« Valve (j) Control structure/sump CONTROL BUILDING TREATED WASTEWATER IMPOUNDMENTS LOW-VOLUME WASTEWATER IMPOUNDMENTS TREATMENT PLANT METAL-CLEANING WASTEWATER IMPOUNDMENTS TREATMENT PLANT TO PUNT DISCHARGE P) DISCHARGE PUMPS P-150 A It B "• TO PLANT DISCHARGE FROM POWER PLANT GRAPHIC SCALE (FEET) 100 10BOOOO1 FIGURE 3-2 PLAN VIEW OF SURFACE IMPOUNDMENTS IMPOUNDMENT CLOSURE PLAN SOC&t ENCINA POWER MM I I I 1 I U i I I /VUTTELH/1USER t.corpora hon SDG&E 3-4 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC Based on information supplied by SDG&E, the low-volume and metal-cleaning waste impoundments overlie the location of a former unlined waste impoundment. SDG&E has indicated that the unlined impoundment received discharges of low-volume and metal-cleaning wastes prior to construction of the present impoundments. Prior to construction of Impoundments No. 1 through 4, soils in the area of the former unlined impoundment were excavated and the area was filled. An additional lined impoundment was constructed in an area northeast of the present impoundments and was used as a temporary impoundment for low-volume and metal-cleaning wastes during construction of Impoundments No. 1 through 4. The impoundments were installed as double-lined with a 3-inch thick upper liner and a 2-inch thick lower liner, both constructed of hydraulic asphalt concrete (HAC). Figure 3-3 presents a schematic cross section of this impoundment liner design. Each impoundment has a leachate collection system which consists of 6-inch inner diameter perforated polyvinyl chloride (PVC) in an aggregate fill located between the liners. The leachate collection system drains into sumps at the control structures. The sump pumps are controlled by water-level sensors which activate the pumps and automatically pump leachate, if 'DRAIN CLEANOUT HYDRAULIC ASPHALT CONCRETE (3" thick) PERFORATED LEACHATE DRAIN. (6" inner d!ameter)\ PORTLAND CEMENT CONCRETE DRAIN FLUSHING RISER (3" Inner diameter)HYDRAULIC ASPHALT CONCRETE (2" thick) AFTER SDG&E. 1976. POND LINING SECTION VIEW. SHEET C-10. KKM 12/M NONE P1080 FIGURE 3-3 SCHEMATIC CROSS SECTION OF TYPICAL IMPOUNDMENT IMPOUNDMENT CLOSURE PLAN S3CJC ENCINA POWER PLANT A1ITTEL ion.1080-00-002 /MITTELH>4USER vcorpora hon SDG&E 3-6 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC detected, back into the impoundments. Flushing lines between the impoundment liners permit injection of water for the purpose of purging the leachate collection system. The installation details for the collection piping are presented in Figure 3-4. A summary of impoundment design characteristics, capacity and surface area is provided in Table 3-1. A groundwater subdrain system was installed beneath the lower liner of Impoundments No. 1 through 4 to relieve possible hydrostatic uplift pressures during periods of high groundwater elevations. The subdrain system consists of 6-inch perforated pipe, within aggregrate-filled trenches beneath the lower liners, that drains to a common collector and discharges to Agua Hedionda Lagoon (Figure 3-4). 3.1.1 Impoundment Operation The Encina Power Plant has six on-site surface impoundments and a wastewater treatment facility for the treatment of low-volume wastes and metal-cleaning wastes. Following treatment, impoundment wastewaters are discharged to the Pacific Ocean under National Pollutant Discharge Elimination System (NPDES) Permit No. CA0001350. Sediment that accumulates in the impoundments is analyzed and disposed in accordance with federal and state regulations. n GRQUNDWAJER SUBDRAIN SYSTEM • Perforated Subdrain (6")* — Subdrain Collector (6")* LEACHATE -COLLECTION SYSTEM — Inlet Piping (6")* - Perforated Drain (6")* — Drain Collector (6")* - Drain Flushing Riser (3")* Control Structure/Sump Drain Cleanout Impoundment Inlet Structure + Inner Diameter TREATED WASTEWATER IMPOUNDMENTS LOW-VOLUME WASTEWATER IMPOUNDMENTS METAL-CLEANING WASTEWATER IMPOUNDMENTS GRAPHIC SCALE (FEET) "*" HJTCMC »r rff ay "*"" KKM ' 1A11 12/88 ' sc'a- NOUE f° C10B00003 w FIGURE 3-4 GROUNDWATER SUBDRAIN AND LEACHATE COLLECTION SYSTEMS IMPOUNDMENT CLOSURE PLAN -— 5t>&4£ FNCINA PnWFR PI ANT Xi4n IH U JllCCI? I awa no 1 REV /MITTELHXUSER SDG&E Encina Power PlantClosure Plan Surface Date of Impoundment* Construction TABLE 3-1 IMPOUNDMENT CHARACTERISTICS ENCINA BAY POWER PLANT Estimated Approximate Approximate Storage Dimensions Area, Capacity (feet) sq.ft. (gallons) LVW No. 1 1978 115 X 80 9,200 x 11 (depth) LVW No. 2 1978 130 x 85 11,000 x 14 (depth) MCW No. 3 1978 140 x 90 12,600 x 15 (depth) MCW No. 4 1978 90 x 80 7,200 x 13 (depth) TW No. 5 1978 120 x 85 10,200 x 6 (depth) TW No. 6 1978 140 x 70 9,800 300,000 590,000 750,000 330,000 220,000 270,000 x 6 (depth) 60,000 2,460,000 * LVW: Low-volume waste MCW: Metal-cleaning waste TW: Treated wastewater b HAC - Hydraulic asphalt concrete. c Treated wastewater impoundments receive all metal-cleaning wastes wastes which are treated in the chemical treatment facility. December 1988 Rev: 0 P1080RR 1985 Estimated Impoundment Throughput Liner (gal x 10') Material 10.7 HAC" 3-inch upper 2-inch lower 12 . 6 Same 1 . 8 Same 2 . 2 Same 1 . 9 Same 1 . 9 Same and any low-volume /HITTELH/IUSER L.^corporation SDG&E 3-9 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC Metal-Cleaning Wastes. Metal-cleaning wastes are generated from chemical cleaning operations within the power plant/ including boiler fireside washes/ air preheater washes/ and boiler water-side acid and chelant (Vertan) cleanings/ hypochlorinator cleanings and reverse osmosis cleanings. Wastes are initially received in Impoundment Nos. 3 or 4 and then processed through the chemical treatment facility for removal of metals. Low-Volume Wastes. Sources of low-volume wastes typically discharged to surface impoundments include: evaporator blowdown, sample line discharges/ floor drain discharges/ demineralizer waste, zeolite softener waste, reverse osmosis brine, and condenser cleaning waste. These wastes are typically received in Impoundment Nos. 1 and 2. If an analysis indicates compliance with the plant's NPDES permit limitations, low-volume wastes are discharged along with the plant's cooling water system in accordance with the NPDES permit; otherwise, they are processed through the chemical treatment facility prior to discharge. Treated Wastewater. Treated wastewater is discharged from the tanks in the chemical treatment facility into Impoundment /MITTELKMUSERcorpora hon SDG&E 3-10 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC Nos. 5 and 6. The treated wastewater is then discharged along with the plant's cooling water if chemical analyses indicate compliance with the plant's NPDES permit limitations. 3.2 MAXIMUM EXTENT OF OPERATION AND MAXIMUM INVENTORY The maximum extent of operations for the six pond system is approximately 1.5 acres in surface area. The maximum possible inventory, if all the ponds were simultaneously full of wastewater or treated water, is 2,460,000 gallons. The methods of operation would make this event highly unlikely, but it is reported per regulatory requirements. Table 3-1 presents impoundment characteristics for the Encina Power Plant. These facilities are not located within the 100-year floodplain. Rain run-off is diverted around the ponds by local grading. 3.3 WASTE IDENTIFICATION San Diego Gas & Electric provided detailed chemical analyses of the waste streams in their Hydrogeologic Assessment Report (HAR) submitted to the San Diego Regional Water Quality Control Board. Several tables from the HAR are reproduced here which summarize the waste composition information. /MITTELH/4USER vcorporation SDG&E 3-11 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC Chemicals that are used in boiler metal-cleaning operations and that may be present in low-volume wastes are shown in Tables 3-2 and 3-3, respectively. Results of chemical analyses of composite samples of metal-cleaning wastes, treated wastes, and low-volume wastes collected by SDG&E in 1985 are summarized in Table 3-4. Chemical analyses of treated and untreated water side acid cleaning wastes from the South Bay Power Plant are also provided in Table 3-4 and are considered representative of similar waste streams at the Encina Power Plant. Samples of treated, low-volume, and metal-cleaning wastewaters were collected from the Encina Power Plant impoundments in January 1986. Samples were analyzed for metals, general minerals, purgeable and extractable organics, and other constituents according to Environmental Protection Agency (EPA) test procedures. The results of these analyses and results of chemical analyses of filter cake samples collected by SDG&E in January 1986 and by Woodward-Clyde Consultants in April 1986 from the Encina chemical treatment facility are given in Table 3-5. Results of the analyses of a low-volume waste sludge sample collected from Impoundment No. 1 are also presented in Table 3-5. Chemical analyses of wastewater constituents were compared to the applicable soluble threshold limit concentrations (STLCs) for hazardous waste (CCR, Title 22, Article 11, Section 66699). For those constituents with established STLC values, TABLE 3-2 CHEMICAL CONSTITUENTS OF METAL-CLEANING OPERATIONS ENCINA POWER PLANT Acid Cleaning Chemicals 0 Hydrochloric Acid 0 Brornate 0 Thiourea 0 Citric Acid 0 Inhibitor - Dowell A120 Chemical Formula HC1 HOOCCH2C(OH) (COOH)CH2 Proprietary Chelant Cleaning Chemicals EDTA (Vertan 675) 0 Ammonium Hydroxide 0 Ammonium Bicarbonate 0 Inhibitor - Dowell A251 (COOH-H2C)2-N-CH2-CH2-N-(CH2-COOH) NH.OH4 NH.HCO.4 3 Proprietary Reverse Osmosis Unit Cleaning Chemicals 0 Polycarboxylic Acid 0 Sulfamic Acid Citric Acid [R] COOHn C,H.,NHSO,OHoil i HOOCCH2(OH)(COOH)CH2 Hypochlorinator Unit Cleaning Chemical Dilute Nitric Acid * Table from the Hydrogeologic Assessment Report Prepared for San Diego Gas and Electric Company HNOr Table 3-3 CHEMICAL CONSTITUENTS OF LOW-VOLUME WASTE ENCINA POWER PLANT Chemical Active Ingredient Nalco 8331 Nalco 1367b Nalco 71-D5b Nalco 7328b Nalco 356 Nalco 1362* Nalco 789* Nalco 1340* Nalco 750* Nalco 19-HC Nalco 7763 Monosodlum Phosphate Dibasic DIsodium Phosphate £Trisodium Phosphate Sulfuric Acid Hydrochloric Acid Nitric Acid Sodium Bichromate Sodium Hydroxide Sodum Nitrite-26Z Polyglycol-lOOZ Polyglycol/Fatty Acids-lOOZ Bis(tri-n-butyltin) oxlde-2.5Z Cyclohexamine-25Z Amlnomethylenephosphate-7Z Polyphospate-5Z Polyacrylate-lOOZ Polyoxylated Clycol-lOOZ Hydrazine-35Z Anionic Polymer-17Z Chemical Formula Use Where Used NaNCK NH2CCHCH-P04 CH2-CHOHCOOH NaH2P04 HC1 NaOH Corrosion Inhibitor Deposit Penetrant Defoamer Microbiocide Neutralizing Amine Deposit Inhibitor Deposit Inhibitor Deposit Inhibitor Antifoam Oxygen Scavenger Anionic Polymer Boiler Water Conditioner Boiler Water Conditioner Boiler Water Conditioner pH Control Regeneration Regeneration Regeneration Corrosion Inhibitor pH Control pH Control Regeneration Service Water Systems Service Water System* Service Water Systems Service Water Systems Condensate Systems Units 1,2,3 Evaporators Unit 5 Flash Evaporator Unit 5 Flash Evaporator Units 1,2,3 Evaporators & Unit 5 Flash Evaporator Boiler Wastewater Treatment Boiler Boiler Boiler Wastewater Treatment Deminerallzer Wastewater Treatment Hypochlorlnator Service Water Systems Wastewater Treatment Service Water Systems Demlneralizer .Evaporators are not presently in use. Use of these chemicals was discontinued in 1985. °Boller blowdown Is not discharged to the impoundments. However, Che boilers may occasionally be drained to the impoundment?. — Chemical formula hot available. * Table from the Hydrogeologic Assessment Report Prepared for: San Diego Gas and Electric Company Table 3-4 IKPOUNDMENT WASTESTREAM CHARACTERISTICS - 1985 SDC&E POWER PLANTS Wastestream Composite Samples (mg/1) South Bay Water-Side Water-Side Water-Side Acid Acid Acid • STLCb Constituents (mg/1) Antimony 15.0 Arsenic 5.0 Barium 100 Beryllium 0.75 Cadmium 1.0 Total Chromium 560 Chromium VI 5 Cobalt 80 Copper 25 Lead 5 Mercury 0.2 Molybdenum 350 Nickel 20 Selenium 1.0 Silver 5 Thallium 7.0 Vanadium 24 Zinc 250 PH S2,al2.5* Pentachlorophenol 1.7 Trichloroethylene 204 Acute Fish Toxicity 500 Reactivity g FlnmnabiHty h California Administrative Code, j Sample collected at SDG&E South 24-hour composite sample. , California Administrative Code, 100Z fish survival. ? California Administrative Code, California Administrative Code, Clean (Un- Clean (Un- Clean treated)0 treated)0 (treated) 9/27/85 fc — 0.005 — —0.08 K20 NA --2.9 1.5 — —43 —NA —1.0 41 NA NA NA 180 None None to boil Title 22, Bay Power Title 22, Title 22, Title 22, 11/3/85 -» —0.058 — —0.01 0.50 NA 0.19 8.8 0.4 —0.11 4.0 —NA —6.0 0.15 NA NA NA 1,800 None None to boll Article 11, Plant. Article 11, Article U, Article 11, 11/6/85 .. 0.026 — —0.01 —NA 0.07 — — —0.11 — —NA —2.0 —13 NA NA 49,000 None None to boil Section 66699 Section 66708 Section 66705 Section 66702 Untreated Chelant (Vertan) Clean 10/23/85 » 0.08 1.7 ——. 2.2 — —- 300 4.3 — —76.0 —NA —4 9.5 9.6 NA NA 4,200 i None to boil . . . Processed Water from Vertan Clean 11/4/85 ••— 0.094 — —0.01 0.25 —0.13 —0.4 —0.11 32.0 —NA — —0.05 12.3 NA NA 12,000 None None to boil Fireside Wash (Un- treated) 8/10/85 NA —NA NA — —NA NA 1.29 — —NA 24.8 — —' NA —3.96 5.2 — —<560,000 None NA Encina Fireside Wash (Un- treated) 10/26/86 ~_ 0.22 0.8 — —2.7 NA 1.76 2.20 0.6 — —31. 0.01 NA —17 3 3.0 NA NA 120,000 None None to boil Water from Fireside Wash (treated) 8/19/85 NA —NA NA — —NA NA — — —NA 1.2 — —NA — __ 5.8 NA NA f None NA Rainbow Tower Slowdown j/ 30/85 NA —NA NA —12.2 1.1 NA 1.33 — —NA —— - —NA —5.01 6.95 — —f NA NA . Low- Volume Waste3 8/1/85 MA —NA NA — —_- NA 0.12 — —NA 2.8__ __ NA__ 0.25 6.6 — —f None NA Releases bromine gas when oxidized. »-« - Not detected. NA • Not analyzed. * Table from the Hvdroeeoloeic Assessment- Itenorf Prona-rcsH fnT- • Ran T)T ocrr* fla ^ •3 T-» ^1 P T rt rt *- 1 Project 1 J35K-ENRP Parameter General Minerals PH Specific Conductance (umhos/cm) Filterable Residue (IDS) Sodium Potassium Calcium Magnesium Manganese Iron Chloride Bromide Fluoride Sulfate Nitrate (as NOj) Total Phdsphorous Alkalinity Carbonate Alk Bicarbonate Alk -Hydroxide Alk Total Alkalinity Table 3-5 IMPOUNDMENT WASTE CHARACTERISTICS - 1986 ENCINA POWER PLANT Solid Waste (mg/kg)Impoundment Wasteva'ter (mg/1) TTLC* S2.212.58 None None None None None None None None None None 18,000 None None None None None None None Filter Cak| (January) Dry NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Wet 10.1 NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Filter Cakec (April) 9.6 NA NA NA NA NA NA 620 64,000 NA ~ 0.1 NA — 1700 NA NA NA NA Low- Volume Waste Sludge (April) 7.4 NA NA NA NA NA NA 230 39,000 NA 0.23 NA — 3200 NA NA NA NA STLCe S2,a2.58 None None None None None None None None None None 180 None None None None None None None Treated ~ Wasteuater 8.8 8,500 7,000 2,300 7.1 33 3.8 0.01 0.4 3,900 — 0.49 520 ~ 0.3 42 31 0 73 Metal-Cleaning Wasteuater 2.5 10,000 6,000 1.700 6.8 11 45 1.8 200 3,800 — 0.27 170 — 4.4 ' 42 31 0 73 Low-Volume Wastewater 10.8 460 280 55 0.63 16 1.4 — — 30 — — 14 — 0.4 42 31 0 73 Projei >. 55935K-ENRP Table 3-5 (continued) IMPOUNDMENT WASTE CHARACTERISTICS - 1986 ENCINA POWER PLANT Solid Waate (mg/kg)Impoundment Wastevater (mg/1) Parameter Total Organic Nitrogen Ammonia Nitrogen Total Kjeldhal Nitrogen Mat a Is Arsenic Aluminum Antimony Bariun Beryllium Cadmium Copper Chromium Cyanide Lead Mercury Molybdenum Nickel Selenium Silver Thallium Vanadium Zinc me* None None None 300 None 500 10,000 75 100 2,500 500h None 1,000 200 3,500 2,000 100 500 700 2,400 5,000 Filter Cake (January) Filter Cakec Dry NA NA NA NA NA 302 NA 8.7 7,639 83 ~ 365 NA NA 14,350 NA NA 18 NA 2.026 Wet NA NA NA 32.4 NA NA 117 NA 3 2,078 32 0.043 141 0.099 NA 5,539 0.07 NA _- NA 782 (April) 1,900 —1,900 22 710 — 120 0.44 0.7 2,600 46 NA 100 — — 4,900 5.1 — — 1.300 700 Low-Volume Waste Sludged (April) 5,700 — 5,700 86 2,900 — 1,700 0.31 3.5 780 270 NA 670 14 -- 6,100 1.7 1.6 — 11,000 790 STLCe None None None 5 None 15 100 0.75 1.0 25 5h None 5 0.2 350 20 1 5 7 24 250 Treated Metal-Cleaning Low-Volume Wastevater Wastevater Wastevater 55 22 1 11 11 0.4 66 33 1.4 0.022 0.14 — 0.43 2.6 — — 0.044 0.26 0.097_ — — 0.6 0.18 NA NA NA — 0.001 0.0021 0.15 0.13 3.2 — — — 0.7 5.5 0.16 0.07 0.89 — Proj o. 55935K-ENRP Table 3-5 (concluded) IMPOUNDMENT WASTE CHARACTERISTICS - 1986 ENCINA POWER PLANT Solid Waste (mg/kg)Impoundment Wastevater (mg/1) Parameter Organic Compounds Oil and Crease Phenolics EDTA Hydrazine Thlourea 1,1, l-Trichloroe. thane Tetrachloroethylene Toluene Catbon Disulflde 2-4. Dlmethylphenol C10-C36 Hydrocarbon Matrix C16-C36 Hydrocarbon Matrix Acetophenone C-10 Nitrogen Compound Anfolecular Sulfur TTLC* None None None None None None None None None None None None None None None Filter Cakg Low-Volume . (January) Filter Cakec Waste Sludge Pry NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Wet (April) (April) 3.5 1000 170,000 NA — 54 NA 5.4 5.0 NA NA NA NA — 0.7 NA NA NA NA 10,000 NA -- 400,000 NA NA 40 NA STLC6 None None None None None None - None None None None None None None None None Treated Metal-Cleaning Low-Volume Wastewater Wastevater Wastevater 19 42 — 0.17 0.16 0.13 NA NA NA NA NA MA NA NA NA 0.002 0.001 0.010 0.800 -- 0.02 0.012 -- — — ~ 0.1 — 0.02 • 0.3 — Not detested, NA - Not analyzed * Total Threshold Limit Concentration, California Administrative Code, Title 22, Article 11, Section 66699. Sample collected and analyzed by SDG&E in January 1986. *' Sample collected from chemical treatment facility by WCC in April 1986. Sample collected by WCC from Low-Volume Waste Impoundment No. 1 in April 1986. " Soluble Threshold Limit Concentration, California Administrative Code, Title 22, Article 11, Section 66699. Samples collected b'y SDG&E and WCC from impoundments in January 1986. * California Administrative Code, Title 22, Article 11, Section 66708. TTLC and STLC provided are for Chromium VI. * Table from the Hydrogeologic Assessment Report Prepared for: San Diego Gas and Electric Company /MITTELhMUSER tcorporation SDG&E 3-16 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RC wastewater concentrations in January 1986 samples from the impoundments were below the applicable STLCs. However, 1985 composite waste stream samples of boiler water-side acid cleanings, at the South Bay Power Plant exceeded STLCs for nickel, toxicity and pH. Chelant cleanings and boiler fireside wash wastes at the Encina Power Plant exceeded STLC's for nickel and copper. Concentrations of copper and nickel in the 1986 filter cake sample exceeded the applicable total threshold limit concentrations [ (TTLCs) CCR, Title 22, Article 11, Section 666999] . Concentrations of nickel and vanadium in the 1986 low-volume waste sludge exceeded the applicable TTLCs. None of the constituents analyzed in wastewater samples exceeded criteria for restricted hazardous wastes (Section 25122.7, California Health and Safety Code). Furthermore, none of the concentrations of constituents analyzed in waste stream, wastewater, sludge, or filter cake samples exceeded TTLCs for extremely hazardous wastes (CCR, Title 22, Article 11, Section 36723) . /MITTELH/IUSER v'corporation SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD SECTION 4.0 CLOSURE PROCEDURES /HITTELU4USER t."corporation SDG&E 4-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD 4.0 CLOSURE PROCEDURES 4.1 CLOSURE PERFORMANCE STANDARDS During closure of the wastewater ponds at the Encina Power Plant, SDG&E intends to remove all wastes and contaminated materials to agreed upon levels from the wastewater ponds. Upon completion of closure activities, there will be no threat to human health or the environment. Extended post closure maintenance is therefore not anticipated. Until closure is complete, SDG&E will continue to take all steps to prevent threats to human health and the environment and will maintain current security operations. All closure activities will be conducted under supervision of an independent engineer or a registered engineering geologist. A detailed written narrative of closure activities will be prepared, certified and submitted to the regulatory agencies after closure has been completed. 4.2 SITE CLEANUP STRATEGY 4.2.1 Introduction The State of California requires removal or decontamination of waste residues, contaminated liners and contaminated subsoils when a surface impoundment is closed. This /MITTELH/4USER L.corporation SDG&E 4-2 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD requirement, in 22 CCR67288 and 23 CCR2582, does allow contaminated subsoil to remain at a closed surface impoundment if it can be shown that it does not pose "a significant hazard to water quality, public health, domestic livestock, wildlife or the environment." A site cleanup strategy for closure of the surface impoundments is described in this section. The strategy will be utilized to decide if subsoils are contaminated, and, if they are contaminated, whether the subsoils may be left on-site. 4.2.2 Analysis Parameters To develop a cleanup strategy, it is necessary to identify analysis parameters and the action levels that will indicate whether the subsoils are contaminated. The parameters to be analyzed are based on past analyses of four types of samples associated with the impoundments: 1. Waste streams that were discharged to the impoundments; 2. Wastewater in the impoundments; 3. Solids filtered or settled from the impoundments' contents; and 4. Soil samples from borings beneath and adjacent to the impoundments. The samples of the four media were taken as part of two earlier studies of the impoundments, "Hydrogeologic Assessment Report, Encina Power Plant," September 1986 and "Remedial Investigation, Encina Power Plant," February 1988. Analytical /V1ITTELH>1USERcorporation SDG&E 4-3 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD data tables from these reports are presented in Chapter 3.0 and in Attachment 4-1. Locations of the samples and discussions of the analytical results can be found in those studies. The following discussion will focus only on constituents that were present in the wastes placed in the impoundments and on waste constituents that were present in subsoil samples at concentrations greater than the background concentrations. Table 2.3-3 from the Hydrogeologic Assessment Report (HAR) is presented in Chapter 3.0, Table 3-4. It lists concentrations of metals and a few other parameters in waste stream composite samples. These analyses indicate that concentrations of copper and nickel in several waste streams exceeded the STLCs. Concentrations of metals and other parameters listed in Table 2.3-4 from the HAR and presented in Chapter 3.0, Table 3-5, indicate that filtered and settled solids from the impoundments were hazardous because total copper, nickel and vanadium exceeded the respective TTLCs. In addition, arsenic, barium, chromium, lead and mercury concentrations in these samples exceeded ten times the STLCs. Concentrations of metals in wastewater in the impoundments were less than the STLCs. Concentrations of other parameters, including specific organic compounds, were low in both the solids and wastewater. Oil and grease, phenolics, and hydrocarbons were high in the solids. TPH will be used as an indicator parameter for organics during closure. /V1ITTELH/4USER tcorporation SDG&E 4-4 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD Tables 7.2-1 and 7.2-2 from the HAR are presented in Attachment 4-1. They present analytical data for samples taken from borings around the perimeters of the impoundments. Samples Ell-2 (Table 7.2-1), E10-3, E10-7, Ell-2 and E12-2 (Table 7.2-2) are far enough away from the impoundments that they were considered background samples. A comparison of samples taken near the impoundments to the background samples was made. Those parameters whose concentrations exceeded twice the average background concentration, by soil type, include barium, chromium, copper, nickel and zinc. Samples near the impoundments were also compared in the HAR to the background samples using a statistical frequency distribution. This evaluation showed that beryllium, copper, nickel and zinc had bi-normal distributions, indicating two or more dissimilar sample populations. Based on the analytical data discussed above, the Regional Water Quality Control Board suggested that soil samples from beneath the impoundments be analyzed to determine the extent to which soil remediation might be necessary. SDG&E subsequently retained a consultant to perform a RI. Table 5.2-1 from that report is presented in Attachment 4-1. Analytical data for nine metals and total petroleum hydrocarbons are listed in that table. The samples came from borings through the bottoms of the impoundments and were intended to show if contamination had occurred directly beneath the impoundments. The parameters selected for these analyses are the same as those which were /HITTELH/IUSER t.corporahon SDG&E 4-5 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD mentioned above as being in the wastes or in soils at concentrations greater than background concentrations. In the RI the data presented in Table 5.2-1 were compared to background data using Cochran's approximation to the Behrens-Fisher Student's t-test. Arsenic, chromium/ nickel/ lead and vanadium concentrations were statistically different by this evaluation. The results of the statistical analysis is presented on Tables 6.1 and 6.2 in Attachment 4-1. Based on the extensive past analyses described above/ 11 parameters will be analyzed during closure: total petroleum hydrocarbons/ pH, arsenic, barium, chromium, copper, mercury/ nickel, lead, vanadium and zinc. Total petroleum hydrocarbons was selected as a screening parameter to indicate migration of petroleum wastes from the impoundments; pH will indicate the extent to which acidic or basic wastewaters have altered soil chemistry. The nine metals are those that have been present in relatively high concentrations in wastes or subsoils according to the criteria discussed above. /V1ITTELH/1USERcorpora hon SDG&E 4-6 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD 4.2.3 Cleanup Levels Cleanup levels will be based on naturally occurring total background concentrations of the 11 parameters. The basis for determining cleanup levels in soils is presented in Attachment 4-2. For each parameter a separate cleanup level will be calculated for each soil type and for each of the two impoundment areas. There are analytical data for four background samples in the HAR and for ten samples in the RI. SDG&E will use this data and augment it with data from four borings/ two each in uncontaminated areas near the two impoundment areas. Samples will be taken every two feet to groundwater in each boring. A minimum of two and a maximum of four samples will be analyzed from each soil or formation type in each boring. The other samples will be archived for possible later analysis. Soil cleanup levels for total metal concentrations equal to the mean plus three standard deviations will be calculated separately for each soil type in each of the two impoundment areas. The basis for mean plus three standard deviations is presented in Attachment 4-2. Samples beneath the surface impoundments will be analyzed for the same 11 parameters as the background samples. /MITTELH/1USER vcorporation SDG&E 4-7 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD The total metal concentrations in potentially contaminated soils will then be compared to the cleanup levels to determine whether significant contamination has occurred. If the concentration of any metal exceeds the respective cleanup level, the soil may be sampled and analyzed again. The reanalysis must confirm contamination or the soil will be considered clean. Alternate approaches may be proposed to the regulators by SDG&E for addressing low levels of contaminants. One such approach is presented in Attachment 4-3. This Attachment describes procedures used under similar site circumstances where there were no beneficial uses of the shallow groundwater with elevated metals. Samples were analyzed using a deionized water extraction. The extraction evaluates the potential for metal ions to migrate through soils. The rational for using this test which has been approved by regulators is presented in Attachment 4-3. The basis for this decision is available health-based information. Alternatively, contaminated soil may be treated in place. Once the spatial extent of soil contamination is determined, the soils will be excavated for proper disposal or treatment. After removal or treatment of contaminated soil, confirmation samples will be taken in which pH and total concentrations of the nine metals will be analyzed. If earlier samples exceeded the background standards for total petroleum /MITTELH>4USER^corporation SDG&E 4-8 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD hydrocarbons, hydrocarbons will also be measured in the confirmation samples. Analytical results from the confirmation samples are expected to indicate that contamination has been removed or successfully treated. However, if the tests show contamination still exists, up to two feet more of soil will be removed and the soils retested. Sampling, analysis and removal will continue until the soil is found to be uncontaminated or groundwater is reached. If excessive contamination exists, SDG&E may decide to leave the contaminated soils in place and proceed with post-closure. In the latter event, the regulatory agencies will be contacted and a remedial action plan developed. The site cleanup strategy is summarized in Attachment 4-4, Closure Decision Diagram. The diagram shows what tests will be run and how the results will be used to determine waste classifications for soil underlying the surface impoundments. 4.3 APPROACH TO CLOSURE This section is a description of SDG&E's overall approach for closure of the surface impoundments. Extensive analytical data associated with soils and groundwater underlying the impoundments and the asphalt liners of the impoundments have already been collected. The analytical data, which is described in Section 4.3.1, will be supplemented during closure by additional sampling in contaminated areas. /MITTELhMUSER vcorporahon SDG&E 4-9 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD Closure activities are summarized in Section 4.3.2; the actual closure steps are described in Section 4.4. During implementation of the closure steps, samples of water/ asphalt concrete, gravel and soils will be collected. Attachment 4-5, "Sampling and Analysis Plan," describes the procedures for collecting and analyzing the samples. 4.3.1 Existing Analytical Data As mentioned above, extensive soils characterization data have been previously collected by SDG&E as part of two earlier studies, "Hydrogeologic Assessment Report, Encina Power Plant," September 1986 (HAR) and "Remedial Investigation, Encina Power Plant," February 1988 (RI). Data tables from these reports are reproduced in Chapter 3.0 and Attachment 4-1. During the implementation of the RI, samples of the asphalt liners (upper and lower) and soils underlying the surface impoundments were obtained and analyzed. The groundwater monitoring data collected through 1987 was reviewed for significant increases. Samples of the asphalt liners (upper and lower) were obtained and analyzed for moisture content, pH, TTLC and STLC. These results indicated that the liners are not hazardous /MITTELH/IUSERcorporation SDG&E 4-10 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD materials. These results are presented in Attachment 4-1, Table 5.1. The soil samples underlying the surface impoundments were collected and analyzed for moisture content, total petroleum hydrocarbons (TPH), pH, TTLC and STLC. These results indicated that none of the soils underlying the surface impoundments are hazardous materials except for LVW 2. The STLC limit for vanadium, 24 mg/1, was exceeded in boring B-2 at a depth of 1.5-2.5 feet. These results are presented in Attachment 4-1, Tables 5.2-1, 5.2-2 and 5.3. The soil and groundwater analytical data were then evaluated statistically to determine if significant contamination had occurred. The results of these evaluations are shown in Tables 6.1 and 6.2 in the RI. These tables are reproduced in Attachment 4-1. Soil beneath the Low Volume Waste Pond 1 (LVW 1) was found to be contaminated with chromium and nickel and copper. The soil beneath the Low Volume Waste Pond 2 (LVW 2) was found to be contaminated with nickel and vanadium. Soil beneath LVW 1 and Metal Cleaning Waste Pond 4 (MCW 4) had an extreme value for vanadium concentration. /MITTELHMUSERcorporation SDG&E 4-11 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD Soil beneath Treated Waste Ponds 5 and 6 (TW 5 and 6) was found to have a statistically significant level of arsenic. This increase may be from comparing the soil results to background levels which may not represent the material underlying the impoundments. Finally, groundwater in well 5/ adjacent to TW 5, showed statistically significant levels of nickel. After reviewing the RI, the California Regional Water Quality Control Board (RWQCB), San Diego Region, concluded in a letter dated May 11, 1988, that "a polluted vadose zone exists beneath LVW impoundment No. 2". The RWQCB has required soil remediation beneath LVW 1 and 2. The May 11 letter is presented in Attachment 4-6. Based on the soil results and the statistical analyses described above and the conclusions of the RWQCB expressed in the May 11 letter, SDG&E proposes to sample soil beneath LVW 1 and 2 during closure to determine the extent of contamination. The samples of soil beneath the other four ponds did not indicate any contamination in levels which would require remediation. However, since these ponds will not be closed for approximately two years, random soil sampling and analysis will be performed during closure to verify that no soil contamination exists. /MITTELH>1USER t.corporation SDG&E 4-12 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD 4.3.2 Summary of Closure Activities At the start of closure/ discharges to the surface impoundments will cease, and any remaining wastes in the ponds will be treated in the wastewater treatment system and discharged to the Pacific Ocean in compliance with the plant's NPDES permit. Piping to the surface impoundments that will not be used with the above grade tank system will be flushed with water. The final wash water will be tested to confirm that the lines are decontaminated. The lines will then be either abandoned in place or removed and either disposed off-site. The impoundments themselves will be washed or cleansed using high pressure water and/or steam, as appropriate. The resulting wastes will be pumped to the wastewater treatment system for treatment and then discharged in accordance with the NPDES permit. Alternatively, the wastes may be placed in portable tanks and then disposed of off-site at an approved disposal site. After cleaning is completed, the surface impoundments will be inspected for structural damage and visible contamination on the asphalt liner. The inspection will be performed as described in Attachment 4-5, Sampling and Analysis Plan. The two liners and the gravel between the liners will be sampled and analyzed to demonstrate that they have been ^ITTELH/IUSERcorporation SDG&E 4-13 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD decontaminated. If structural damage or areas of visual contamination are reported during the inspection, the asphalt concrete liners and gravel between the liners will be sampled at that point. If no deterioration is observed during the inspection, the sample points will be randomly selected for the units which have no previous indication of contamination. At LVW 1 and 2, sample points will be selected authoritatively in order to help determine the extent of existing contamination. Samples from each boring will be taken and analyzed for metals in accordance with the Sampling and Analysis Plan, Attachment 4-5. Previous analysis has shown the liners to be non hazardous. However, if the liner or gravel is hazardous, it will be transported off-site to a hazardous waste disposal facility. If the liners and gravel are not hazardous, they will either be broken up and buried on site or excavated and transported to an off-site facility, such as a municipal landfill. The choice of the method for disposal will depend on the classification by the RWQCB of the backfilled surface impoundments. If the RWQCB plans to classify the surface impoundments as landfills if the asphalt and gravel are buried, the liners and gravel will be disposed of off-site. If the RWQCB does not classify the impoundments as landfills, SDG&E will dispose of the these materials with the backfill material placed in the impoundments. /HITTELH4USERcorporation SDG&E 4-14 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD Soil samples will be taken below or around each impoundment to determine if any contamination exists below the ponds or, if necessary, the vertical and horizontal extent of any soil contamination underlying the ponds. The sampling locations will be randomly selected in the units where previous analysis does not indicate significant contamination and liner deterioration is not evident. Sampling locations will be authoritatively placed in units where, based on the history of the site, analytical results presented in the RI, and results of the inspection of the liner, contamination is suspected or confirmed. Soil will be segregated by classification: background, contaminated (statistically greater than background levels) and hazardous. Contaminated soils will be disposed based on their classification as either hazardous or non-hazardous waste. Soils with concentrations less than the background levels will be left on-site. After removal of contaminated soils, additional confirmation samples will be taken and analyzed for the identified constituents. SDG&E will work closely with the regulatory agencies during implementation of the soil sampling and analysis activities. Should excessive soil contamination preclude clean closure, a revised closure plan and a post-closure plan will be submitted. The revised closure plan will outline the activities /MITTELH/1USER vcorporation SDG&E 4-15 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD to close the area as a landfill and will describe the activities that will be completed during the post closure period. 4.4 FINAL CLOSURE ACTIVITIES / Final closure of the impoundments will commence approximately two months after the new aboveground tank system has been operating. The expected starting date for closure activities is August 1990. However, this date may be impacted due to local grading requirements which are out of SDG&E's control. These requirements do not allow grading operation to occur between October and April Normal operation includes treatment of wastewater and discharging to the Pacific Ocean in compliance with the NPDES permit and removal of sludges by a registered hauler to an approved off-site facility. It is expected that the impoundments will be empty/ or nearly empty/ at the start of closure operations. Throughout closure, SDG&E will consult with the regulatory agencies to inform them of any unexpected events which might impact the closure activities and will notify them at least 48 hours prior to inspection of the impoundments, sampling activities and removal of the liners. /MITTELH/IUSER t.corporation SDG&E 4-16 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD The following closure steps will be implemented after approval of the Closure Plan by RWQCB and DHS: Step 1: Notify RWQCB and DHS 14 days before implementation of the approved Closure Plan. Prepare Site Specific Health and Safety Plan for the implementation of the closure plan. Step 2: Treat any wastewater and sludges remaining in the pond using the wastewater treatment system. Discharge the treated wastewater to the Pacific Ocean in compliance with the NPDES Permit. The sludges will be dewatered and disposed of as a hazardous waste. Step 3: Disconnect the piping associated with the surface impoundments. Step 4: Wash the surfaces of the impoundment liners to remove any remaining waste residues. The asphalt concrete will be washed using either a hydroblaster or steam cleaner. The wash water will be collected using a pump or vacuum truck and placed in a portable tank or will be transferred to the wastewater treatment system. Step 5: Flush with water the piping that is associated with the surface impoundments and will not be used with the new tank system. The flush water will be collected in the surface impoundments. A sample of the flush water will be obtained and analyzed for the parameters listed in the Sampling and Analysis Plan, Attachment 4-5. If the flush water is hazardous, the piping will be flushed and the water sampled again. This will continue until the piping flush water is not hazardous. After flushing of the piping is complete, the flush water will be treated in the wastewater treatment system. Flushed piping will be abandoned inplace. Step 6: Inspect the asphalt concrete liner for structural damage and any signs of leakage. Document the inspection as described in Part C of Attachment 4-5, "Sampling and Analysis Plan." Step 7: Sample and analyze the asphalt concrete (top and lower) liners and the gravel between the liners in accordance with the Sampling and Analysis Plan in Attachment 4-5. The analytical results will be compared to the background values identified in the RI. /VIITTELH/1USER ucorpora rion SDG&E 4-17 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD The material will be left on-site or disposed at an appropriate landfill, depending on analytical results and the RWQCB determination of the classification of the material. The material will be left on-site if RWQCB agrees that this would not constitute a landfill regulated under Title 23. If on-site disposal will result in the area being regulated as a landfill/ the material will be excavated and disposed at an appropriate off site landfill. Step 8: Test the underlying and surrounding soil for contamination. Evaluate and decontaminate the site as described in Section 4.3, Site Cleanup Strategy. See Attachment 4-5, "Sampling and Analysis Plan," for detailed procedures. Step 9: Remove any contaminated soil and dispose as appropriate based on its waste category. Step 10: Confirm that the site is decontaminated by testing for total petroleum hydrocarbons, pH and metals in accordance with the Sampling and Analysis Plan. If contamination exists, continue soil removal and testing until site is decontaminated. If soil analyses demonstrate low levels of contamination, SDG&E may propose using a deionized water extraction test for evaluating the potential threat to human health or the environment from the metal ions in the soils. A rationale for this methodology is presented in Attachment 4-3. If excessive contamination is found, meet with regulatory agencies and develop a revised closure plan and a post-closure plan. Step 11: Backfill the excavation with the existing berms and supplement as necessary with clean fill material. Step 12: Certify closure of the surface impoundments in accordance with the approved Closure Plan. Submit to DHS and RWQCB certification by SDG&E and an independent professional engineer or a registered engineering geologist (registered in California) that the surface impoundments have been closed in accordance with the approved Closure Plan. An independent engineer and/or a registered engineering geologist will direct the appropriate steps of closure. /MITTELH>1USER vcorporation SDG&E 4-18 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD 4.5 SCHEDULE FOR CLOSURE After approval of the Closure Plan, all hazardous wastes will be emptied from the surface impoundment within 90 days following the start of closure, as required. All closure activities will comply with the approved Closure Plan and will be completed within the required 180 day time period. The time period to complete closure may be extended due to local grading activity restrictions during the months between October and April which are out of SDG&E's control. The following table shows the estimated time required to complete each step of the closure process. Days Required to Closure Activity Complete Activity 1. Notify regulatory agencies 2. Remove wastes from impoundments 10 3. Disconnect pipelines 10 4. Flush and sample pipelines 5 5. Decontaminate impoundments 5 6. Inspect concrete 5 7. Sample and dispose of liner material 30 8. Sample and test underlying soil 30 9. Remove contaminated soil 40 10. Retest soil and remove as necessary 25 11. Backfill excavation 15 12. Certify closure 5 TOTAL 180 days 41ITTELH/1USERcorporation SDG&E 4-19 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD 4.6 POST-CLOSURE PLAN It is assumed that no hazardous wastes or constituents above background levels will remain in soil surrounding the impoundments after closure. If, during closure, the results of the sampling and analysis program indicate subsoils to be hazardous and SDG&E makes the decision to not remove the hazardous waste, a Post-Closure Plan will be prepared and submitted to EPA, DHS and RWQCB for approval, in accordance with State and Federal Regulations. /MITTELKMUSER ucorpora Hon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RD ATTACHMENT 4-1 ANALYTICAL DATA FROM RI Project No. 8753249K-ENRP TABLE 5.1 HAG CORE SAMPLE ANALYSES ENCINA POWER PLANT (Units • rag/kg, unless noted otherwise) Impoundment Background LW1 MCW4 TW6 Liner Patch Mix Patch Mix* Patch Mix* Upper Lower Upper Lower Upper Lower Sample I.D. Number ENC-NPA-HAC-10/28 SB-NPA-HAC-10/27 SB-NPA-HAC-11/3 ENC-P1-B1-UL ENC-P1-B1-LL ENC-P4-B6-UL ENC-P4-B6-LL ENC-P6-B10-UL ENC-P6-B10-LL Detection Limits TTLC Moisture Content (Z) ND ND ND 2.16 5.39 ND ND ND ND 1.0 NA PH (units) 6.77 7.29 6.98 7.26 7.12 10.65 9.79 9.74 9.16 — NA As 2.3 4.8 3.3 5.1 7.7 ND 8.9 ND 9.0 1.0 500 Ba 18.2 25.7 12.4 51.2 30.1 9.6 30.3 7.6 29.1 NA 10000 Cr 2.9 1.1 7.6 17.6 2.6 2.1 ND ND ND 0.5 500 Cu 10.6 5.2 27.4 32.4 10.6 10.8 19.1 17.6 12.2 NA 2500 Hg ND ND ND 2.6 ND ND ND ND ND 0.25 20 Ni 16.3 7.8 10.5 204.0 15.3 10.4 13.7 11.0 10.7 NA 2000 Pb 1.0 ND ND 39.3 1.5 3.1 1.7 2.3 2.4 1.0 1000 V Zn 10.5 5.7 17.5 8.3 10.2 7.6 221.0 14.9 22.4 10.0 16.2 9.1 22.0 25.9 5.5 8.9 14.4 9.8 NA NA 2400 5000 HAC CORE WASTE EXTRACTION TESTS (Units - ng/I) LVW1 MCW4 TW6 Upper Lower Upper Lower Upper Lower ENC-P1-B1-UL ENC-P1-B1-LL ENC-P4-B6-UL ENC-P4-B6-LL ENC-P6-B10-UL ENC-P6-BIO-LL Detection Limits STLC — — ~ — NA — — — -- NA 0.02 0.08 0.04 0.04 ND ND 0.02 5.0 3.6 0.8 0.4 1.3 0.7 1.1 NA 100.0 0.1 ND ND ND ND ND 0.1 5.0 ND ND ND 0.8 ND ND 0.2 25.0 ND ND ND ND ND ND 0.005 0.20 0.9 ND ND 0.1 ND ND 0.1 20.0 1.8 ND 0.02 0.31 ND ND 0.02 5.0 2.6 0.2 ND ND ND ND 0.4 0.4 ND ND ND ND 0.1 0.1 24.0 2SO.O Abbreviations:As - Arsenic, Ba • Barium, Cr " Chromium, Cu - Copper, Hg » Mercury, Nl - Nickel, Pb - Lead, V - Vanadium, Zn • Zinc, ND - Not detected above laboratory detection limit — • Not Analyzed NA - Not Applicable/Not Available LVW1 • Low-Volume Waste Impoundment No. 1 MCW4 - Metal-Cleaning Waste Impoundment No. 4 TW6 - Treated Waste Impoundment No. 6 *Parch Mix samples from South B.iv site Project No. 8753249K-ENRP TABLE 5.2-1 1987 SOIL CHEMICAL ANALYSES ENCINA POWER PLANT (Units - mg/kg, unless noted otherwise) LVW AND MCW IMPOUNDMENT BORINGS Impoundment West Background LVW1 LVW2 MCW3 MCW4 Approximate Depth Interval Sampled* Boring (feet) B-12 0.5-1.0 2.0-2.5 5.0-5.5 10.0-10.5 17.0-17.5 B-l 0-0.5 1.0-1.5 3.5-4.0 5.0-5.5 11.5-12.0 B-2 ' 0-1.0 1.5-2.5 2.5-3.5 12.0-13.0 B-3 0-1.0 1.5-2.0 3.5-4.0 7.5-8.0 9.5-10.0 B-4 0-0.5 1.0-1.5 3.5-4.5 8.0-9.0 B-5 0.5-1.5 2.0-3.0 3.0-4.0 8.0-9.0 B-6 0.5-1 J 2.0-^.5 3.5-4.0 7.0-7.5 ASTM* Soil Type (SM/SC) (SM/SC) (SM) (SO (SP) (SM) (SM) (SM/SP) (SC) (SM) (SP) (SP) (SM/SC) (SP) (SP/SC) (SM/SC) (SM/SC) (SM) (SP) (SW) (SW) (GP) (SP) (SW) (SW) (SW) (SP) (SO (SM/ML) (SC) (SW) Sample Moisture I.D. Content Number (Z) ENC-WBB-B12-1 10.7 ENC-WBB-B12-2 10.7 ENC-WBB-B12-4 9.53 ENC-WBB-B12-5 10.6 ENC-WBB-B12-7 21.5 EN-P1-B1-1 9.53 EN-P1-B1-2 8.29 EN-P1-B1-4 7.99 EN-P1-B1-5 10.60 EN-P1-B1-9 16.90 ENC-P2-B2-1 ND ENC-P2-B2-2 11.6 ENC-P2-B2-3 12.3 ENC-P2-B2-9 19.9 ENC-P2-B3-1 10.6 ENC-P2-B3-2 14.5 ENC-P2-B3-4 15.1 ENC-P2-B3-7 25.7 ENC-P2-B3-9 21.4 ENC-P3-B4-1 6.53 ENC-P3-B4-2 9.41 ENC-P3-B4-5 1.46 ENC-P3-B4-8 21.0 ENC-P3-B5-1 5.82 ENC-P3-B5-2 5.86 ENC-P3-B5-3 9.96 ENC-P3-B5-6 18.6 ENC-P4-B6-1 12.9 ENC-P4-B6-2 6.69 ENC-P4-B6-3 11.9 ENC-P4-B6-4 8.16 Detection Limits: 1.0 TTLC NA Total Petroleum Hydrocarbons (Method pH 418.1) (Units) 3 5 24 8 ND 170b 17 11 52 62 420b 40 96 3 24 3 ND 22 12 37 81 23 12 220b 87 13 10 7 ND 31 11 1.0 NA 8.28 6.07 9.20 9.60 9.02 7.59 6.98 7.10 8.05 7.95 6.48 8.33 8.95 5.91b 8.73 8.48 8.72 8.59 8.28 5.95b 8.38 7.89 8.32 8.73 8.70 8.12 8.42 7.93 7.41 6.15 4.82b> NA NA As 4.5 3.3 8.8 2.5 1.7 5.1 7.0 4.2 7.7 7.5 1.7 3.8 4.9 ND 5.8 6.0 5.3 1.4 ND 3.7 3.6 2.0 ND 1.8 1.9 2.5 ND 3.0 3.7 2.7 1.0 1.0 500 Ba 59.9 40.4 56.3 32.1 22.8 31.9 35.7 27.0 43.1 50.0 44.6 65.0 66.2 12.2 87.0 128. Ob 86.6 26.0 8.0 23.9 47.8 5.7 5.9 30.9 19.8 17.0 6.4 21.1 21.3 25.2 8.6 NA 10000 Cr 5.5 5.2 5.5 5.2 3.3 7.7 10.9 7.9 7.5 9.9 6.3 5.2 1.6 2.6 4.5 1.9 5.7 6.2 1.9 4.8 5.2 5.2 4.3 3.6 3.4 2.0 4.5 6.0 4.4 5.0 5.5 NA 500 Cu 8.0 4.2 5.7 2.2 1.1 9.0 11.0 8.1 11.0 10.7 5-V12. lb 6.7 1.2 3.4 1.4 1.5 1.7 ND 5.6 3'6b22.5b 2.6 3'6b30. Ob 2.1 1.7 3.5 2.0 11. lb 2.5 1.0 2500 «R ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND 0.25 20 Nl 3.1 1.5 2.3 1.7 ND 6.4 4.8 11.3 42.7b 4.2 !'*b214.0b 3.5 ND 4.6 1.6 ND ND ND 4.4 2.2 5.6 3.0 1.5 4.2 2.2 3.1 7.4b 3.5 3.4 2.0 1.0 2000 Pb 5.0 5.9 15.2 3.9 2.2 2.9 4.7 2.0 4.0 4.5 2.0 8.3 5.4 ND 4.6 4.9 4.1 6.4 ND 3.5 3.2 3.1 1.1 2.3 2.1 1.7 1.4 4.0 4.4 2.9 1.7 1.0 1000 V 15.8 19.5 17.1 13.1 10.0 25.8 23.1 30.6 118.0b 18.5 37.5. 530.0b 16.2 9.2 20.1 7.7 11.1 10.2 6.3 24.1 20.0 11.8 10.7 15.2 17.6 11.3 14.3 25.0b 16.6 16.9 16.4 NA 2400 Zn 36.3 17.3 26.8 12.7 9.6 13.7 16.7 13. !•< 12.8- 21. 3X 13.4 15. 8£ 19.0 4.2 15.4 12.4 17.6 7.0 2.7 14.1 13.8 16.0 6.3 12.2 7.8 6.4 9.3 10.0 6.1 27.5 3.6 NA 5000 Project . 8753249K-ENRP TABLE 5.2-1 (concluded) 1987 SOIL CHEMICAL AHALYSES ENCINA POWER PLANT (Units - mg/kg, unless noted otherwise) TW IMPOUNDMENT BORINGS Approximate Depth Interval Sampled* Impoundment Boring (feet) East B-ll 9.5-10.0 Background 10.5-11.0 12.0-12.5 23.5-24.0 32.0-32.5 TW5 B-7 0.5-1.0 2.0-2.5 5.0-5.5 13.5-14.0 24.0-25.5 B-8 0,5-1.0 2.0-2.5 5.0-5.5 | O C 1 /, ft1 J* 3— iH .U 26.0-26.5 TW6 B-9 0.5-1.0 2.5-3.0 3.5-4.0 7.5-8.0 12.5-13.0 22.0-22.5 B-10 0.5-1.0 2.0-2.5 3.5-4.0 12.5-13.0 19.0-19.5 ASTMa Soil Type (GW) (GW) (SW) (SM/SW) (SM/SC) (SC) (SC) (SW) (SW) (SW/SC) (SC/SW) (SC/SW) (SP) fCD\(SP) (SM) (SW) (SW) (SW) (ML/CL) (SW) (GP) (SW) (SW) (SW) (SC/SW) (SC/SW) Sample I.D. Number ENC-EBB-B11-2 ENC-EBB-B11-3 ENC-EBB-B11-4 ENC-EBB-B11-6 ENC-EBB-B11-9 ENC-P5-B7-1 ENC-P5-B7-2 ENC-P5-B7-4 ENC-P5-B7-6 ENC-P5-B7-11 ENC-P5-B8-1 ENC-P5-B8-2 ENC-P5-B8-4vur* DC 11 Q AtnL— rj— Bo— D ENC-P5-B8-12 ENC-P6-B9-1 ENC-P6-B9-2 ENC-P6-B9-3 ENC-P6-B9-4 ENC-P6-B9-5 ENC-P6-B9-9 ENC-P6-B10-1 ENC-P6-B10-2 ENC-P6-B10-3 ENC-P6-B10-5 ENC-P6-B10-7 Detection Limits: TTLC: Moisture Content (Z) 4.53 2.77 4.40 6.99 20.5 5.77 5.40 2.66 6.12 14.6 7.50 5.46 7.24 A C 1 19.0 5.75 2.61 1.81 14.7 4.03 12.4 2.40 9.60 2.93 4.10 8.94 1.0 NA Total Petroleum Hydrocarbons (Method pH 418.1) (Units) As ND 16 4 ND 2 5 ND ND 10 38 19 5 ND wnN1J ND ND ND ND ND ND 25 ND 4 ND ND 33 1.0 NA 7.31 1.9 7.19 ND 7.15 1.7 6.95 ND 7.23 ND 7.91 2.8 7.99 5.4 8.09 ND 8.31 ND 7.45 ND 7.98 2.3 8.01 2.8 7.62 2.2 8 QQ 1 f*oy i . / 7.90 4.2 6.29 4.8 6.61 1.2 6.66 ND 8.50 3.7 9.03 1.8 8.06 1.5 8.69 1.2 8.15 4.5 8.39 1.1 7.90 ND 6.90 2.0 NA 1.0 NA 500 Ba 23.2 11.6 39.4 6.4 8.9 19.8 30.2 14.5 6.9 8.2 25.2 20.5 38.2 8 C*3 18.4 20.2 11.7 7.1 33.3 7.6 7.6 12.0 24.4 13.1 4.6 17.7 NA 10000 Cr 4.8 1.5 5.5 1.9 2.7 5.3 6.4 2.1 2.2 1.4 5.4 4.3 7.3 2 1.4 3.5 7.7 2.8 3.0 5.8 1.8 1.6 2.9 5.2 2.3 1.3 3.6 NA 500 Cu 1.9 3.2 1.6 1.6 1.1 1.1 1.1 ND ND ND 2.6 ND ND 1.2 1.6 ND ND 3.5 1.2 2.1 ND ND ND ND 3.3 1.0 2500 Hg ND ND ND ND ND ND ND ND ND ND ND ND ND UT\NL> ND ND ND ND ND ND ND ND ND ND ND ND 0.25 20 Nl 2.2 ND 1.4 ND ND 1.3 1.9 ND ND 1.1 1.9 1.3 3.4 2 ft• U 2.6 2.0 ND ND 1.5 1.2 ND ND 1.0 ND ND 1.7 1.0 2000 Pb 2.0 1.3 1.6 1.5 2.6 2.4 2.3 2.7 3.8 2.3 3.1 2.0 1.3 4.5 2.9 1.1 1.3 5.7b 2.1 2.8 1.7 2.7 1.6 2.5 3.9 1.0 1000 V 14.3 5.8 18.3 8.8 15.5 19.6 19.4 7.1 13.7 6.2 21.2 14.8 19.0 8.5 25.9 7.9 3.5 17.4 13.2 10.0 7.6 16.8 7.6 8.5 14.3 NA 2400 Zn 8.0 7.8 17.1 8.0 9.8 6.7 11.6 3.7 6.2 3.8 10.0 6.6 17.9 17.0 8.3 4.0 1.7 14.8 3.8 8.6 4.3 8.5 5.5 6.0 11.8 •A 5000 Abbreviations:As - Arsenic, Ba » Barium. Cr - Chromium, Cu - Copper, Hg " Mercury, Ni - Nickel, Pb - Lead, V - Vanadium, Zn - Zinc. ND • Not detected above laboratory detection limit ~ • Not Analyzed NA - Not Applicable/Not Available LVW1 - Low-Volume Waste Impoundment No. 1 MCW4 - Metal-Cleaning Waste Impoundment No. 4 TV6 - Treated Waste Impoundment No. 6 *Patch Mix samples from South Bay site 'Symbol Is the Unified System Classification of Soils for Engineering Purposes, ASTM Designation D-2487 CL - Clays, ML - Silts, SC • Clayey Sands, SM • Silty Sands, SP - Poorly graded (well sorted) Bands, SW - Well-graded . (poorly sorted) sands, GP - Poorly graded gravels, GW - Well-graded gravels Indicates soil samples which were statistically analvzed as potential extreme values Project No. 8753249K-ENRP TABLE 5.2-2 1987 SOIL CHEMICAL ANALYSES WASTE EXTRACTION TESTS ENCINA POWER PLANT (Units - mg/1) Impoundment LVWl LVW2 MCW3 MCW4 TW5 TW6 Boring 8-1 B-2 B-3 B-5 B-6 B-8 B-9 B-10 Approximate Depth Interval Sampled* (feet) 1.0-1.5 5.0-5.5 0-1.0 1.5-2.5 1.5-2.0 0.5-1.5 2.0-3.0 3.5-4.0 7.0-7.5 5 .'0-5.5 12.5-13.0 19.0-19.5 ASTM* Soil Type (SM) (SC) (SP) (SP) (SM/SC) (SW> (SW) (SC) (SW) (SP) (SW) (SC/SW) Detection STLC Sample I.D. Number ENC-P1-B1-2 ENC-P1-B1-5 ENC-P2-B2-1 ENC-P2-B2-2 ENC-P2-B3-2 ENC-P3-B5-1 ENC-P3-B5-2 ENC-P4-B6-3 ENC-P4-B6-4 ENC-P5-B8-4 EKC-P6-B9-5 ENC-P6-B10-7 Limits Total Petroleum Moisture Hydrocarbons Content (Method pH (Z)' 418.1) (Units) _ _ _— __ — — — ND — — —__ — ND ND _„ „» —__ __ — 0.05 NA NA NA As ND 0.03 ND 0.05 ND ND ND ND ND ND ND ND 0.02 5.0 Ba 2.3 3.2 1.2 5.0 4.2 1.6 1.0 1.5 ND 0.8 1.0 0.3 0.2 100.0 Cr ND ND ND t).2 ND ND ND ND ND ND ND ND 0.1 5.0 Cu ND ND ND 0.3 ND ND ND ND ND ND ND ND 0.2 25.0 Hs ND ND ND ND ND ND ND ND ND ND ND ND 0. 0. Nl 0.2 5.3 0.3 13.0 ND 0.2 0.3 ND 0.4 0.2 0.3 0.2 005 0.1 20 20.0 Pb 0.06 0.11 ND 0.36 0.07 0.02 ND 0.03 ND ND ND 0.04 0.02 5.0 V 0.3 23.0 0.9 37.2 ND 0.2 0.3 ND ND ND 0.2 0.4 0.1 24.0 Zn 0.6 0.2 ND 0.5 ND NO ND ND ND ND ND 0.2 0.1 250.0 Abbreviations:As • Arsenic, Ba • Barium, Cr - Chromium, Cu - Copper, Hg - Mercury, Ni - Nickel, Pb - Lead, V - Vanadium, Zn - Zinc ND • Not detected above the laboratory detection limit — • Not «• alyzed MA - Not ..pplicable/Not Available LVWl, LVW2 - Low-Volume Waste Impoundments No. 1 & 2 MCW3, MCW4 - Metal-Cleaning Waste Impoundments No. 3 & 4 TW5, TW6 - Treated Waste Impoundments No. 5 & 6 * Depth is calculated from the bottom of the lower liner in impoundment borings and from ground surface in background borings. Symbol is the Unified System Classification of Soils for Engineering Purposes, ASTM Designation D-2487. See Table 5.2-1 for explanation of symbols. Project . 8753249K-ENRP TABLE 5.3 1986 AND 1987 CROUNDWATER MONITORING DATA ENCINA POWER PLANT Paraacter pH Units unit less Sampling Dace 2/86 4/86 9/86 11/86 3/87 5/87 9/87 Detection Field Limit Blank 6.0 6.7 — — — — MU-1 7.3 7.1 7.3 7.3 7.3 7.3 7.4 MW-2 7.8 7.5 7.5 7.3 7.7 7.4 7.37/7.37 LVW/MCW MW-3 8.1 8.0 8.0 8.0 8.0 8.1 7.9 MW-4 7.5 7.4 7.3 7.4 7.6 7.5 7.45 MW-ll(B) 7.8 7.8 7.8 7.9 8.0 7.5 7.94 Conductivity wmhos/ci» 2/86 4/86 9/86 11/86 3/87 5/87 9/87 Coppe mg/L Nickel mg/L 2/86 4/86 9/86 11/86 3/87 5/87 9/87 2/86 4/86 9/86 11/86 3/87 5/87 9/87 0.02 0.02 0.01 0.01 0.01 0.01 0.01 0.05 0.08 0.02 0.01 0.02 0.02 85 110 ND ND ND ND ND ND ND ND ND ND 10000 9400 9200 10400 9850 8950 10900 ND ND ND ND ND ND 0.04 ND ND 0.06 ND 0.02 0.03 0.09 4200 5300 5500 6500 5900 5450 5600/5600 ND ND ND ND ND 0.02 0.04/0.04 ND ND 0.03 ND 0.02 0.05 0.09/0.09 4100 4300 2950 4500 4300 5000 4150 ND ND 0.03 ND ND ND 0.04 ND ND 0.02 ND 0.04 0.04 0.09 8300 7800 2640 3900 6150 5350 10750 ND ND ND ND ND ND 0.08 ND ND 0.02 ND 0.02 ND 0.13 12000 12000 10800 11330 9850 11200 10050 ND ND ND ND ND ND 0.17 ND ND 0.04 ND 0.04 0.04 0.13 TW MW-6 7.3 7.1 7.2 7.2 7.3 7.2/7.2 7.03 8400 9200 8550 8100 7850 6750/6750 7850 0.29 0.12 ND ND 0.02 0.10/0.09 0.13 1.4 1.4 1.25 1.35 1.57 1.04/1.05 1.34 MW-9 7.7 7.4 7.4 7.5 7.3 7.3 7.16 3800 4500 4000 4250 4250 4175 4150 ND NO ND ND ND 0.02 0.04 ND ND 0.05 ND 0.02 0.04 0.13 HU-13 ^M — —7.0 7.1 6.8 7.0 „ — —8200 3550 9950 9650 __ _ —ND ND ND 0.08 „ — —ND 0.05 0.04 0.13 MU-IO(B) 7.6 7.7 7.4 7.4 7.7/7.7* 7.9 7.5 3200 3300 3900 4500 3600/3650 3950 4100 ID ID IDn> ND/ND n> 0.04 m •D 0.03 HD 0.03/0.03 0.02 0.11 Project no. 8753249K-ENRP TABLE 5.3 (Concluded) 1986 AND 1987 GROUNDWATER MONITORING DATA ENCINA POWER PLANT Parameter Vanadium Units mg/L Zinc mg/L Sampling Date 2/86 4/86 9/86 11/86 3/87 5/87 9/87 2/86 4/86 9/86 11/86 3/87 5/87 9/87 Limit 0.03 0.04 0.02 0.02 01 02 0.01 0.03 0.04 0.01 0.01 0.01 0.01 Field Blank ND ND — — ND ND ND 0.083 ND — — ND ND ND MW-1 ND NO 0.04 ND 0.03 0.04 ND ND ND 0.04 ND 0.02 0.02 ND MW-2 ND ND 0.06 ND ND 0.03 ND/ND ND 0.08 0.05 ND 0.05 0.01 ND/ND LVW/MCU MU-3 ND ND ND ND ND 0.02 ND ND ND 0.17 ND 0.41 0.04 ND MW-4 ND ND ND ND ND ND ND 0.075 ND 0.04ND 0.05 0.02 ND MW-1 1(B) ND ND 0.03 ND 0.03 0.03 ND ND ND 0.04 ND 0.01 0.02 ND TW HW-6 ND ND 0.06 ND* 0.02 0.02/0.03 ND 0.23 0.08 0.20 ND 0.10 0.10/0.09 ND MU-9 ND ND 0.03 ND ND 0.03 ND ND ND 0.05 ND 0.05 0.04 ND MW-1 3 w — ND ND 0.02 ND — __ ND 0.03 0.01 ND MW-IO(B) HD SO HO ND ND/ND ND HD ND HD 0.08 ND 0.02/0.22 0.01 ND Abbreviations: — - Not Analyzed NS - Not Sampled: Dry Wells 7.7/7.7* • Duplicate samples analyzed ND • Not detected above laboratory detection limit LVW/MCW - Low-Volume and Metal-Cleaning Waste Impoundments TV - Treated Waste Impoundments (L. - Background well 8 - Concentration revised by SDG&E Laboratory Note: Detection limits are shown only for parameters that were not detected. Project No. 8753249K-ENRP TABLE 6.1 STATISTICAL SIGNIFICANCE TEST RESULTS SUMMARY 1986 AND 1987 SOIL DATA ENCINA POWER PLANT Impoundment Boring TPH pH As Ba Cr Cu Hg Ni Pb V Zn LVW1 LVW2 MCW3 MCW4 B-l B-2 B-3 B-4 B-5 B-6 LVW/MCW*MW-1 through MW-5 NA NA TW5 TW6 B-7 B-8 B-9 B-10 TW*MW-6 through MW-9 NA NA Abbreviations:TPH - Total Petroleum Hydrocarbons, As = Arsenic, Ba = Barium, Cr • Chromium, Cu » Copper, Hg = Mercury, Ni = Nickel, Pb = Lead, V - Vanadium, Zn = Zinc LVW = Low-Volume Waste Impoundment MCW = Metal-Cleaning Waste Impoundment TW - Treated Waste Impoundment + = Statistically significant difference = No statistically significant difference (+) = Indicates statistical significance for an extreme value in the boring > = Indicates pH value was significantly elevated NA = Not analyzed * = 1986 Monitoring Well Boring Data Project No. 8753249K-ENRP TABLE 6.2 Parameter MW-1 STATISTICAL SIGNIFICANCE TEST RESULTS SUMMARY 1987 GROUNDWATER MONITORING DATA ENCINA POWER PLANT LVW/MCW MW-2 MW-3 MW-4 MW-6 TW MW-9 MW-13 Cu Ni V Zn Abbreviations: Cu Ni V Zn Copper Nickel Vanadium Zinc + - statistically significant difference - « no statistically significant difference LVW/MCW » Low-Volume Waste and Metal-Cleaning Waste Impoundments TW • Treated Waste Impoundments a - Indicates parameter was statistically significant in 1986 and 1987. Project No. 8753249K-ENRP TABLE 7.2-1 SOIL CHEMISTRY COMPARED TO NORMAL RANGES IN WESTERN U.S. SOILS (mg/kg) Parameter Arsenic Barium Chromium Copper Mercury Nickel Lead Vanadium Zinc Maximum Concentration At Encina Site Adjacent or Beneath Impoundments 7.7 128 27 98 ND 214 8.3 530 320 U.S. Soils Mean (Range) 6(0.1-40) 500(100-3000) 100(5-3000) 20(2-100) 0.03(0.01-0.3) 40(10-1000) 10(2-100) 100(20-500) 50(10-300) Data from: Bowen, H.G.M.; 1986: Trace Elements in Biochemistry. New York: Academic Press, Inc. Concentrations are for oven dried soils, excluding soils near mineral deposits. Project No. 8753249K-ENRP TABLE 7.2-2 GROUNDWATER QUALITY DATA AND DRINKING WATER STANDARDS (mg/1) Maximum Concentration Drinking Water Parameter Arsenic Barium Chromium Copper Mercury Nickel Lead Vanadium Zinc in Downgradient Wells 0.008 0.21 0.06b 0.29 0.0029 1.57 0.12 0.06 0.41 Standards 0.05 1.0 0.05b 1.0 0.002 None 0.05 None 5.0 Excludes monitoring wells MW-5 and MW-12. Groundwater samples were analyzed for total chromium; drinking water standard is for hexavalent chromium. CMarshack, "Update of Water Quality Goals," California Regional Water Quality Control Board, Central Valley Region, September 18, 1987. Includes primary and secondary maximum contaminant limits. Project No. 8753249K-ENRP TABLE A-2 1986 SOIL CHEMICAL ANALYSES - ME1ALS* MONITORING WELL BORINGS ENCINA POWER PLAN! LVW/MCU Parameter HW-1 (»g/kg) El-2 Metals Aluminum 4,500 Arsenic 0.82 Barium 72 Beryllium 0.22 Cadmium Total Chromium 14 Copper 98 Lead Mercury Nickel 5.0 Vanadium 19 Zinc 150 Geologic Fill Formation Sample 2.8 Elevation (ft, MSL) Sample Type V MW-2 MW-3 MW-4 E2-2 E2-5 E2-11U E3-2 4,900 5,800 8,100 5,300 0.81 0.56 -- 0.76 43 76 77 48 0.17 0.28 0.52 0.15 -. 7.4 10 9.0 10 17 20 27 8.8 -- .- 3.4 3.9 5.7 3.9 17 9.9 22 20 47 86 41 42 Fill Fill Fill Fill 20.0 8.1 -3.0 12.8 V F S V (above perched) E3-3" E4-2 3,800 5,900 - 36 63 0.006 0.31 .- 7.4 7.2 SO 14 -- - 5.7 3.4 30 15 31 320 Fill Fill 8.8 9.8 V V/S (below perched) MW-5 MW-1KB) MW-12(B) E5-3 £5-6 Ell-2 E12-2 4,300 1,200 6,900 4,500 0.96 58 8.7 19 24 0.29 " 27 5.2 9.2 5.8 5.3 1.8 13 5.2 — .- 6.5 -- 2.4* 1.3 13 8.3 37 20 15 6.3 16 11 Fill Ql Fill Fill 0.8 -10.7 9.6 9.8 V S V V TV MW-6 E6-3 28 4.6 2.2 14 9.8 Qby 26.1 E6-5 MW-7 E7-3 MW-8 MW-9 E8-4 E8-8 E9-3 E9-7 mi-lO(g) EU>-3 E10-7 3,600 2,900 3,300 2,300 24 3.8 1.8 1.3 9.6 15 I*b 15.1 14 3.4 31 21 5.0 1.7 8.2 17 65 4.8 Qby Qby 4,500 1.9 15 0.26 6.7 14 2,000 5,100 1,400 3,200 25 18 0.28 3.4 4.9 1.5 1.6 8.4 J7 18 Tab 1.2 9.5 7.6 28.4 27.0 20.5 25.0 15 40 — 0.20 4.S 3.8 1.1 2.0 2.1 5.8 9.8 Tab 5.0 1.2 1.2 22 7.6 6.1 9.4 Q*r Tab 44.6 2S.6 Sanplei collected January 15 through 29, 1986, and analyzed In March 1986, except where noted. Samples collected In January, 1986, and analyzed In February, 1986. Ql • Quaternary lagoonal depoalta; Qby - Quaternary Bay Folnt Formation (terrace deposits); Tab - Tertiary Santiago Fonatlon. V • Vadoie Zone, F • Perched Water Zone, S - Saturated Zone. Concentration reported Incorrectly aa "not detected" In HAR. •- • Not detected. LVW/HCW - Lov-Voluae Watte and Metal-Cleaning Waate Impoundment*. TH - Treated Waste lapoundnents. (B) • Background well borings. /VIITTELH>1USERcorpora Non SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN ATTACHMENT 4-2 ESTABLISHMENT OF BACKGROUND LEVELS /MITTELH/1USERcorpora Non SDG&E 4-2-1 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN ESTABLISHMENT OF BACKGROUND LEVELS INTRODUCTION To determine whether soils surrounding the hazardous waste surface impoundments have been contaminated by the impoundments, the concentrations of selected parameters in the suspect soils will be compared to concentrations of the same parameters in uncontaminated background soils. Thus, for each parameter, it is necessary to establish a background level. The methodology that will be followed to establish these background levels is described in this attachment. Statistics are used throughout both State and Federal hazardous waste regulations to set standards, determine whether wastes are hazardous and evaluate groundwater monitoring data to determine whether contamination has occurred. However, there is no regulatory method for evaluating whether a site has been contaminated above background levels but below hazardous levels. There is not even a method for exactly determining background levels. This attachment will evaluate a statistical approach to set background levels or standards for site remediation or closure efforts. This attachment has two major parts. The first is an evaluation of statistical approaches currently employed by regulators to determine whether a waste is hazardous or groundwater is contaminated. The second part is a description of a new statistical approach for establishing background levels. The attachment also includes information on selecting the number of background samples, dealing with analytical limitations and using data transformations for statistically non-normal data. Examples using this new method will also be presented. EXISTING STATISTICAL METHODS Two existing statistical methods used in applying hazardous waste regulations have been suggested by some regulators as possible methods for establishing background levels for site decontamination strategies. The first method is from "Test Methods for Evaluating Solid Waste," SW-846, and is often used to determine whether a waste is hazardous. The second method is the Cochran's Approximation to the Behrens-Fisher Student's t-test which is used to determine whether groundwater contamination has occurred from a hazardous waste unit. The two methods are described below, and reasons are presented to explain why they are not appropriate for determining if contaminant concentrations are statistically greater than background levels. /HITTELH/3USERcorpora Non SDG&E 4-2-2 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080KN Hazardous Waste Approach Section One of SW-846 describes a statistical method for determining whether a waste is hazardous. An example is presented of a pond that is filled with sludge containing barium. The sludge is sampled and analyzed to determine whether the EP toxicity level of 100 mg/1 for barium is exceeded. From the analytical data the mean and the standard deviation of the sample population are calculated. The Student's t-test is then used to calculate the confidence interval of the true population mean. The sludge is considered hazardous if the upper bound of the confidence interval for the population mean exceeds the EP toxicity level (100 mg/1 for barium). It is important to understand what the Student's t-test is and how it is being applied. The Student's t-test determines the upper and lower bounds of the true population mean, based on the sample mean and sample standard deviation, at a given level of confidence. It assumes that both the entire population and samples are normally distributed. The larger the certainty required, the farther the upper and lower bounds of the confidence interval are from the sample mean. As more samples are taken from a normally distributed population, the smaller the confidence interval becomes. As the number of samples approaches infinity, the upper and lower bounds of the confidence interval converge at the point where the population mean and sample mean become equal. In applying this method to a waste, the regulatory threshold for a waste is compared to the upper bound of the confidence interval of the population mean at a given level of confidence. In effect, it is an attempt to compare the average concentration of a contaminant to the regulatory level without taking an infinite number of samples. This is done by relying on statistics to establish the highest average concentration which could actually exist, with an acceptable level of confidence, based on the limited sampling. As the sample size increases, the maximum probable concentration would decrease as the confidence interval narrowed. This was demonstrated quite well in the example in SW-846. More samples were taken until the regulatory level was found to be greater than the upper bound of the confidence interval, thus indicating that the sludge was not hazardous at the 90% level of confidence. In site remediation or closure projects we are comparing one sample per segment of soil to the background concentrations to see if the whole segment is contaminated. If a large number of background samples was taken from a normally distributed population, the confidence interval for the true mean would be quite small. With larger and larger sample sizes, the upper bound of the confidence interval would decrease, approaching the population mean, until finally they were equal. At this point, if /HITTELH>1U$ERcorpora Non SDG&E 4-2-3 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN a sample concentration was compared to the upper bound, it would have a fifty percent chance of exceeding it, even if contamination had not occurred. Consequently, this approach might lead to erroneously excavating uncontaminated background soils up to fifty percent of the time. In summary, the Student's t-test is not appropriate for determining whether contaminant concentrations in soils exceed background concentrations. Its best use is to compare a set value, such as a regulatory level, to the probable average concentration of a waste. Groundwater Contamination Approach California (23CCR2556(h)) and Federal (40CFR264.97(h)) regulations require use of Cochran's Approximation to the Behrens-Fisher (CABF) Student's t-test to evaluate whether groundwater contamination from a hazardous waste management unit has occurred. It is evaluated below as a decision-making tool to determine, with statistical validity, if concentrations in potentially contaminated soils exceed the concentrations in background soils. The CABF Student's t-test statistically compares two sets of samples to determine whether they are from the same population or from two different populations. The t-test determines whether there is an overlap in the confidence intervals of the true population means of the two data sets at a given level of confidence. In a groundwater detection monitoring program, upgradient groundwater is sampled a sufficient number of times (a minimum of sixteen samples) to establish background statistics for each monitoring parameter. Once monitoring begins, four samples are taken quarterly from each upgradient and downgradient well. The mean and standard deviation of each parameter are computed for each well. This data is then compared to the original background values using the CABF Student's t-test to see whether the new samples are from the same population as the old. If they are not, groundwater contamination is assumed to have occurred, and the wells are resampled for confirmation of the contamination. Application of the CABF Student's t-test to site remediation or closure projects would usually be very costly and time consuming because a large number of samples are required. If analytical costs for a soil segment exceed the costs to excavate that segment and dispose of it as a hazardous waste, it is economically advantageous to excavate rather than test. The CABF requires a minimum of four samples from each soil segment for comparison to background. To make this approach economically feasible, the soil segments should be large enough so that testing a segment is cheaper than removing and disposing of it. /VIITTELhMUSER corpora Non SDG&E 4-2-4 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN However, migrating contaminants are usually spatially concentrated rather than dispersed. With the large number of samples that are required per segment, only a relatively small number of soil segments are necessary before exceeding the total number of samples that are economically feasible. This would increase the size of each segment, which would decrease the chance of detecting contamination. The CABF Student's t-test would be a cumbersome decision tool. In the end, each concentration value would be separately evaluated to see whether it exceeds background. Rather than this approach, the statistical approach described in the next section is proposed for determination of the extent of contamination. PROPOSED STATISTICAL APPROACH This part of the attachment presents an alternative statistical approach for establishing background levels that will be used to determine if soil is contaminated. The first section describes a statistical basis for establishing background levels. The remaining sections describe how to implement it. They describe how to select the number of background samples, deal with analytical limitations and transform statistically non-normal data. Some examples of this method are also presented. Background Levels The goal of this statistical approach is the same as the regulatory goal for evaluating groundwater monitoring data: the method provides "a reasonable balance between the probability of falsely identifying a significant difference and the probability of failing to identify a significant difference..." (23CCR2555). It is assumed that the population of true background concentrations has a normal distribution with a mean, M, and standard deviation, S. For a normally distributed population, the probability that a random sample will have an actual value less than or equal to a given value can be found using the distribution function F(x). From a table for the normal distribution function, it can be seen that there is a 50% chance that a random sample will be less than M, a 84.13% chance that a sample will be less than M + S, a 97.73% chance of it being less than M + 2S and a 99.87% chance of it being less than M + 3S. For this closure, it is proposed that each background standard, BL, be established at three standard deviations above the mean; that is, BL = M + 3S. (1) /HITTELH/IUSERcorporaNon SDG&E 4-2-5 December 1988 Encina Power Plant Rev: .Q Closure Plan . 1080RN To evaluate the reasonableness of this value for background, assume that sixteen samples will be taken of the soils underlying one pond and twenty-five analyses will be run on each sample. This means that four hundred values will be compared to background. If no contamination has occurred, the probability, P, of an individual parameter exceeding its background standard would be about 0.13 percent (P=l.0-F(x=BL)). However, for 400 parameters, the cumulative probability, C, of one or more uncontaminated samples exceeding its background standard would be about 41 percent (C=l.0-(F(x=BL))3, where q=400). Therefore, even if no contamination has occurred at the site, there is almost an even chance that contamination would be falsely indicated. Another way of looking at the reasonableness of this approach is to compare the maximum possible value of the background level to hazardous levels. For normally distributed data, the coefficient of variation, CV, must be less than or equal to 1.0. Since CV is equal to S/M, the largest permissible value of S is M. Substituting M for S into equation (1) , the maximum value for background, BL, is four times the mean concentration. Background soil concentrations are usually orders of magnitude below hazardous concentration levels; thus, the maximum background levels would be well below any environmental or health threat level. The above formula for background standards uses the the statistics of the population and must be converted to those of the sample. For the population standard deviation, S, the sample standard deviation, s, is recommended. For the population mean, M, it is proposed that the sample mean, m, be used. Substituting these values for M and S, the background level, BL, is equal to three sample standard deviations above the sample mean: BL = m + 3s. (2) A sample calculation for determining the background standards is given in Example 1. Minimum Sample Size To calculate the number of samples required to establish background, a rather involved statistical approach has been used. For a given number of background samples, n, taken from an infinite population, each with concentration, x(i), where i=l to n. The sample mean concentration, m, is defined as: 1 n m = 3C x (i) . (3) n i = l /VHTTELI-MUSERcorpora Non SDG&E 4-2-6 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN The square of the approximate standard deviation, s, used for small sample size is: 1 n s2 = — £ (x(i) - m)2 (4) n-1 i=l If the data is assumed to be normally distributed, statistical analysis applicable to a normal population can be utilized. For a 100 (1-a) percent confidence interval for the population mean, M, given the sample mean, m, and the sample standard deviation, s, the Student's t-distribution yields: Pr {-t < (M-m) yTn < t} = 1-a (5) s Since the value of t is fixed by "a" and "n", the difference between the sample mean and the true population mean lies within a given range for a given degree of probability. Rearranging the inside yields: ts ts (6) This means that there is a (1-a) 100% confidence that the population mean, m, is between the two extremes. Letting CI equal the confidence interval of the population mean at 1-a probability yields: ts CI = m +_ JTT (7) While the above equation is generally used to calculate the confidence interval of the population mean after sampling has occurred, it can also be used to calculate the number of samples required to obtain a given confidence interval for an assumed set of data. The first step is to select a confidence interval for the population mean. The sample mean plus and minus one standard deviation was chosen as a reasonable interval. Thus, the lower bound is equal to m - s, and the. upper bound is equal to m + s. Substituting the value for the upper bound into Equation (7) yields the equation: m + s = m + st (8) For Equation (8) to be valid, t /V"n must be equal to 1.0. For a given 1-a probability of the population mean which is /HITTELH/1USERcorpora Non SDG&E 4-2-7 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN within the given confidence interval, there is only one combination of n and t (from a Student's t-distribution table) which will solve equation (8) . Thus/ a confidence interval must be selected. In keeping with current regulatory practice for the t-test, the 95th percentile for the upper bound was selected. (This is equivalent to 90% confidence level for a two-sided test.) For n samples, the degree of freedom, df, is equal to n-1. From a Student's t-distribution table, it was found that six samples would be required. In summary, for a 95% probability of having the true population mean not exceed twice the sample mean for a normally distributed data set, a minimum of six samples would be required. If the standard deviation is actually less than the sample mean, then the confidence interval for the population mean would be even smaller. Analytical Limitations This method to determine the background level, BL, assumes that all of the data for a given parameter are measurable and quantifiable; that is, they are above the method detection limit, MDL, for that parameter. This section addresses how the background level for a parameter should be calculated when some or all of the background concentrations are below its MDL. The simplest case is when all of the background samples are below the parameter's MDL. If this happens, the background level will be assumed to be equal to twice the MDL for that parameter. This value was chosen by assuming that both the mean and standard deviation are equal to one-half the MDL. The more difficult situation arises when some of the data are below the MDL and some are above it. The problem is how to best handle the data to statistically describe its distribution in terms of the sample mean and standard deviation. The graphic approach used by McCarty et al. (2,3) will be used as follows: 1. Arrange the data in descending rank order and calculate the probability distribution function, F, for each concentration which is above the MDL: F[x(i)] = (i - 0.375)/(n + 0.25), where x(i) is the i-th largest observed value from sample size n. /MITTELH/IUSERcorporation SDG&E 4-2-8 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN 2. Linearize the probability function by using the formula which approximates a normal distribution: P(i) = 4.91 * {{F[x(i) ] }0.14 - [I - F[x(i) ] }°-14} 3. Plot the concentrations versus P(i) for the values above the MDL. 4. Perform a least squares fit on the data above the MDL. The zero intercept will be the mean, m, and the slope will be the standard deviation/ s. Example 2 shows how this method would be used when some of the data is below the MDL. Data Transformations In the above discussion, it was assumed that the data would be normally distributed. Current regulatory practices assume the data is from a normal population if the coefficient of variation, CV(=s/m) is less than or equal to one. Each data set will be checked to see if it meets this requirement. If it does not, various transformations will be tried to normalize the data. Transformations which will be tried include log, square root and arcsin. The normalized mean and standard deviation will be determined for the transformed data and the coefficients of variation checked to see if the transformed data is now normal. If the transformed data is normal, the background level will be determined for the transformed data. By taking the anti-transform, the true background level, BL, can be found. Example 3 demonstrates how the transform process would work using the log-transformation. /VIITTELhMUSERcorpora hon SDG&E Encina Power Plant Closure Plan 4-2-9 December 1988 Rev: 0 1080RN 1. 2. 3. REFERENCES Benjamin, J.R. and C.A. Cornell, Probability, Statistics, and Decision for Civil Engineers, McGraw-Hill, NY, 1970. McCarty, P.L., M. Reinhard, C. Dolce, H. Nguyen, and D.G. Ar go, Water Factory 21; Reclaimed Water, Volatile Organics, Virus, and Treatment Performance, EPA-600/2-78-076, 1978. McCarty, P.L., M. Sutherland, T. Reinhard, Everhart, J. Graydon, J. and D.G. Argo, Schreiner, K. Wastewater Contaminant Removal for Groundwater Recharge at Water Factory 21, EPA-600/2-80-114, 1980. /VllTTELhMUSERcorporation SDG&E 4-2-10 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN EXAMPLE 1: BACKGROUND LEVEL DETERMINATION 1. Assume the following background values. a. X-values: 89, 90, 87, 96, 93, 113. n=6 2. Determine the sample mean, m: 1 n 89+90+87+96+93+113 m = — £ x(i) =n 1=1 6 m = 94.7 3. Determine the sample standard deviation, s: 1 n s2 = £T (x(i)-m)2 n-1 1=1 s2 = 96.7 s = 9.5 4. Check the coefficient of variation, CV, to see if the data are normal. CV = s/m = 9.5/94.7 = 0.10 CV <_ 1.0; therefore, the data are normal. 5. Calculate the background level, BL: BL = m + 3s BL = 94.7 + 3(9.5) BL = 123.2 /MITTELH>1USER vcorpora hon SDG&E 4-2-11 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RN EXAMPLE 2: SOME DATA LESS THAN THE MDL 1. Use the data from Example 1, but assume the MDL = 90. X-values: <90, 90, <90, 96, 93, 113. n=6. 2. Rearrange the data in descending rank order. Determine F(x(i)) and P(x(i)) for values above the MDL. 6 5 4 3 2 1 113 96 93 90 <90 <90 0.90 0.74 0.58 0.42. 1.28 0.64 0.20 -0.20 Plot x(i) vs. P(x(i)) and do a least squares fit of the data. Determine the 0-intercept, which equals m, and the slope, which equals s. (See Figure 1 for graphical representation.) m = 0-intercept =90.6 s = slope = 15.4 Check the coefficient of variation, CV. CV = s/m = 15.4/90.6 = 0.17 CV £ 1.0; therefore, assume normal distribution. Calculate the background level, BL. BL = m + 3s = 90.6 + 3M15.4) BL = 136.8 /VHTTELH/1USER tcorporation SDG&E 4-2-12 December 1988 Encina Power Plant Rev: 0 Closure Plan 1080RNRGURE1 BACKGROUND LEVEL DETERMINATION WHEN SOME DATA ARE BELOW MDL 140 130 — 120 — 110 — 100 — 90 — BL-136.8 MOL-90.0 Least Squares FK m - Onntercept - 90.6 • - slop* . 15.4 -3.0 -2.0 -1.0 0.0 +1.0 +2.0 +3.0 xfiVm s /HITTELhMUSER vcorpora hon SDG&E 4-2-13 December 1988 Encina Power Plant Rev: o Closure Plan 1080RN EXAMPLE 3: LOG TRANSFORMATION OF DATA 1. Use the data from Example 1. X-values: 89, 90, 87, 96, 93, 113. n=6. 2. Transform the data by taking the log of each data point, a. Log X-values: 1.95, 1.95, 1.94, 1.98, 1.97, 2.05 3. Calculate the mean of the transformed x-values. 1 n mT = £ log(x(i)) n i=l mT= 1.97 4. Calculate the standard deviation of the transformed x-values. ST = 0.04 5. Check the efficiency of variation, CV^, of the transformed data. CVT = sT/mT = 0.04/1.97 =0.02 CVT £ 1.0; therefore, assumed normal. 6. Calculate the transformed background level, BLip BLT = mT + 3sT = 1.97 + 3(0.04) = 2.09 7. Determine the actual BL by taking the anti-transform, which is the anti-log. BL = 1QBLT = 1Q2.09 BL = 124. /MITTELhMUSER L.' corpora hon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RO ATTACHMENT 4-3 DEIONIZED WATER WASTE EXTRACTION TEST RATIONALE /MITTELH>IUSERcorporation SDG&E 4-3-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RO DEIQNIZED WATER WASTE EXTRACTION TEST RATIONALE Soluble metal ion concentrations may be measured during closure to predict if contaminated soils will adversely impact surface or groundwaters. The soluble concentrations will be measured in deionized water extracts of background soil samples and of soil samples collected beneath the impoundments. To prepare the extracts, the California Waste Extraction Test procedures (22 Cal. Code of Regulations, Section 66700) will be followed except that deionized water will be substituted for the standard citric acid buffer solution. The impact of metals contamination on ground or surface water depends on the concentrations that migrate under actual site conditions. On-site soil pH values are expected to be slightly alkaline, in the range of 7 to 10. In this range of pH values the metals will generally be relatively insoluble hydroxides, carbonates or other salts and will, in effect, be fixed in the soil. Consequently, even if total concentrations exceed the background standards, the metals may not be soluble under the pH conditions at the site. As mentioned above, deionized water will be substituted for citric acid in the Waste Extraction Test (WET) to extract soluble metal ions. Use of deionized water simulates on-site conditions in the saturated and unsaturated zones more closely than citric acid. In the standard WET, the low pH and moderate ability of citric acid to complex metal ions both contribute to solubilizing metal ions. In the future, the on-site soil pH is expected to be greater than the value of 5 used in the standard WET procedure. Moreover, there should be no appreciable concentrations of complex-forming organics in the soil, from, for example, decomposition of organic wastes. Even if metal ions leak out of the impoundments, they are likely to be fixed in the soil. Use of deionized water as the extraction solution in the WET procedure will most closely simulate site conditions with regard to metal ion mobility. A further, practical advantage of the deionized water waste extraction test procedure (DW-WET) is the familiarity of the procedure among California hazardous waste laboratories and the ready availability of the extraction solution in those laboratories. Following the methodology presented in the draft guidance document, "Waste Classification and Cleanup Level Determination," by Jon Marshack of the Central Valley Regional Water Quality Control Board, soluble concentrations of contaminated soils can be used to predict the impacts of migrating contaminants on surface and groundwater quality. Mittelhauser Corporation has successfully used this methodology in a surface impoundment closure. In that project, it was shown that although /VHTTELH4USERcorporahon SDG&E 4-3-2 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RO contaminated soils had total metal concentrations greater than site-specific cleanup levels, soluble metals were sufficiently low to not adversely impact water quality. In the Encina closure, if total metal concentrations exceed the background standards established for total metals, soluble concentrations may be measured. The soluble concentrations will be compared to applicable water quality standards multiplied by an environmental attenuation factor. Using criteria explained in the Marshack document, an attenuation factor of 10 to 100 would be appropriate for the Encina site due to the depth to groundwater and annual rainfall. Appropriate water quality standards might be health based standards, such as drinking water standards or maximum contaminant levels (MCLs), the soluble concentrations in background soil, groundwater concentrations or perhaps other applicable standards. vcorporation SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RO ATTACHMENT 4-4 CLOSURE STEP DECISION DIAGRAM STEP 1 IMPLEMENT CLOSURE PLAN AND NOTIFY AGENCIES. PREPARE SITE SPECIFIC HEALTH AND SAFETY PLAN STEP 2 TREAT AND REMOVE ALL WASTE FROM UNITS STEP 3 DOCUMENT ALL ASSOCIATED PIPING STEP 4 WASH THE UNER BY HYDROBLAST1NG OR STEAM CLEANING SAMPLE WASHING RESIDUALS AND ANALYZE FOR pH AND TTLC ARE RESIDUALS HAZARDOUS WASTE ? CAN THE RESIDUALS BE TREATED IN THE WASTEWATER TREATMENT SYSTEM TRANSFER TO WWT SYSTEM (CONT. WITH STEP 5) DISPOSE Of RESIDUALS OFF-SITE STEP 5 FLUSH ALL ASSOCIATED PIPING TEST FLUSH WATER FOR pH AND TTLC METALS IS THE FLUSH WATER HAZARDOUS ? STEP 6 INSPECT LINER AND DOCUMENT AREAS OF CONCERN. IDENTIFY UNER SAMPLING LOCATIONS AS OUTLINED IN ATTACHMENT 4-5 IDENTIFY AND COLLECT A MINIMUM OF- 2 ADDITIONAL BACKGROUND SOIL SAMPLES AND ANALYZE FOR pH. TPH AND TTLC STEP 7*8 SAMPLE THE LINER. GRAVEL. AND UNDERLYING SOIL AS OUTLINED IN ATTACHMENT 4-5 ANALYZE THE SAMPLES FOR pH. TPH, AND TTLC PER ATTACHMENT 4-5 CONTINUED ON PAGE 2 PAA KYM °*1t 12/05/8E »** NONE ATTACHMENT 4-4 CLOSURE STEP DECISION DIAGRAM PAGE 1 OF 2 SDG4E ENC1NA POWER PUNT 0 ""1 0800702 "• "°P1080 1080-00-004 CONTINUED FROM PACE 1 YESARE LINER RESULTS GREATER THAN THE TTLC OR STLC LIMITS 7 DOES ON-SITE DISPOSAL OF LINER CONSTITUTE A REGULATED LANDFILL 7 LINER REMAINS ON-SITE REMOVE AND DISPOSE OF LINER AS AN INERT WASTE REMOVE AND DISPOSE OF LINER AS A HAZARDOUS WASTE ARE SOIL RESULTS GREATER THAN TTLC LIMITS 7 ARE TTLC RESULTS GREATER THAN 10 TIMES STLC LIMITS 7 ARE SOIL RESULTS GREATER THAN CALCULATED BACKGROUND 7 YES YES ARE STLC RESULTS GREATER THAN LIMITS 7 YES SOILS ARE HAZARDOUS OR CONTAMINATED WASTE. COMPLETE ADDITIONAL SAMPLING TO DEFINE VERTICAL AND HORIZONTAL EXTENT. IF NECESSARY. SITE DECONTAMINATED ASSESS POTENTIAL ENVIRONMENTAL IMPACT STEP 11 BACKFILL STEP 9 REMOVE HAZARDOUS OR CONTAMINATED SOIL STEP 12 PREPARE CLOSURE CERTIFICATION REPORT STEP 10 COLLECT AND ANALYZE CONFIRMATION SOIL SAMPLES PAA KYU JLZ/06/Bi ATTACHMENT 4-4 CLOSURE STEP DECISION DIAGRAM PAGE 2 OF 2 SDG&E ENCINA POWER PLANT 1080-00-004 /VIITTELH/1USER tcorporahon SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM ATTACHMENT 4-5 SAMPLING AND ANALYSIS PLAN /MITTELH>4USERcorpora hon SDG&E 4-5-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM ATTACHMENT 4-5 SAMPLING AND ANALYSIS PLAN A. INTRODUCTION San Diego Gas and Electric Company (SDG&E) is closing six surface impoundments at the Encina Power Plant. The surface impoundments were used to collect wastewaters prior to treatment and/or discharge. This sampling and analysis program will be performed to determine proper handling or disposal methods for flush water, surface impoundment washing residues, liners (asphalt and gravel) and soil. The analytical results will be used in conjunction with the Site Cleanup Strategy presented in Section 4.2 to determine the waste categories for the asphalt concrete and soils. Based on the analytical results, the materials will be classified as hazardous, designated or inert. Hazardous and designated wastes will be transported off-site for appropriate disposal. Materials classified as inert, concentrations meeting background criteria, may be left in place at the site or disposed of at a Class III facility. B. ANALYTICAL PARAMETERS Samples collected during the implementation of this sampling and analysis plan will be analyzed for the following eleven parameters: Total Petroleum Hydrocarbons (TPH) pH Mercury Arsenic Nickel Barium Lead Chromium Vanadium Copper Zinc The analytical procedures for these parameters are identified in Section H of this attachment. The rationale for the selection of these parameters is presented in Section 4.2.2. C. VISUAL OBSERVATION The surface impoundments will be inspected for any visible cracks, discoloration, or other signs of leakage or deterioration. Before the inspection, all wastes will be removed from the impoundments. The asphalt concrete liner will be washed using a hydroblaster or steam cleaned. The cleaning residuals will be transferred to either a portable tank or to the new wastewater treatment system. /MITTELH4USERcorporation SDG&E 4-5-2 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM After removing all of the wastes and cleaning the asphalt concrete, the surface will be visually inspected by two people such as the plant engineer or inspector, environmental coordinator, registered geologist, engineering geologist or a qualified contractor. The inspectors will look for visible cracks in the asphalt concrete or areas of erosion, pitting, or spalling. The approximate length, width, and depth of any significant cracks will be recorded by the inspectors. On a plot plan of the impoundments, the size and location of any significant areas of erosion, pitting, or spalling found during the inspection will be recorded. A photographic record of the inspection will be kept which pictures problem areas encountered. D. ASPHALT CONCRETE LINERS AND GRAVEL SAMPLING AND ANALYSIS After the impoundment has been cleaned and visually inspected, samples of the asphalt concrete liners (upper and lower) and gravel between the liners will be taken to classify the materials for disposal methods. Each impoundment will be divided into quadrants and one core sample will be taken within each quadrant, four sample locations per impoundment. The sample will be taken at areas of concern identified by the inspection or at a randomly selected point within a quadrant. If no areas of concern were identified, the quadrant will be divided into approximately 20 numbered squares, and a random number will be selected using a random number generator such as those built into hand-held calculators. Asphalt samples will be obtained using a coring machine or saw while gravel samples will be obtained using a trowel or shovel. A total of twelve samples, four upper liner, four gravel and four lower liner, will be taken for each impoundments. The samples will be analyzed for total and soluble concentration of metals to determine whether the liner materials are a hazardous waste. If any TTLC or STLC values are exceeded, the corresponding material will be deemed hazardous and disposed as such; if not, the materials will be left on-site or disposed of as a non-hazardous, solid waste. E. LIQUID SAMPLING AND ANALYSIS The flush water and the residual from washing the surface impoundments will be sampled to determine the appropriate disposal method. Samples will be collected using a plastic or glass container from the surface impoundments. The samples will be analyzed for pH, oil and grease, and metals. The flush water and washing residuals will be processed through the plant's on-site wastewater treatment systems or will be disposed of off-site. /V1ITTELH>1USER ucorporation SDG&E 4-5-3 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM F. SOIL SAMPLING AND ANALYSIS Soil samples will be collected and analyzed to determine if contamination exists underlying the surface impoundments by comparing the results to background levels. The analyses will also be used to categorize any soil which is contaminated so that it may be properly disposed. The results of the RI indicated that there is contamination underlying LVW 1 and 2 while there is no contamination underlying MCW 3 and 4 and TW 5 and 6. Based on these results, different soil sampling and analysis strategies have been developed for the different surface impoundments. Background Samples Four soil borings will be completed for background soil sampling; two borings in the area of the LVW and MCW impoundments and two in the area of the TW impoundments. These borings will be located near the impoundments/ close enough to have the same soil characteristics, yet far enough away to be unaffected by any possible leaks from the ponds. The exact locations will be selected in the field during the implementation of the closure plan. Consideration will be given to accessibility, utilities, and likelihood of not being contaminated. Samples will be obtained at 2 foot intervals starting at the surface and extending to groundwater. A minimum of four samples from each boring representing each soil type will be selected. They will be randomly selected from boring samples of similar soil classification, more than four exists. MCW-3 and -4 and TW- 5 and -6 Since the results of the RI indicated no significant soil contamination underlying these surface impoundments, limited soil sampling will be completed for these impoundments. Each surface impoundment will be divided into quadrants and one soil boring will be completed within each quadrant. The exact location of the boring will be based on the inspection of the asphalt liner. If the inspection identified a location of concern within the quadrant, the sampling will be completed in that location. When several areas of concerns were identified, the area which seemed to have the largest impact on the integrity of the impoundment will be chosen. If the inspection did not identify any areas of concern, then the sample location will be randomly selected. The area will be divided into approximately 20 numbered squares and then a random number will be selected using a hand held calculator or equivalent method to select a random number between 1 and 20. /MITTELH/IUSER vcorporation SDG&E 4-5-4 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM Samples will be obtained at 2 foot intervals starting at the surface and extending to groundwater for locations where a drill rig can be used. If the sample location is located on a side wall of the impoundment, a hand or power auger will be used and samples will be obtained at 2 foot intervals starting at the surface and extending to 6 to 10 feet. LVW- 1 and -2 The results of the RI indicated that there is soil contamination underlying LVW 1 and 2. This contamination may be from the operations of an abandoned pond that underlies these two surface impoundments and not from the operations of the existing surface impoundments, Figure 4-5-1. Tables of the results for soil samples completed for the RI are presented in Tables 5.2-1, 5.2-2 and A-2 found in Attachment 4-1. Soil analytical results for B-l in LVW-1 showed high concentrations of metals approximately 5.5 feet below the surface of the impoundment. B-2 in LVW-2 showed the same high levels of metals that B-l showed at approximately 2.5 feet below the surface of the impoundment. However, the results for B-3 in LVW-2 showed no contamination above background. B-3 is approximately 60 feet from B-2. During the installation of monitoring wells MW-1, 2, 4 and 5 which are on the perimeter of LVW-1 and 2, soil samples were analyzed. The results of the samples from MW-1 indicated slight higher concentrations of copper than background. The remaining samples did not indicate any significant concentrations for metals in the soils. Using the approximate location of the abandoned pond and the soil results from the RI, additional soil sampling will be completed to define the vertical and horizontal extent of contamination underlying these two impoundments. SDG&E will complete a minimum of eight additional soil borings in an attempt to determine the extent of contamination. The approximate locations of these borings are shown in Figure 4-5-1 while final locations will be determined at the time of implementation of the closure plan. Samples will be obtained at 2 foot intervals starting at the surface and extending to groundwater for locations where a drill rig can be used. If the sample location is located on a side wall of the impoundment, a hand or power auger will be used and samples will be obtained at 2 foot intervals starting at the surface and extending to 6 to 10 feet. METAL-CLEANING WASTEWATER IMPOUNDMENTS 3 AND 4 \ APPROXIMATE LOCATION OF FORMER WASTEWATER IMPOUNDMENT SB1 MW-1 LOW-VOLUME WASTEWATER IMPOUNDMENTS 1 AND 2 MW-3 PROPOSED SOIL BORING LOCATIONS EXISTING SOIL BORING LOCATIONS GROUNDWATER MONITORING WELL LOCATIONS 50 100 GRAPHIC SCALE (FEET) KM4 11 1J/BB NONE FIGURE 4-5-1 PROPOSED LOCATIONS OF SOIL BORINGS FOR LVW 1 AND : IMPOUNDMENT CLOSURE PLAN SDS*E CNC1NA POWER PLAN! /MITTELH/4USER tcorporahon SDG&E 4-5-6December 1988' Encina Power Plant Rev: 0 Closure Plan P1080RM Sampling Method Soil samples will be obtained using a backhoe/ hand auger, or a drilling rig with a hollow stem auger and split-spoon sampler. Before taking each sample, the sampler will be cleaned with a non-Phosphate detergent and rinsed with water from a known source. Boring techniques will ensure that liquid is not introduced into the boring and will allow accurate detection of saturated zones. Rinse water and residues from the sampling procedures will be collected and either treated on-site or disposed of off-site pursuant to State and Federal Regulations. Sampling blanks will be taken at the end of each day. Lithologic logs will be kept for each of the soil borings. The following parameters will be used to describe the soils: lithology per Unified Soil Classification System (USCS), estimated percentages of secondary soil components, soil color per Munsell color charts, estimated plasticity, estimated consistency or density, and estimated moisture content. The lithologic logs will be completed by a qualified geologist or qualified civil engineer. After completion of each boring, the hole will be sealed with bentonite grout to prevent any groundwater contamination through the boring pathway. Each soil sample will weigh approximately 1,000 grams. This will provide an adequate sample for the designated analyses and replicate analyses, if necessary. Each sample will be placed in a wide-mouthed glass jar with a Teflon lined lid. Split samples will be provided to regulatory agencies upon request prior to sampling. Soil Analysis After arriving at the certified laboratory where the analyses will be performed, the soil samples will be tested for TPH, pH and total metals to provide levels for use in accordance with the Closure Step Decision Diagram, Attachment 4-4. If any contaminated soils are removed, confirmation samples from the affected quadrant, will be taken and analyzed for TPH, pH and total metals. The above will be repeated until all contaminated soils have been removed and the site is clean. /MITTELH/1USERcorporation SDG&E 4-5-7 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM G. SAMPLE CONTROL Each sample container will be labeled with the following information at the time of sampling: Facility Name Sample Number Sample Location Sample Type Date of Sample Time of Sample Name of Sampler Seals will be applied to each container immediately after collection to prevent tampering with the samples. The seals will display the following information: Sample Number Date of Sample Two blank samples, a trip blank and a sampling blank, will be prepared for each day of sampling. The trip blanks will be deionized water transferred to a sample bottle at the lab. The sampling blanks will consist of deionized water and will be handled in a manner similar to the samples. All samples will be placed in a container and packed in ice as needed. They will then be sent to the laboratory. The chain of custody procedures that are described in EPA SW-846 will be followed. The information pertinent to sampling the asphalt concrete and soil will be recorded in a hard bound log book. Entries in the log book will include the following information: Facility name Purpose of sampling Location at sampling site Field contact Type of waste sampled Description of sampling methodology Date and time of collection Weather at time of collection Soil classification, when applicable Field measurements Photos, if taken Signature of personnel responsible for sampling /MITTELhMUSERcorpora hon SDG&E Encina Power Plant Closure Plan 4-5-8 December 1988 Rev: 0 P1080RM H. ANALYTICAL PROCEDURES 1. Total Petroleum Hydrocarbon (TPH)- Method 418.1 2. Total Metals - Acid Digestion, Method 3050, SW-846, Analyze for the following parameters: Arsenic Barium Chromium (total) Copper Lead Mercury Nickel Vanadium Zinc Method 7060 or 7061 7080 or 7081 7190 210.1 or 220.2 7421 7470 or 7471 7520 or 7521 286.1 or 286.2 289.1 or 289.2 SW-846 SW-846 SW-846 EPA-600/4-79-020 SW-846 SW-846 SW-846 EPA-600/4-79-020 EPA-600/4-79-020 5. 6. Waste Extraction Test - 22 CAL. Adm. Code 66700. Analyze the extract for the parameters listed in Item #1 above that exceed 10 times their STLCs. (Note: EP-toxicity tests will not be conducted since the WET extract almost always has higher metal levels due to the use of citrate, a stronger complexing ligand than acetate.) Deionized Water Extraction Test - Use WET-procedure, but with deionized water rather than citric acid for extraction solution. Analyze extract for above metals listed in Item #1. Soil pH - Method 9045, SW-846. pH - Method 9040, SW-846 Archived samples and extracts for analyses will be held in storage only for the time and under the conditions specified in EPA and DHS analytical protocol documents. /VIITTELHMUSERcorporation SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RM ATTACHMENT 4-6 LETTER REGARDING REMEDIAL INVESTIGATION REPORT STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD SAN DIEGO REGION 9771 Clainmont Mm Blvd.. Suite 6 S»n Di»go, California 92124-1331 Telephone: 1619) 26&-5114 May 11, 1988 Mr. Fred Jacobsen San Diego Gas & Electric Company P.O. Box 1831 San Diego, California 92112 Dear Mr. Jacobsen: RE: REMEDIAL INVESTIGATION REPORT FOR THE ENCINA POWER PLANT Regional Board staff has reviewed the ahove referenced document submitted February 22, 1988. According to the report, soil from beneath the Low Volume Waste (LVW) impoundments contain vanadium which exceeds the Soluble Threshold Limit Concentration (STLC) standards for hazardous waste. The elevated concentrations indicate that a polluted vadose zone exists beneath LVW impoundment No. 2 which presents a potential threat to water quality. Based on this information, soil remediation will be necessary beneath the LVW impoundments. No sample analyses results of the liners or soil from beneath the other impoundments exceed the Soluble Threshold Limit Concentration (STLC) or the Total Threshold Limit Concentration (TTLC) standards for hazardous waste and no ground-water sample analyses results exceed drinking water standards. San Diego Gas & Electric Company (SDG&E) will be required to continue monitoring the ground water for possible migration of waste constituents. It is our understanding, through a meeting with staff on April 6, 1988, that SDG&E has opted to close the existing surface impoundments due to extensive work needed to meet the Subchapter 15 seismic criteria for construction. It is our understanding that SDG&E intends to use above-ground tanks instead of surface impoundments. SDG&E will be required to close the surface impoundments pursuant to Article 8, Subchapter i5, Chapter 3, Title 23 of the California Code of Regulations. Under Article 8, SDG&E is required to submit, for approval, a closure plan detailing closure activities and post- closure maintenance. If you have any questions, please call John Anderson at the above number. Very truly yours, LADIN H. DELA Executive Officer jpa cc: Charlene Herbst, TPCA Program Manager, Division of Water Quality, Sacramento /HITTELH>IUSER t.corporation SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RE SECTION 5.0 SAMPLE CONTROL /MITTELH/JUSER vcorpora hon SDG&E 5-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RE 5.0 SAMPLE CONTROL The closure procedures for the wastewater ponds may require samples of liquid, sludge, asphalt concrete and soil to be taken and analyzed. All samples will be labeled and sealed to prevent contamination of, or tampering with, the samples. Any shipping container will also be sealed. To establish the documentation necessary to trace sample possession from the time of custody, a Chain of Custody Record will be filled out and will accompany every set of samples. The laboratory will conduct established quality control procedures throughout the analyses. This will include blanks, spikes, internal standards, and duplicate samples. SDG&E will split some of the samples and label them differently and use them as a quality control procedure. This information will be available for each sample set. Further details are presented in the Sampling and Analysis Program in Attachment 4-5. /VIITTELH/1USER t.corporation SDG&E December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RF SECTION 6.0 DECONTAMINATION OF FACILITY EQUIPMENT /V1ITTELH>1USER u^corporation SDG&E 6-1 December 1988 Encina Power Plant Rev: 0 Closure Plan P1080RF 6.0 DECONTAMINATION OF FACILITY EQUIPMENT All wastes will be removed from the ponds and either discharged in compliance with SDG&E's NPDES permit or be shipped to an approved disposal site by a registered waste hauler. When closure is complete, all equipment and structures associated with the ponds which will not be used with the new abovegrade tank treatment system will have been properly disposed of or decontaminated by removing wastes and residues. Pipelines, valves, pumps and fittings which convey waste to the ponds will be flushed. Flush water will be collected in temporary tanks such as a Baker Tank or in the ponds and be treated in the on-site wastewater treatment system or disposed of off-site pursuant to State and Federal Regulations. Wastewaters treated on-site will be discharged pursuant to the Plant's NPDES Permit. Equipment used during closure for sampling or to clean the asphalt concrete will also be decontaminated. Cleaning of this equipment during the closure activities will be done in a portable tank or in a bermed area such as a "Porta-Berm" system. The wash water will be disposed in the same manner as the flush water from the pipeline decontamination activity.