Appendix F. Industrial Wastewater

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1 Appendix F Industrial Wastewater

2 Table of Contents Page F.1 Background... F-1 F.2 Facilities... F-1 F.2.1 Condensate Collection and Discharge... F-2 F.2.2 Groundwater Collection and Discharge... F-2 F.2.3 Dry-Weather Runoff Collection and Discharge... F-3 F.2.4 Industrial Wastewater Pretreatment System... F-3 F.3 Operation and Maintenance... F-3 F.3.1 Condensate Collection System... F-5 F.3.2 Groundwater Collection System... F-5 F.3.3 Diversion System... F-5 F.3.4 Liquids Treatment System... F-5 F.3.5 Industrial Wastewater Monitoring Instrumentation... F-6 F.4 Industrial Wastewater Monitoring Program... F-6 F.5 Summary of Industrial Wastewater Monitoring Results... F-10 F.5.1 Summary Table Analysis... F-10 F Volatile Organic Compounds... F-10 F Semi-Volatile Organic Compounds... F-14 F Metals... F-14 F Pesticides... F-14 F General Mineral and Physical Parameters... F-15 F.6 Conclusions... F-15 F.7 References... F-15 List of Tables Page Table F-1: Inspection Schedule for Systems Generating Industrial Wastewater... F-4 Table F-2: Table F-3: Industrial Wastewater Monitoring Program for the... F-7 Industrial Wastewater Summary of Sampling Results... F-11 List of Figures Figure F-1: Figure F-2: Figure F-3: Figure F-4: Condensate Collection System Groundwater Collection System Dry-Weather Diversion Systems Schematic of Industrial Wastewater Conveyance Systems F-i

3 Appendix F: Industrial Wastewater F.1 Background At the request of Citizens Advisory Board (CAB) members, the following describes the industrial wastewater treatment system employed at the Palos Verdes Landfill (Site). Industrial wastewater generated at the Site is discharged to the sanitary sewer pursuant to industrial wastewater discharge permits issued by the Industrial Wastewater Section of the County Sanitation Districts of Los Angeles County (Sanitation Districts). These permits contain monitoring and reporting requirements and discharge limitations in compliance with the Sanitation Districts Wastewater Ordinance and other applicable laws and regulations to protect the downstream sanitary sewer system and to ensure compliance at the downstream regional wastewater treatment facility. All industrial wastewater discharged from the Site, along with wastewater from businesses and residences, is conveyed through closed underground sewer lines, to a centralized wastewater treatment facility in Carson, California. The Site currently operates under three Industrial Wastewater Discharge Permits: Permit Nos , 11561, and Permit Nos and were originally issued on July 16 and December 17, 1987, respectively, and Permit No was originally issued on February 25, These permits are revised and renewed every five years. The currently applicable version of Permit No became effective on February 7, The currently applicable versions of Permit Nos and became effective on February 23, In addition, Permit Nos and have been revised by an addendum dated July 29, 2005 and a modification that applied to both of the permits dated September 13, F.2 Facilities The Site is currently divided into three areas: the Main Site, the South Coast Botanic Garden, and Ernie Howlett Park. Figures F-1 through F-4 show the wastewater collection, diversion, and conveyance systems. The permitted discharge locations for Permit Nos , 11561, and are designated on Figure F-2 as SB4, SB3, and SB5, respectively. The majority of the industrial wastewater from the Main Site is discharged to the sanitary sewer at Discharge Station SB3 pursuant to Permit No These flows include landfill gas condensate (condensate) from the Main Site, extracted groundwater from the Main Site, and underdrain water from the Main Site. The flows from these sources are treated prior to being combined with flows of cooling water blowdown from the Gas-to-Energy facility and the dry-weather surface runoff diversion system from the western portion of the Main Site. The underdrain water and extracted groundwater from Ernie Howlett Park discharges to the sanitary sewer at SB4 under Permit No Extracted groundwater and condensate from the South Coast Botanic Garden and dry-weather surface runoff from the eastern portion of the Main Site are discharged to the sanitary sewer at SB5 under Permit No Treatment of the flows at SB4 and SB5 is not necessary because these F-1

4 flows meet the discharge limitations of their respective industrial wastewater discharge permits without treatment. F.2.1 Condensate Collection and Discharge Landfill gas condensate is generated as a by-product of the landfill gas collection system. Landfill gas is saturated and forms liquid condensate due to a reduction of temperature while moving through collection pipelines. Landfill gas condensate typically contains measurable levels of volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs). The existing condensate collection system at the Site is shown on Figure F-1. The majority of the condensate collection system is located on the Main Site with a lesser amount located at the South Coast Botanic Garden. Primarily inert wastes were disposed at Ernie Howlett Park; accordingly, there is no gas extraction or condensate collection system at the park. Condensate generated in landfill gas headerlines flows to low points and is gravity drained to condensate sumps located throughout the Main Site and South Coast Botanic Garden. From these sumps, the condensate is pumped to either the Liquid Treatment System at SB3 or to the holding tank at SB5 as shown on the Figure F-4 schematic. The condensate collection system also collects liquids from gas wells equipped with dedicated liquid extraction systems. Pumps have been installed in each of these wells to maximize gas extraction potential. Currently, there are 86 gas wells and/or trenches that are equipped with dedicated pumps. The majority of these wells/trenches are located on the northeast boundary of the Main Site; however, a few wells/trenches are located in other parts of the Main Site. Condensate and other liquids that are collected from these gas wells/trenches are pumped to the treatment plant at SB3. F.2.2 Groundwater Collection and Discharge Sixteen groundwater extraction wells are operated at the Site. Discharge from these wells is eventually routed to one of the three sanitary sewer discharge locations (Figure F-2). As shown on Figure F-4, extracted groundwater from Wells E01 through E11, and E14 is treated via an oil/water separator, an air stripper, and a clarifier prior to discharge at SB3. Extraction Well E13 is treated by an air stripper and a clarifier prior to discharge at SB3. Extraction Well E12 is located at Ernie Howlett Park. The groundwater extracted from E12 is discharged to the sanitary sewer at SB4. Extraction Wells E15 and E16 are located on the northeast side of the South Coast Botanic Garden. Groundwater extracted from E15 and E16 is discharged to the sanitary sewer at SB5. Treatment of the groundwater extracted from E12, E15, and E16 is not necessary because these flows meet the industrial wastewater discharge limitations without treatment. In addition to the groundwater extraction system, there are two underdrains located beneath the Site that are used to collect contaminated waters. These underdrain systems are designated on Figure F-2 as the Parcel 6 Underdrain and the Parcel 4 Underdrain. The Parcel 6 Underdrain runs along the northeast boundary of the Main Site. The liquids collected by the Parcel 6 Underdrain flow by gravity to Sump 7 in the northern corner of the Main Site before treatment via an oil/water separator, an air stripper, and a clarifier prior to discharge at SB3. The Parcel 4 Underdrain runs beneath the center of Ernie F-2

5 Howlett Park as shown on Figure F-2. The Sanitation Districts installed this underdrain in 1969 to collect natural seepage flowing in the canyon where Parcel 4 (now Ernie Howlett Park) was to be filled. The liquids collected by the Parcel 4 Underdrain flow by gravity to the Parcel 4 Sump at the eastern corner of Ernie Howlett Park. These flows are pumped without treatment to the SB4 sanitary sewer discharge location. F.2.3 Dry-Weather Runoff Collection and Discharge The Sanitation Districts have installed three dry-weather surface runoff diversion systems to capture potential spills from the landfill gas condensate collection system or the extracted groundwater collection system. The surface areas served by the diversion systems and the industrial wastewater discharge locations are shown on Figure F-3. The diversion systems are designed to capture dry-weather surface water runoff at diversion sumps located adjacent to storm inlets NPD2 (adjacent to the Gas-to-Energy facility), NPD3 (eastern corner of the Main Site), and NPD5 (low-point drain along the northeast boundary). NPD2 flow is diverted to SB3 pursuant to Permit No NPD3 and NPD5 flows are diverted to SB5 pursuant to Permit No The diversion sumps each have a capacity of approximately 3,000-gallons and are comprised of pre-cast concrete vaults equipped with two submersible pumps, a rainwater switch, and discharge piping. When dry-weather flow enters the sump, the sump operates as a fill-and-draw pump station to direct the flow to the associated industrial wastewater discharge location. Under the conditions of the industrial wastewater permits, the diversion pumps are deactivated after 0.05 inches of rainfall or after the sump has pumped 4,000 gallons in 24 hours, whichever occurs first. After the diversion pumps are deactivated, the 3,000- gallon vault continues to fill as additional storm water runoff is collected. If the intensity or duration of the rain event exceeds the available storage, the vault will overflow and discharge the additional storm water to the adjacent storm drain inlet. This system allows the vault to collect up to 7,000 gallons of rainwater before storm water is discharged to the storm drain system. Twenty-four hours after the cessation of rain, the pumps are reactivated and the accumulated storm water is pumped to the sanitary sewer. The diversion systems are equipped with alarms to warn site personnel of potential high water levels and/or system malfunctions. F.2.4 Industrial Wastewater Pretreatment System As shown on Figure F-4, a portion of the flow that is discharged at SB3 receives treatment at the Liquid Treatment System prior to being discharged to the sanitary sewer. This system is defined in the industrial wastewater discharge permit as a pretreatment system because all of the flow discharged to the sanitary sewer receives additional treatment at the Joint Water Pollution Control Plant in Carson. The Liquid Treatment System at SB3 consists of an oil/water separator, an air stripper, and a clarifier. The operation of this system is discussed in Section F.3.4. F.3 Operation and Maintenance Table F-1 outlines inspection and data collection frequencies for components of the industrial wastewater collection, treatment, and discharge system. If any conditions are F-3

6 observed that require maintenance, the field technician will either perform the work or submit a request for the work. Table F-1: Inspection Schedule for Systems Generating Industrial Wastewater Component Inspection Frequency Data Collection Frequency Condensate Collection Sumps and Pumps Sump 7 Daily Daily Getty Sump Daily Daily NE Torpedo Sump Daily Daily Parcel 4 Sump Daily Weekly Hawthorne Sump Daily Weekly 50 Series Sump Daily Weekly Low Point Tank Daily Weekly Crenshaw Sump Daily Daily FS3 Sump Daily Daily BC Sump Daily Weekly BR Sump Daily Weekly Extraction Wells E01 Weekly Bi-Weekly E02 Weekly Bi-Weekly E03 Weekly Bi-Weekly E04 Weekly Bi-Weekly E05 Weekly Bi-Weekly E06 Weekly Bi-Weekly E07 Weekly Weekly E08 Weekly Weekly E09 Weekly Bi-Weekly E10 Weekly Weekly E11 Weekly Weekly E12 Weekly Weekly E13 Weekly Weekly E14 Weekly Weekly E15 Weekly Weekly E16 Weekly Weekly Sewer Discharge Points SB3 Twice Daily Daily SB4 Bi-Weekly Weekly SB5 Twice Daily Daily Gas Well Pumps First Bench Wells Daily Weekly Other Wells Weekly Weekly Discharge Tanks Tanks at SB3 Daily Daily Tank at SB5 Daily Daily F-4

7 F.3.1 Condensate Collection System During daily inspections, site technicians note whether the sumps/tanks are functioning properly. Pumps are run manually to be sure they are operational. Volumetric flow data are regularly collected (see Table F-1 for frequency) and compared with historical data to further ensure all liquid pumps are working properly. Landfill gas well pumps are inspected regularly to ensure that the systems are operating properly (Table F-1). Weekly flow readings are collected for each gas well pump. Volumetric flow data are compared with historical data to further ensure all systems are functioning properly. F.3.2 Groundwater Collection System During weekly inspections, site technicians note whether groundwater extraction pumps are functioning properly and record the discharge volumes. Site technicians monitor the underdrain collection sumps, the Parcel 4 Sump, and the Sump 7 (see Table F-1 for frequency), and the accumulated volumes are recorded. Volumetric flow data are compared with historical data to further ensure all systems are functioning properly. Groundwater extraction wells are equipped with pumps that automatically turn on and off based on the groundwater level. These systems are typically set to maintain ten feet or more of drawdown in each extraction well. The volume of pumped groundwater and the number of operational hours for each well is recorded by site technicians on a weekly basis. In some cases, the mixture of condensate and extracted groundwater has an increased scale potential from calcium carbonate and other minerals. This scale can cause blockages in the collection system that could potentially lead to accidental surface water discharges. To prevent scale induced blockages, the condensate/groundwater transfer line from the BC Sump to the FS3 Tank (see Figure F-4) and the sewer connection lines at SB3, SB4, and SB5 are hydrojetted approximately every six months. Other condensate and groundwater collection lines are cleaned as needed. F.3.3 Diversion System During normal operations, the diversion systems collect only minor amounts of irrigation runoff. Site personnel check the diversion systems on a daily basis to ensure proper operation and to collect flow volume readings. In addition, if the liquid level within any of the diversion collection vaults reaches a specified upper level (outside of a rainfall event) or if a diversion sump generates more than 4,000 gallons during any 24-hour period, an alarm is triggered and a field technician will investigate. If any conditions are observed that require maintenance, the field technician will either perform the work or submit a request for the work. F.3.4 Liquids Treatment System The majority of the flow from the Main Site is treated by the Liquids Treatment System prior to discharge at SB3. The majority of the extracted groundwater and landfill gas condensate is routed to the oil/water separator where floating materials (primarily oils) are removed. The oil is collected in 55-gallon drums and is removed by an F-5

8 environmental contractor every ninety days. The Site generates approximately 500 pounds of oil every 90 days. The water from the oil/water separator is directed to an influent sump where it combines with flow from Extraction Well E13 and condensate from the NE Torpedo Sump and the Hawthorne Sump. Liquids in the influent sump are pumped into flow/equalization tanks. The liquid in the equalization tanks is pumped to an air stripper then to a clarifier prior to discharge to the sanitary sewer system. This is shown schematically on Figure F-4. Off gases from the air stripper are piped to the Gasto-Energy facility where they are combusted. After the air stripper, settlable solids are removed by a clarifier. The clarifier solids flow into the treatment plant sludge tank. Collected solids from the wastewater stream are removed by an environmental management contractor for proper disposal approximately every six months. The Site generates about 2,000 gallons of clarified sediment every six months. F.3.5 Industrial Wastewater Monitoring Instrumentation Pursuant to Industrial Wastewater Discharge Permits 10995, 11561, and 11695, the sewer discharges at SB4, SB3, and SB5 are monitored continuously. Chart recorders document the ph and flow rate at SB3, SB4 and SB5. The ph meters at SB3 and SB5 are calibrated weekly by Site instrument technicians 1. Discharge flow meters are calibrated at least annually. Specifically, hydraulic calibrations are performed every three years and instrument calibrations are performed in the years that hydraulic calibrations are not performed. Calibration reports are submitted to the Sanitation Districts Industrial Waste Section as required by the respective permits. An alarm on the flow meter at SB3 is monitored in the Gas-to-Energy facility control room. If the discharge location experiences high flow, site personnel are sent to investigate and implement corrective actions as necessary. The ph meter at Discharge Location SB5 is wired to the Site s call-out alarm system. If the measured ph falls below 6.0 ph units, site personnel are called to investigate and implement corrective actions as necessary. F.4 Industrial Wastewater Monitoring Program As required by the current Self-Monitoring Requirements (SMRs) associated with Permit Nos , 11561, and 11695, wastewater samples are collected at least quarterly from each of the discharge locations. The industrial wastewater sampling parameters and the currently applicable discharge limitations are presented in Table F-2. 1 An effluent ph meters is not required for Permit No Consequently, this meter is calibrated as necessary. F-6

9 Table F-2: Industrial Wastewater Monitoring Program for the Constituent Units Permit (SB3) Permit (SB4) Permit (SB5) Monitoring Parameter Limitation Monitoring Parameter Limitation Monitoring Parameter Limitation General Parameters ph ph units Yes 6.0 Yes 6.0 Yes 6.0 Soluble Sulfide mg/l Yes 0.1 Yes 0.1 Yes 0.1 Suspended Solids mg/l Yes -- Yes -- Yes -- Total COD mg/l Yes -- Yes -- Yes -- Total Cyanide mg/l Yes 1.2 Yes 1.2 Yes 1.2 Metals Arsenic mg/l Yes 3 Yes 3 Yes 3 Cadmium mg/l Yes 0.69 Yes 0.69 Yes 0.69 Total Chromium mg/l Yes 2.77 Yes 2.77 Yes 2.77 Copper mg/l Yes 3.38 Yes 3.38 Yes 3.38 Lead mg/l Yes 0.69 Yes 0.69 Yes 0.69 Mercury mg/l Yes 2 Yes 2 Yes 2 Nickel mg/l Yes 3.98 Yes 3.98 Yes 3.98 Silver mg/l Yes 0.43 Yes 0.43 Yes 0.43 Zinc mg/l Yes 2.61 Yes 2.61 Yes 2.61 Volatile Organic Compounds Volatile TTO ug/l Calculated Value 1,000 Calculated Value 1,000 Calculated Value ,1,1-Trichloroethane ug/l Yes -- Yes -- Yes -- 1,1-Dichloroethane ug/l Yes -- Yes -- Yes -- 1,2-Dichloroethane ug/l Yes -- Yes -- Yes -- Benzene ug/l Yes -- Yes -- Yes -- Bromodichloromethane ug/l Yes -- Yes -- Yes -- Bromoform ug/l Yes -- Yes -- Yes -- Chlorobenzene ug/l Yes -- Yes -- Yes -- Chloroform ug/l Yes -- Yes -- Yes -- Dibromochloromethane ug/l Yes -- Yes -- Yes -- Ethyl Benzene ug/l Yes -- Yes -- Yes -- Methylene Chloride ug/l Yes -- Yes -- Yes -- o-dichlorobenzene ug/l Yes -- Yes -- Yes -- F-7

10 Table F-2: Industrial Wastewater Monitoring Program for the (continued) Permit (SB3) Permit (SB4) Permit (SB5) Constituent Units Monitoring Monitoring Monitoring Limitation Limitation Limitation Parameter Parameter Parameter Volatile Organic Compounds p-dichlorobenzene ug/l Yes -- Yes -- Yes -- Tetrachloroethylene ug/l Yes -- Yes -- Yes -- Toluene ug/l Yes -- Yes -- Yes -- Trans-1,2- ug/l Yes -- Yes -- Yes -- Trichloroethylene ug/l Yes -- Yes -- Yes -- Vinyl Chloride ug/l Yes -- Yes -- Yes -- Semi-Volatile Organic Compounds Semi-Volatile TTO ug/l Calculated Value 1,000 Calculated Value 1,000 Calculated Value 1,000 Acenaphthene ug/l Yes -- Yes -- Yes -- Anthracene ug/l Yes -- Yes -- Yes -- Diethyl Phthalate ug/l Yes -- Yes -- Yes -- Diethylhexyl Phthalate ug/l Yes -- Yes -- Yes -- Di-N-Butyl Phthalate ug/l Yes -- Yes -- Yes -- Fluoranthene ug/l Yes -- Yes -- Yes -- Fluorene ug/l Yes -- Yes -- Yes -- Isophorone ug/l Yes -- Yes -- Yes -- Naphthalene ug/l Yes -- Yes -- Yes -- Phenanthrene ug/l Yes -- Yes -- Yes -- Pyrene ug/l Yes -- Yes -- Yes -- Pesticides Aldrin ug/l Yes 0 No -- Yes 0 Alpha-BHC ug/l Yes 0 No -- Yes 0 Aroclor 1016 ug/l Yes 0 No -- Yes 0 Aroclor 1221 ug/l Yes 0 No -- Yes 0 Aroclor 1232 ug/l Yes 0 No -- Yes 0 Aroclor 1242 ug/l Yes 0 No -- Yes 0 Aroclor 1248 ug/l Yes 0 No -- Yes 0 Aroclor 1254 ug/l Yes 0 No -- Yes 0 F-8

11 Table F-2: Industrial Wastewater Monitoring Program for the (continued) Constituent Units Permit (SB3) Permit (SB4) Permit (SB5) Monitoring Parameter Limitation Monitoring Parameter Limitation Monitoring Parameter Limitation Pesticides Aroclor 1260 ug/l Yes 0 No -- Yes 0 Beta-BHC ug/l Yes 0 No -- Yes 0 Delta-BHC ug/l Yes 0 No -- Yes 0 Dieldrin ug/l Yes 0 No -- Yes 0 Endosulfan I ug/l Yes 0 No 0 Yes 0 Endosulfan II ug/l Yes 0 No 0 Yes 0 Endosulfan Sulfate ug/l Yes 0 No 0 Yes 0 Endrin ug/l Yes 0 No 0 Yes 0 Endrin Aldehyde ug/l Yes 0 No 0 Yes 0 Heptachlor ug/l Yes 0 No 0 Yes 0 Heptachlor Epoxide ug/l Yes 0 No 0 Yes 0 Lindane (Gamma-BHC) ug/l Yes 0 No 0 Yes 0 pp'-ddd ug/l Yes 0 No 0 Yes 0 pp'-dde ug/l Yes 0 No 0 Yes 0 pp'-ddt ug/l Yes 0 No 0 Yes 0 Technical Chlordane ug/l Yes 0 No 0 Yes 0 Toxaphene ug/l Yes 0 No 0 Yes 0 mg/l - milligrams per liter ug/l - micrograms per liter COD - chemical oxygen demand TTO - total toxic organics " " - greater than or equal to; "--" - no permit limit F-9

12 F.5 Summary of Industrial Wastewater Monitoring Results Section 6.4 of the Work Plan (Todd and RBD, May 2004), states that Wastewater quality data collected during the RI and the recent data will be compiled and summary tables prepared. The summary tables will tally the number of samples analyzed, the number of non-detect results, and the range of results. The percentage of recent samples that exceed permit limitations will be calculated. The data will be assessed to determine if wastewater quality complies with permit requirements. F.5.1 Summary Table Analysis A summary of the industrial wastewater SMR data has been prepared to assess compliance with the industrial wastewater discharge permits. The compounds have been divided for discussion purposes into categories as follows: 1) VOCs, 2) SVOCs, 3) metals, 4) pesticides; and 5) general mineral and physical parameters. The data are also divided into historic (January 1, 1987 through June 30, 1994) and recent (July 1, 1994 and December 31, 2006) time periods. Table F-3 includes the total number of samples analyzed, the range of values, and the number of non-detects for the recent and historic periods. In addition, the recent data are compared to the currently applicable permit limitations (evaluation criteria). The number and percentage of instances where permit limitation criteria were exceeded in the recent time period are provided. The analytical results are discussed in the following paragraphs. All instances where evaluation criteria were not met occurred at SB3, which handles all of the condensate and extracted groundwater from the Main Site. These instances were infrequent and each event was addressed as the situation dictated. No on-going instances of criteria exceedences are observed. F Volatile Organic Compounds The self-monitoring requirements of Permit Nos , 11561, and 11695, prescribe a limitation of 1,000 micrograms per liter (ug/l) for Volatile Total Toxic Organics (Volatile TTO). The Volatile TTO for a sample is the summation of the detected concentrations of methylene chloride, chloroform, 1,1,1-trichloroethane, carbon tetrachloride, 1,1-dichloroethene, trichloroethylene, tetrachloroethylene, bromodichloromethane, dibromochloromethane, bromoform, chlorobenzene, vinyl chloride, 1,2-dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, 1,l-dichloroethane, 1,1,2-trichloroethane, 1,2-dichloroethane, benzene, toluene, ethylbenzene, trans-1,2- dichloroethylene, bromomethane, chloroethane, 2-chloroethylvinylether, chloromethane, 1,2-dichloropropane, cis-l,3-dichloropropene, trans-1,3-dichloropropene, and 1,1,2,2- tetrachloroethane. For the purpose of this calculation, non-detect values and constituents that are not required to be tested are treated as zero. The Volatile TTO limitation was not exceeded in the recent or historic periods. F-10

13 Table F-3: Industrial Wastewater Summary of Sampling Results Constituent (a) Units No. Analyzed Historic Min Max No. ND No. Analyzed Recent Min Max No. ND Limit No. (%) Criterion (b) General Parameters ph ph (0.6%) Soluble Sulfide mg/l 54 <0.1 < < (0.6%) Suspended Solids mg/l <10 3, Total COD mg/l , Total Cyanide mg/l 55 < < Metals Arsenic mg/l Cadmium mg/l 55 < < Chromium (Total) mg/l 55 < < Copper mg/l 55 < < Lead mg/l 55 < < Mercury mg/l 55 < < Nickel mg/l 55 < < Silver mg/l 55 < < Zinc mg/l 55 < < (1.7%) F-11

14 Table F-3 Industrial Wastewater Summary of Sampling Results (continued) Historic Recent Constituent (a) Units No. Analyzed Min Max No. ND No. Analyzed Min Max No. ND Limit No. (%) Criterion (b) Volatile Organic Compounds 1,1,1-Trichloroethane ug/l 55 < <0.5 < ,1-Dichloroethane ug/l 55 < < ,2-Dichloroethane ug/l 55 < < Benzene ug/l 55 < < Bromodichloroethane ug/l 55 < < Bromoform ug/l 55 < < Chlorobenzene ug/l 55 < < Chloroform ug/l 55 < < Dibromochloromethane ug/l 55 < < Ethylbenzene ug/l 55 < < Methylene Chloride ug/l 55 < < o-dichlorobenzene ug/l 55 < < p-dichlorobenzene ug/l 55 < < Tetrachloroethylene ug/l 55 < < Toluene ug/l 55 < < Trans-1,2-Dichloroethylene ug/l 55 < < Trichloroethylene ug/l 55 < < Vinyl Chloride ug/l 55 < < IW Limit Exceedances for VOCs (Volatile TTO) ug/l ,000 0 F-12

15 Table F-3 Industrial Wastewater Summary of Sampling Results (continued) Constituent (a) Units No. Analyzed Historic Min Max No. ND No. Analyzed Recent Min Max No. ND Limit No. (%) Criterion (b) Semi-Volatile Organic Compounds Acenaphthene ug/l 55 < < Anthracene ug/l 55 < < Diethyl Phthalate ug/l 55 < < Diethylhexyl Phthalate ug/l 55 <10 22, < Di-n-butyl Phthalate ug/l 55 < < Fluoranthene ug/l 55 < < Fluorene ug/l 55 < < Isophorone ug/l 55 < < Napthalene ug/l 55 < < Phenanthrene ug/l 55 < < Pyrene ug/l 55 < < IW Limit Exceedances for SVOCs (Semi -volatile TTO) ug/l , ,000 0 Pesticides Aroclor 1242 ug/l 8 < < (9.0%) Aroclor 1254 ug/l 8 < < (1.5%) Aroclor 1260 ug/l 8 <0.1 < < (1.5%) Lindane ug/l 8 < <0.01 < pp'-ddd ug/l 8 < <0.01 < pp'-dde ug/l < (8.8%) pp'-ddt ug/l 8 <0.01 < <0.01 < Technical Chlordane ug/l 8 < <0.05 < (a) Constituent list includes those detected during the recent period (7/1/94-12/31/06) or the historic period (1/1/87-6/30/94) (b) Number and percent criterion are number (and percentage) of instances when permit limits were exceeded ND - not detected; "--" - not applicable; "<" - less than detection limit; greater than or equal to; IW - industrial wastewater ug/l - micrograms per liter; mg/l - milligrams per liter Min - minimum; Max - maximum F-13

16 F Semi-Volatile Organic Compounds The self-monitoring requirements of Permit Nos , 11561, and 11695, prescribe a limitation of 1,000 micrograms per liter (ug/l) for Semi-volatile Total Toxic Organics (Semi-volatile TTO). The Semi-volatile TTO for a sample is the summation of the detected concentrations of acenaphthene, acenaphthylene, anthracene, benzidine, 1,2- benzanthracene, benzo(a)pyrene, 3,4-benzofluoroanthene, 1,12-benzoperylene, 11,l2- benzofluoranthene, bis (2- chloroethoxy) methane, bis (2-chloroethyl) ether, bis (2- chloroisopropyl) ether, bis (2-ethylhexyl) phthalate, 4-bromophenyl phenyl ether, butyl benzyl phthalate, 2- chloronaphthalene, 4-chlorophenyl phenyl ether, chrysene, 1,2,5,6- dibenzanthracene, 3,3-dichlorobenzidine, diethyl phthalate, dimethyl phthalate, di-n-butyl phthalate, 2,4-dinitrotoluene, 2,6-dinitrotoluene, di-n-octyl phthalate, 1,2- diphenylhydrazine, fluoranthene, fluorene, hexachlorobenzene, hexachlorobutadiene, hexachlorocyclopentadiene, hexachloro-ethane, indeno (l,2,3-c,d)pyrene, isophorone, naphthalene, nitrobenzene, N-nitrosodimethylamine, N-nitrosodi-n-propylamine, phenanthrene, pyrene, 2,3,7,8-TCDD, 1,2,4- trichlorobenzene, 2,4-dinitrophenol, 2- methyl-4,6-dinitrophenol, 2-nitrophenol, 4- nitrophenol, 4-chloro-3-methylphenol, pentachlorophenol, 2,4,6-trichlorophenol, and N-nitrosodiphenylamine. For the purpose of this calculation, non-detect values and constituents that are not required to be tested are treated as zero. There were no exceedances of the Semi-volatile TTO limitation in the recent period. F Metals Metals were frequently detected in the industrial wastewater samples (Table F-3), however the low concentrations of metals in the industrial wastewater were generally below the discharge limitations. The levels of arsenic, cadmium, total chromium, copper, lead, mercury, nickel, and silver were consistently below the applicable discharge limitations. Of the 116 zinc samples collected in the recent period, only two samples (1.7 percent) exceeded the 2.61 milligrams per liter (mg/l) limitation for zinc. F Pesticides The self-monitoring requirements of Permit Nos and prescribe that pesticides shall not be detected in the industrial wastewater. Four pesticide compounds have been detected in the recent period. These detections consisted of three polychlorinated biphenyls (Aroclor 1242, Aroclor 1254, and Aroclor 1260) and pp -DDE. There were 69 samples analyzed for Aroclor 1242 in the recent period and this compound was detected in six (9.0 percent) of those samples. Sixty-seven (69) samples were analyzed for Aroclor 1254 and Aroclor 1260, and each of these compounds was detected only once (1.5 percent). Of the 70 pp -DDE samples collected in the recent period, pp -DDE was detected in six samples (8.8 percent). The majority of these detections occurred in 1994 and The Sanitation Districts instituted corrective action and since 2005 there have been no detections of pesticides in any of the industrial wastewater samples from the Site. F-14

17 F General Mineral and Physical Parameters The Site has been largely in compliance with permit limitations for the general mineral and physical parameters. The ph levels in recent and historic samples appear to be relatively consistent, and are generally within the neutral range of 6.5 to 8.5 (Table F-3). Of the 171 samples measured for ph in the recent period, only one sample (0.6 percent) was lower than the minimum ph limitation of 6.0 ph units. Soluble sulfide was generally not detected in recent and historic samples. Of the 170 soluble sulfide samples collected in the recent period, only one sample (0.6 percent) exceeded the 0.1 mg/l limitation. There are no discharge limitations for suspended solids and total chemical oxygen demand (COD). There have been no exceedances of the total cyanide limitation. F.6 Conclusions The Site is currently in compliance with all Industrial Waste permit conditions and limitations. In addition, industrial wastewater flows are discharged via subsurface sanitary sewer connections. Accordingly, as described in Appendix J, potential emissions from industrial waste discharges were deemed not to pose a long-term hazard to users of the Site. F.7 References Todd Engineers (Todd) and Risk-Based Decisions, Inc. (RBD), Work Plan, May F-15

18 Figures

19 LEGEND Condensate Line Collection Sump Wastewater Discharge at SB3 Wastewater Discharge at SB5 Property Boundary Ernie Howlett Park Main Site South Coast Botanic Garden N 0 Scale in Feet 500 August 2008 TODD ENGINEERS Alameda, California Figure F-1 Condensate Collection System

20 LEGEND Extraction Well Sump Discharge Piping Wastewater Discharge at SB3 Wastewater Discharge at SB4 Wastewater Discharge at SB5 Underdrain Property Boundary Ernie Howlett Park Main Site South Coast Botanic Garden N 0 Scale in Feet 500 August 2008 TODD ENGINEERS Alameda, California Figure F-2 Groundwater Collection System

21 Ernie Howlett Park Property Line Runoff Discharge Location NPDES Sampling Location Drop or Pipe Inlet Diversion Sump Subsurface SUBSURFACE Storm STORM DrainDRAIN Onsite Subsurface Drain Surface Channel Runoff Watershed Boundary Currugated Metal Pipe Currugated Metal Channel Dry Weather Runoff System Area Discharges to SB5 Area Discharges to SB3 Main Site South Coast Botanic Garden N Scale in Feet August 2008 TODD ENGINEERS Alameda, California Figure F-3 Dry-Weather Diversion Systems

22 Ernie Howlett Park LEGEND Storage/Holding Facility Source of Industrial Water: HLC (Headerline Condensate) and/or Liquids from Blowdown, Toe Drains and Underdrains Industrial Discharge Point Treatment Facility Extraction Well August 2008 TODD ENGINEERS Alameda, California Figure F-4 Schematic of Industrial Wastewater Conveyance Systems