To:  Rod Chisolm, USACE
     Frank Snitz, USACE
     Herb Cheong, USACE

From:  Gail Staba  (initialed)

Date   15 November 1996

Regarding:  Results of Telephone Meeting with RWQCB Regarding Acute Toxicity
            Results at Galbraith Dredged Material Facility

The telephone meeting occured at 8:30 a.m., Friday, 11.15.96.  The following
persons participated:  Gail Staba, Port; Eric Joliffe, ISACE; Paul Krause,
MEC; Greg Bartow, RWQCB; Bill Dutra, Dutra; Bob Johnston, Dura; Jim Galli,
Gutra; Phil Torres, Dutra.

Cleanup and abatement Order No. 96-148 was received by fax (attached).

The group discussed additional sampling and analysis results from samples
taken on 11/12/96.  I have included these results on the attached
effluent/biassay data table.  The focus of the discussion was on PAHs detected
in the effluent and how this, especially Napthalene, could be a causal factor
in bioassay morbidity.

MEC should sample upsteam of SW-2 and B and perform expedirted analysis of
filtered effluent for PAH.  This should provide further information on the
state of PAHs in question; whether PAJs are bound to sediment and could be
takne into organisms through their eating sediment poarticiles of PAHs in
solution and taken through gills.  If PAHs are possibly causing morbidity and
they are bound to sediemnt, remediation through filtering is an option.  If
PAHs are dissolved, remediation becomes more expensive and more a problem.

Dutra should devise a filtering system at SW-2A and B to decrease TSS and PAHs
bound to smaller particles.

As a result of the telecon and Abatement Order, the contract with MEC should
be amended to inlcude the following:

       -  Perform research for costing of equipment toread and log NTU
          continuously and log data.
       -  Provide sampling results in a table to discuss sediment chemistry
          results for PAHs on Togg Wing deliveries from the areas neaaaaar
          creosote piles
       -  Work with the Project Team to develop remediation plans for the
          current effluent violations and plan to meet effluent limits upon
          returning to turning wings dredging and delivery at Galbraith
       -  Perform sampling and analtsis and document when compliance with the
          Abatement Order is reached.

- SW-2A and SW-2B ------------------ Resulting from telecon: - Filtered bioassay (11/18/96) - Unfiltered bioassay (11/18/96) - Filtered with EDTA added to bioassay (11/18/96) - Filtered water PAH and VOC testing (11/15/96 and 11/18/96 Resulting from order: - TSS sampling and analysis every 6 hours - Continuous or hourly monitoring of turbidity and purchase of equipment as necessary - Daily 48 hour expedited analysis for metals (7) and sulfides and weekly expedited metals (11) and sulfides analysis Liberty _______ - Daily 48 hours expedirted analysis for metals (7) As a result of the telecon and Abatement Order, Dutra should be directed to perform the following: General ------- - Notify MEC of the samples previously collected from the Todd Wigg near creosote piles that may have contirbuted to bioassay violations of the Waste Discharge Order. - Develop and test a system for filtering decant water. Recommend testing at SW-3 for probable implementation at SW-3. This will be necessary to restart discharge if PAHs bound to small particles need to be minimized to meet effluent limits - Coordinate with MEC to monitor turbidity "continuously." Greg Bartow, RWQCB, indicated verbally that until regular compliance is established, this action is necessary. He would consider hourly NTU readings synonymous with continuously. - Revise Daily Report of Operations cover sheet to disaggregate volume of decant water discharged of SF Bay to volume for each VCA decanted over SW-2A (west pond) and SW-2B (east pont). - Prepare an estimate of the volume of decant water released to SF bay in excess of effluent limits noted in the Abatement Order, Table 2. - Work with Port to develop remediation plans for the current effluent violations and plan to meet effluent limits upon returning wings dredging and delviery at Galbraith. Port,m USACE, RWQCB, MEC, and Dutra will meet via telecon on Monday 11/18/96 at 4:00 p.m. to discuss further sampling results and proposed remediation. cc: Jim McGrath, Ralph Gin, Rob Andrews, Eric Joliffe, Paul Krause, GFreg Bartow, Phil Torres, Jim Galli, Bob Johnston, Bill Dutra.
Sheet 1 GALBRAITH DREDGED MATERIAL FACILITY EFFLUENT/BIOASSAY DATA DATE LOCATION BIOASSAY SURVIVAL DISSOLVED Ph DEGRESS SALINITY EXCEEDENCES H2S TSS PECENT CELCIUS 10/15/96 SW-2A 30 9.6 8.22 19.4 33.1 None 0.01 67.9 10/15/96 SW-2B 45 9 8.09 24.1 35.8 As <.02 66.2 10/29/96 SW-2A 15 9.4 8.37 14.7 31.9 Ni 0.18 25.4 10/29/96 SW-2B 85 8.3 7.87 15.5 31.6 None - 15.6 11/5/96 SW-2A 5 11 8.74 15.3 30 70.8 11/5/96 SW-2B 10 8.5 8.48 16.9 31 67.2 11/7/96 SW-2A 0 on day 1 10.2 8.67 14.8 30.6 83.4 11/7/96 SW-2B 0 on day 1 10.2 8.76 15 31 145.2 11/9/96 SW-2A 0 on day 1 8.5 8.35 15.8 30.8 44 11/9/96 SW-2B 65 on day 1 10.2 8.81 16.1 31.4 77.2 11/12/96 SW-2A filtered: 85 on day 1 9.4 8.34 15.9 30 PAHs detected, Ni 69.8 11/12/96 SW-2A unfiltered: 50 on day 1 9.4 8.34 15.9 30 PAHs detected, Ni 69.8 11/12/96 SW-2A filtered w/EDTA 175 ppm; 90 on day 1 9.4 8.34 15.9 30 PAHs detected, Ni 69.8 filtered w/edta 35 ppm; 80 on day 1 11/12/96 SW-2B filtered: 65 on day 1 8.6 8.6 16 30 PAHs detected, Ni 51.6 11/12/96 SW-2B unfiltered: 70 on day 8.6 8.6 16 30 PAHs detected, Ni 51.6 11/12/96 SW-2B filtered w/EDTA 175 ppm; 60 on day 1 8.6 8.6 16 30 PAHs detected, Ni 51.6 filtered w/edta 35 ppm; 90 on day 1 11/12/96 Liberty unfiltered: 100 11/12/96 SW-4 65

California Regional Water Quality Control Board Phone (510) 286-1255 San Francisco Bay Region Fax: (510) 286-1380 2101 Webster Street, suite 500 BBS (510) 286-0404 Oakland 94612 Stamp Date: Nov. 14 1996 File No. 2199.9305(GWB) Mr. Rick Ferrin Portland of Oakland 520 Water Street Oakland, CA 94607 Subject: Cleanup and Abatement Order No. 96-148 Dear Mr. Ferrin:
Enclosed is a copy of Cleanup and Abatement Order No. 96-149, relating to the NPDES permit violations at the Galbraith Dredged Sediment Disposal Site. There have been numerous violations of the fish toxicity limit and effluent limit for total suspended sediment. Therefore, we are issuing this Order which prohibits the continuing violation of the effluent limits in the Port's NPDES Permit. I urge you to take immediate measures necessary to comply with this Order. If you have any questions relating to this Order, please contact Gregory Bartow of my staff at (510 286-0741). Sincerely, s/ Loretta K. Barsamian Executive Officer cc: Jim McGrath, Port of Oakland Rod Chisholm Paul Krause US Army Corps of Engineers MEC Analytical Systems, Inc. San Francisco District 98 Main St., Suite 428 333 Market Street, 7th Floor Tiburon, CA 94920 San Francisco, CA 94105 Lt.Col. Richard G. Thompson Frank Sintz US Army Corps of Engineers US Army Corps of Engineers San Francisoc District San Francisco District 333 Market Street 333 Market Street, 7th Floor San Francisco, CA 94105 San Francisoc, CA 9415

(Attachment to above letter - CRWQCB letter dated 961114 STATE OF CALIFORNIA CALIFORNIA REGIONAL WATER QUALITY CONTROAL BOARD SAN FRANCISCO BAY REGION CLEANUP AND ABATEMENT ORDER NO. 96-148 PORT OF OAKLAND GALBRAITH DREDGED SEDIMENT DISPOSAL SITE OAKLAND, ALAMEDA COUNTY The California Regional Water Quality Control Board, San Frandcisco Bay Regional (hereinafter called the Board), finds that: 1. The Board issued NPDES Permit No. CA003007 (Order No. 94-131) to the Port of Oakland for discharge of up to 7 million gallons per day of decant water from Galbraith Dredged Sediment Disposal Site. 2. Based on the Daily Reports submitted to the Board, the Port violated the toxocity limit of 90% median survival during October and November 1996, as shown on Table 1. TABLE 1. SUMMARY OF BIOASSAY VIOLATIONS - GALBRAITH DREDGED SEDIMENT DISPOSAL SITE, OAKLAND, ALAMEDA COUNTY Sample Collecltion Date Fish Bloassay/Percent Survival (Menidia beryllina) Permit Combined Volume of Limit is a minimum median Water Discharged to survival of 90% S.F. BAY(1) Reported as total of SW-2\a and SW-2B S.F. Bay S.F. Bay Discharge Discharge Point SW-2A Point SW-2B October 15, 1996 30 45 2,000,000 October 22, 1996 75 85 not availabe October 29, 1996 15 85 4,300,000 November 5, 1996 5 10 900,000 November 7, 1996 0 0 2,200,000 November 9, 1996 65 0 not available All values indicate permit exceedences, 3. Based on the Daily Reports submitted to the Board, the Port exceeded the Total Suspended Sediment effluent limit of 100 mg/1 in October and November 1996, as shown on Table 2.
Cleanup and Abatement Order Port of Oakland page 2 TABLE 2. SUMMARY OF TOTAL SUSPENDED SEDIMENT VIOLATIONS - GALBRAITH DREDGED SEDIMENT DISPOSAL SITE, OAKLAND, ALAMEDA COUNTY Violation Date Total Suspended Sediment Level (mg/1) Permit Limit is 100 Combined Volume of mg/1 Decant Water Discharged to S.B.Bay (Reported as S.F. Bay S.F.Bay total of SW-2A and Discharge Discharge SW-2B) Point SW-2A Point SW-2B October 9, 1996 946* 13 5,000,000 October 12, 1996 98 180* 7,000,000 October 15, 1996 67 898* 2,200,000 October 17, 1996 106* 118* 800,000 October 18, 1996 154* 64 100,000 November 7, 1996 83 145* 2,200,000 November 8, 1996 259* 225* not available * Bold values indicate permit exceedence. 4. Pursuant to Water Code Section 13385, the above violations may subject the Discharger to a maximum liability of $10,000 per day of violation and $10 per gallon. 5. The Board finds that the Discharger has impacted waters of the State. This Order prohibits continuing violation of the effluent limits in the discharger's NPDEs Permit. 6. This Order is an action for the protection of the environment and is categorically exempt from the California Environmental Quality Act, purusant to Section 15108, Chapter 3, Title 14 of the California Code of Regulations. IT IS HEREBY ORDERED, PURSUANT TO THE CALIFORNIA WATER CODE SECTION 13304, that the Discharger shall abate the effect of further discharge, and take other remedial actions as follows: A. Prohibitions. The discharger shall cease discharging in violation of the effluent limits of NPDES Permit No. CA003007 (Order No. 940131).
Cleanup and Abatement Order Port of Oakland Page 3 B. Remedial Measures 1. Submit a technical report, acceptable to the Executive Officer within seven working days of receiving the Order that documents when compliance with this Order's Prohibition was achieved. In addition, such a report shall include an estiamte of the volume of sediment discharged to San Francisco Bay in excess of the effluent limit violations shown on Table 2. 2. The Self-Monitoring Plan in Order No. 94-131 is hereby amended as follows: a. The turbidity of the discharge shall be monitored continuously in the field and no discharge shall be permitted if the turbidity exceeds 50 NTUs. Total suspended sediment measurements shall be made every 6 hours. b. For the remainder of the project please submit the results to the Regional Board for metals (i.e., As, Cr, Cu, Cd, Pb, Ni,m Zn, Cn, Hg, Se, Ag), TSS, pH, dissolved oxygen, and dissolved sulfidesas hydrogen sulfide within 48 hours of sampling. This will allow staff to monitor compliance with the permit more closely, and allow field personnel to modify pond operation to maintain compliance. c. In future daily reports, include the volume of water discharged out of SW-2A and SW-2B individually rather than as the combined flow. Pursuant to Section 13304 of the Water Code, the Discharger is hereby notified that the Regional Board is entitled to, and may seek reimbursement for, all reasonable costs actually incurred by the Regional Board to investigate unauthoriezed discharges of wastes and to oversee cleanup of such waste, abatement of the effects thereof, or other remedial actions, required by the Order. Up receipt of a billing statement for such costs, the Discharger shall reimubrse the Regional Board. Pursuant to Section 13304 and 13350 of the Water Cose, if a Discharger fails to comply with the provisions of this Order, the Board may schedule a hearing to consider assessing civil monetary pernalties and to consider requesting the Attorney General to take appropriate enforcement action against the dischargers, including injunctive and civil monetary remedies. s/ Loretta K. Barsamian November 14, 1996 Executive Officer Date