PORT OF OAKLAND MEMO
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:
General
_______
- 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