HomeMy WebLinkAbout01-09-2016 Item 8, BrownCOUNCIL MEETING: _6 1 /tat 2 01
ITEM NO_:
To: Maier, John Paul REECEIVED
Subject: RE: Item 8, current agenda
1 �9 2016
From: Wendy Brown FJAN
CITY CLERK
Sent: Saturday, January 16, 2016 6:58 PM
To: E -mail Council Website
Subject: Item 8, current agenda
To the Mayor and Council,
Attached are a letter and report concerning Item 8 on your current agenda. We will also be present at your meeting on
Tuesday.
Regards,
Wendy Brown, Treasurer
Central Coast Grown
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CENTRAL
COAST
GROWN
Mayor and Council Members January 16, 2016
City of San Luis Obispo
By email
Re: Item 8, January 19, 2016 Agenda
Dear Mayor and Council Members,
Please do not approve this item right now. There are several issues that it would be prudent for you to consider first.
1. If the water is still contaminated with PCE and nitrates, unless ARH Quiky Investments, 1,11", is going to cap the
well and promise never to use it, the use of that water exposes their employees and customers to contaminants, and
allows the waste water to enter either our water treatment system or the groundwater on site. The state of
contamination will not be known until the water is tested.
2, Given the possibility that the groundwater in the whole area is contaminated, other wells nearby need to be
tested. Please see attached report from the California Regional Water Quality Control Board, discussing PCE
contamination as of 2005. There may be newer reports.
3. If the new owners plan to pump the water and it is not contaminated, the City is jeopardizing the water table
serving the Calle Joaquin Agricultural Preserve, which includes City Farm. This is giving away a precious public
resource, which will become even more essential in years to come, to a private party. One of our new tenants on
City Farm is there because wells near his previous location drew down the water table. We don't want to allow that
to happen at City Farm. In our comments regarding the San Luis Ranch EIR, we requested that well levels near the
site be tested before construction, and annually in September thereafter, with mitigation measures required for all
users if the water level dropped significantly. Unregulated use of the well under discussion would jeopardize all
other users of the local groundwater.
4. Back in the years when the City pumped water from the same aquifer that supplies this well, the water table
dropped so seriously as to cause ground subsidence. This caused damage to buildings in the Auto Park area, and
serious monetary damages to the City. No one wants a repeat of those unfortunate circumstances, no matter who is
financially responsible.
Water is crucial for all of us. How we manage that resource is of utmost importance. Please take the time to
investigate all aspects of this issue.
Thank you for your careful attention.
Wendy Brown, Board Member
Central Coast Grown
cc: Bob Hill: hill, Robert <rhill @slocity.org>
Carrie Mattingly <cmattingly @slocity.org>
CENTRAL COAST GROWN • P.O. Box 3736 San Luis Obispo, CA 93403 • 805.769, 8344 • centre1coast9r0wn.0rg
STATE OF CALIFORNIA
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
CENTRAL COAST REGION
STAFF REPORT FOR REGULAR MEETING OF DECEMBER 1-2,2005
Prepared on November 2, 2005
ITEM NUMBER: 24
SUBJECT: Madonna Plaza Shopping Center, San Luis Obispo County; Waiver of
Waste Discharge Requirements for Chemical Oxidation Injection of
Potassium Permanganate, [KMnO4]
SUMMARY:
Project Area:
Treatment Method:
Volume of Discharge:
Groundwater Contaminant:
Responsible Parties:
Existing Orders:
DISCUSSION
0.20 acres
Chemical Oxidation with Potassium Permanganate (KMn04)
45,000 gallons KMn04
Tetrachloroethylene (PCE)
MRP Institutional Associates and Mr. Charles Pasquini, Jr
Monitoring and Reporting Program Order No. R3- 2005 -0028
From 1969 to 1988, Sparkle Dry Cleaners and
three others operated dry cleaning businesses in
Building F, Suite 1010 at the Madonna Plaza
Shopping Center, located at 227 Madonna Road in
San Luis Obispo (see Location map, Attachment
1). Since at least 1969, Mr. Charles Pasquini, Jr.,
has owned the property in fee. In 1989, MRP
Institutional Associates acquired the ground lease.
Prior to the retail center demolition and subsequent
renovation in 2002, the responsible parties
performed a site investigation and discovered that
the dry cleaning solvent tetrachloroethylene (PCE)
had been discharged to soil and groundwater from
past business operations.
In 2001, the City of San Luis Obispo Fire
Department and Water Board required the
responsible parties to further investigate PCE in
soil and groundwater at the subject property.
During the 2002 investigation, 36 direct push
borings, 11 hand auger borings, and 11
groundwater monitoring wells were installed. One
deep soil boring (1313-1) was drilled near the PCE
source area to determine if the PCE release from
the property co- mingled with the South San Luis
Obispo (SLO) PCE' groundwater plume. The
South SLO PCE plume, discovered by the Water
Board during its mid- 1980's Well Investigation
Program, is thought to originate at one or more dry
cleaning facilities located near the intersections of
Archer and Carmel Streets with Higuera Street, in
downtown San Luis Obispo. The South SLO PCE
plume, with concentrations up to 250 milligrams
per liter (ppb), encompasses an area approximately
two miles long and one mile wide along the length
of the San Luis Obispo Creek valley (Attachment
2). The responsible parties collected soil samples
from DB -1 and analyzed samples at 27 feet below
ground surface (bgs), 32 feet bgs, 46 bgs, and 52
feet bgs. Saturated soil sample data suggests a
separation of PCE impacts between the shallow
(27 feet bgs) and deeper (52 ft bgs) zones.
In 2002, approximately 4,500 cubic yards of soil
were excavated from beneath the former dry
cleaner building. From 2002 to 2005, the
responsible parties have conducted quarterly
groundwater sampling. In 2005, the Executive
.Officer reduced the groundwater sampling
frequency from quarterly to semiannually.
Item No. 24
During the February 2005 groundwater sampling
event, the depth to groundwater at the property
was approximately ten to thirteen feet bgs, which
corresponds with a groundwater elevation of about
131 to 123 feet above mean sea level. The
groundwater flow direction is estimated to be from
the north to the south at 0.0008 feet per foot. On
February 23, 2005, PCE was detected in MW -2R
at 24.2 ppb, as shown on Attachment 4.
Historically, the highest concentration of PCE was
detected in well MW -2R at 56 ppb during the
August 27, 2003 groundwater sampling event. For
comparison, the Water Board's Water Quality
Control Plan (Basin Plan) objective for PCE is 5
ppb in groundwater. Other PCE breakdown
products have not been detected at the property.
On July 18, 2005, Water Board staff received the
"Work Plan for Groundwater Treatment" (Work
Plan) prepared by QORE Property Sciences
(QORE). Permanganate reagent will be applied
via a number of injection wells to target residual
PCE in vadose and saturated soils and in
groundwater. The Work Plan proposes a grid of
injection points to deliver 45,000 gallons of
potassium permanganate to the vadose and
saturated zone in the treatment areas. In the
former excavation area (Area 1), QORE will inject
3,000 gallons of potassium permanganate between
15 and 25 feet bgs, in a 15 -foot square grid pattern
(30 points) as shown on Attachment 5. In Area 2,
the area where PCE concentrations in soil are
estimated to be above 100 ppb, QORE will inject
30,000 gallons of potassium permanganate from
the surface to 25 feet bgs via 170 points installed
on a 12 -foot square grid pattern as shown on
Attachment 6. In Area 3, the remaining area with
PCE groundwater impacts, QORE will inject
12,000 gallons of potassium permanganate from
ten to 25 feet bgs via 90 injection points installed
on a rectangular grid as shown on Attachment 7.
After the injection or infiltration begins,
chlorinated solvents will be mineralized into
manganese dioxide and other soluble ion salts
(potassium, sodium, chloride) and carbon dioxide
by means of oxidation chemical reactions. The
oxidation destroys the organic double bonds of the
chlorinated ethene compounds, reducing them
ultimately to oxygen and carbon dioxide.
Implementation of the Work Plan will expedite soil
and groundwater cleanup at the property.
- 2 - December 1 -2, 2005
Although the chemical oxidation reactions are
swift, the treatment typically requires a few months
due to advection and dissolution transport and
desorption. For these reasons, the sodium
permanganate treatment is expected to mineralize
most of the soil and groundwater contamination
within six months. In the event that the chemical
oxidation reaction stalls and the chlorinated
solvents do not completely break down, the
Dischargers may reapply and monitor the injection
of potassium permanganate in the treatment area
with Executive Officer pre - approval.
Because the injection of sodium permanganate into
the vadose zone and groundwater table is
considered a "discharge ", regulation by the Water
Board is necessary. Water Board staff recommend
a waiver of waste discharge requirements because
the proposed project is in the public interest, and
the project, when conducted in conformance with
the proposed conditions of this waiver, will not
pose a significant threat to water quality. The
proposed Conditional Waiver of Waste Discharge
Requirements, Order No. R3- 2005 -00140 is
included as Attachment 8.
Water Board staff has developed a monitoring and
reporting program to evaluate the effectiveness of
the injection, chlorinated solvent breakdown, and
subsequent impact of the manganese dioxide and
soluble salt injection. Initially, the potassium
permanganate concentrations will be high and the
solution is expected to be above the drinking water
standards for manganese and chlorine (50 ppb and
4,000 ppb, respectively). However, during the
chemical oxidation process, the chlorinated
solvents, manganese, chlorine and sodium will
break down rapidly in the shallow aquifer over the
treatment area and local groundwater quality will
improve and no longer be degraded by chlorinated
solvents. The nearest active irrigation well is
located approximately 4,200 feet north of the
subject property. Two city of San Luis Obispo
municipal wells are located 5,000 -feet south -
southwest of the property. The proposed injection
is not expected to impact private or city drinking
water supplies.
Water Board staff prepared Monitoring and
Reporting Program (MRP) No. R3- 2005 -00141
(Attachment 8). MRP R3- 2005 -00141 will replace
existing Monitoring and Reporting Program No.
2005 -R3 -0058, which required semiannual
Item No. 24 -3- December 1 -2, 2005
groundwater monitoring. After the potassium
permanganate injection is complete, all
groundwater monitoring wells will be monitored
monthly for the presence of potassium
permanganate, its breakdown products (sodium,
potassium, manganese oxide, chlorine) and other
general chemistry parameters (such as pH,
temperature, oxygen reduction potential (ORP),
etc.). Because potassium permanganate is a purple
in color, the colorimetric technique is expected to
be an effective field monitoring method. In
addition, MRP No. R3- 2005 -00141 requires
ongoing quarterly groundwater monitoring for
chlorinated volatile organic compounds, metals,
and general mineral analysis.
Three and six months following treatment, QORE
will evaluate the effectiveness of the potassium
permanganate injection and include this
information as part of its quarterly groundwater
monitoring report for the property.
In addition, a health and safety plan will be
required to be submitted to the City of San Luis
Obispo Fire Department and San Luis Obispo
County Environmental Health prior to work plan
implementation to ensure human health protection.
In addition, Water Board staff will require the
discharger to install two deeper screened (greater
than 25 feet bgs) groundwater monitoring wells to
monitor the effects of the discharge on the
intermediate groundwater zone. In addition, prior
to implementing the Work Plan, the discharger is
required to obtain groundwater
monitoring/injection well permits through the
County of San Luis Obispo and any other local
agency permits.
COMPLIANCE HISTORY
Over the 4 -year period of Water Board staff
regulatory oversight, the responsible parties have
complied with all Water Board directives issued to
date.
PUBLIC NOTICE
Prior to implementing this corrective action (Work
Plan) at the Property, Water Board staff prepared
the attached public hearing notice (Attachment 9).
RECOMMENDATION
Adopt Order No. R3- 2005 -00140 as proposed.
ATTACHMENTS
1. Site Location Map
2. South SLO PCE groundwater plume
3. Analytes Detected in Groundwater (2/23/05)
4. Proposed Injection Map — Area 1
5. Proposed Injection Map — Area 2
6. Proposed Injection Map — Area 3
7. Proposed Order No. 113- 2005 -00140
8. Proposed Monitoring & Reporting Program
R3- 2005 -00141
9. Public Notice (without Attachments)
SAShared\SLICRegulated Sites\San Luis Obispo Co\San Luis
ObispoNadonna Plaza\Board ItemNadonna PlazaWaiver Staff
Report.doc