SITE INFORMATION AND CORRESPONDENCE

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Daby Humbert -2 - 16 April 2013 Zacky & Sons Poultry, LLC • Because the wastewater pond has been in use since 1973 and the liner is reportedly nearly 20 years old, continued use of the pond has the potential to degrade groundwater quality. Specifications of the existing pond liner and/or documentation of pond liner testing results are required as part of the RWD to demonstrate liner integrity. • Baseline groundwater information is necessary to characterize current groundwater conditions. We understand that the facility is located within an industrial area where groundwater degradation may have occurred from other off-site sources, and these factors are always a consideration in any groundwater assessment. General requirements for groundwater assessment activities are included as an attachment to this letter. • The April 2008 Baseline Groundwater Study Workplan proposes the installation and sampling of three shallow groundwater monitoring wells to determine the baseline groundwater quality and site gradient around the on-site aeration pond. The workplan addresses the comments in our 22 August 2007 letter, and is hereby approved. Table 1 of the attached checklist provides a list of required parameters for groundwater analysis to provide a profile of groundwater conditions. Results of two quarterly groundwater monitoring events, including a Monitoring Well Installation Report that contains well installation and construction details, must be included as part of the RWD. The installation of all monitoring wells shall conform to permitting requirements of the San Joaquin County Environmental Health Department. • Please be advised that the proposed monitoring well network may be sufficient for conducting a baseline groundwater assessment, but additional wells may be needed to better characterize groundwater conditions once groundwater conditions and gradient direction are confirmed. If so, the WDRs may include a requirement for the submittal of a workplan for additional groundwater monitoring wells. • State Water Resources Control Board Resolution 68-16 ("Policy with Respect to Maintaining High Quality Waters of the State") (hereafter Resolution 68-16) prohibits degradation of high-quality groundwater unless it has been shown that: a. The degradation is consistent with the maximum benefit to the people of the state. b. The degradation will not unreasonably affect present and anticipated future beneficial uses. c. The degradation does not result in water quality less than that prescribed in state and regional policies, including violation of one or more water quality objectives, and d. The discharger employs best practicable treatment or control (BPTC) to minimize degradation. The threat and complexity of this facility is profiled as 2B, as defined by the nature of facility operations and potential impact to groundwater. The 2008 RWD was submitted with a filing fee for the preparation of WDRs for the facility. Because review of the RWD has been delayed, you are not required to submit an additional filing fee. However, there are annual permit fees for WDRs once they are adopted.