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STATE OFALIFORNIA GEORGE DEUKMEJIAN, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— .' <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO. CA 95827-3098 <br /> t ; <br /> MAY 2 9 199a <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> 24 May 1990 <br /> Mr. Arnold Souza <br /> S.M.S. Briners, Inc. <br /> 17750 East Highway 4 <br /> Stockton, CA 95202 <br /> SMS BRINERS, OPERATIONAL REVISIONS AND GROUND WATER MONITORING NEEDS, SAN JOAQUIN <br /> COUNTY <br /> Thank you for your consultant's February 1990 "Monitoring and Program Status <br /> Report and Work Plan for Source Control , Operational Revisions and Ongoing <br /> Monitoring" for your facility, and their March/April 1990 Progress Report. The <br /> attached memorandum contains staff comments regarding the February 1990 report <br /> which must be addressed. <br /> The reports are inadequate and failed to meet the major objectives: <br /> 1. To control high TDS sources by closing or upgrading the ponds to Subchapter <br /> 15 standards within a reasonable timeframe. We understand that your UIC <br /> permit application will take some time to be processed, but since the north <br /> pond will be required to meet Subchapter 15 standards regardless of the <br /> outcome of the UIC process, this source control work should be done sooner <br /> than 1992. <br /> 2. To provide a work plan and time schedule detailing how the extent of ground <br /> water pollution will be determined. Your reports fail to propose a ground <br /> water investigation. <br /> Your Report concludes that saline waters from the evaporation ponds has degraded <br /> the first aquifer and pumping induced vertical migration has impacted the lower <br /> portion of the aquifer. No actions are proposed to limit or otherwise mitigate <br /> this vertical spreading of pollution. SMS should consider providing interim <br /> ground water clean up measures. <br /> We require you provide to us by 19 June 1990: <br /> 1. A revised time schedule for closing or retrofitting the brine ponds to <br /> Subchapter 15 standards, <br />