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SMS Briners -2- <br /> In the vicinity of the older wooden tanks there appeared to be more of a threat to <br /> groundwater contamination from salt spillage. A salt crust was present on the exterior <br /> of the tanks, and a salty-looking sheen was visible on the surface of the dirt roadway. <br /> At the time of our inspection, one wooden tank was being overfilled and was spilling <br /> onto the roadway. Even though the liquid was reported to be clean rinsewater, it <br /> should have been discharged to the ponds. <br /> The two surface impoundments at the facility have not yet been upgraded to comply with <br /> Subchapter 15 regulations. The discharger is investigating the possibilities of <br /> providing above-ground containment of wastewaters so they may close the impoundments <br /> in lieu of retrofiting. Ground water contamination has been verified in the vicinity <br /> of the impoundments, making resolution of the wastewater disposal issue a necessity <br /> in the near future. <br /> INSPECTION SUMMARY: <br /> At the time of my inspection, the discharger was in violation of Discharge <br /> Specification 3, which states, "The discharge shall remain within the designated <br /> disposal area at all times. " <br /> The discharger should also provide a time schedule for closing or retrofitting the <br /> surface impoundments in conformance with Subchapter 15, a technical report on the <br /> groundwater investigation work completed to date, and a workplan proposing additional <br /> work to define the extent of contamination. <br /> Area ngineer <br />