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.1 MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routler Road Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8.495-5600 T0: Antonia Vorster FROM: Patricia Leary Senior Engineer Associate Engineer DATE: 8 December 1989 SIGNATURE: 6X SUBJECT: SMS BRINERS, SAN JOAQUIN COUNTY On 20 June 1989 the Regional Board sent a letter to SMS Briners Inc. (SMS), asking for an amended Report of Waste Discharge and verification monitoring plan by 1 August 1989. Luhdorff and Scalmanini (L&S) , crnsultants for SMS, submitted in response a report dated 25 October 1989. Their report responded to some of the staff comments, but was not adequate as a workplan for a verification monitoring program. This memorandum summarizes my review of this submittal , taking into account information previously submitted in an April 1989 report. VERIFICATION MONITORING PROGRAM SMS implemented an interim ground water monitoring network during May 1987, consisting of 7 existing agricultural production wells (P1 to P7) , 3 domestic wells (A,B, and C), and one monitoring well (M1) . The monitoring network was sufficient to determine that the two disposal ponds leaked brine wastes into ground water, making it necessary for SMS to implement a verification monitoring program. The network also showed that the ground water gradient shifted seasonally from NW to SE, depending on when wells P3, P4, and P5 were pumping. Our 20 June 1989 letter requested SMS revise their verification monitoring plan by 1 August 1989, by proposing wells in locations that would define the magnitude and extent of the plume. We also informed them that the agricultural and domestic wells were not adequate for verification monitoring. In September 1989, L&S constructed 3 additional monitoring wells at the facility, which were approved as part of SMS's original verification monitoring plan. Two wells, in a cluster (MW3A and MW3B) , were installed immediately south of the ponds, and were screened at different intervals to enable a determination of vertical gradients and to assess if deeper ground water was impacted. The third well (MW2) was located approximately 1100 feet NW of the ponds, to determine water quality at a distance downgradient of the ponds. The logs for these new wells should have been provided in the 25 October 1989 report. These new wells may provide some important information about ground water conditions at the site, but they are not be sufficient to verify if any contamination extends beyond the influence of the production wells. A pumping test to establish the groundwater flow rate during the season when production wells are not operating, could provide good information. SMS should provide a technical report with a detailed proposal on how they will define the extent of contamination. The 25 October 1989 letter indicated this workplan would be submitted by 15 November 1989. This workplan was requested in our 20 June 1989 letter and was due on 1 August 1989.