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+ SEP 05 '89 1342 LUHDORFF`�,C_ALMRNINI WOODLHND -- P.S;10 <br /> i V <br /> T <br /> 1 <br /> L INTRODUCTION <br /> S.M.S Briners, as part of its vegetable pickling operation in eastern San Joaquin County <br /> (Figure 1), produces a brine waste which contains primarily sodium chloride and some <br /> vegetable matter. Historically and at present, the brine waste is disposed via evaporation <br /> from two shallow, lined ponds (Figure 2); in addition, all storm runoff from the plant <br /> site is also directed into the evaporation ponds where it represents the majority of water <br /> evaporated annually, <br /> In 1983, for operational reasons, SMS Briners first began to investigate alternatives for <br /> waste brine disposal. It was decided, at that time, to seek permits for, and ultimately <br /> construct and operate an underground injection well, thus allowing closure of the <br /> existing evaporation ponds. To comply with the Underground Injection Control (UTC) <br /> Provisions of the Resource Conservation and Recovery Act, a UIC permit application <br /> was submitted to the U.S. Environmental Protection Agency (EPA) in July, 1984. For <br /> the subsequent two and one-half years, numerous meetings, correspondence, and <br /> telephone conversations took place between the EPA and Luhdorff and Scalmanini, <br /> Consulting Engineers (LSCE), the consultants who had prepared the permit application <br /> on behalf of the Briners. In March, 1987, the EPA informed LSCE that the permit <br /> application would probably be denied without the availability of test bole drilling and <br /> logging data on-site to confirm the data, included in the application, which had been <br /> correlated and extrapolated from nearby oil and gas borings. EPA staff recommended <br /> that SMS Briners withdraw its permit application and construct the test hole, which <br /> would not require a permit from EPA. The Briners could then resubmit its UIC <br /> application, with confirming test hole data; and it would be treated "without prejudice" <br /> from the previous review. It remains unclear why two and one-half years were required <br /> to conclude that test hole data, not requiring a permit, was necessary for processing of <br /> the permit application. <br />