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California I ;ional Water Quality Cont I.., Board <br /> (\- v Central Valley Region j <br /> vRobert Schneider,Chair <br /> Linda S.AdamsArnold <br /> Secretaryjor Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Protection Phone(916)464-3291 •FAx(916)4644645 <br /> http://www.waterbouds.ca.gov/cenualvallcy <br /> 8 September 2006 RECEl VEDD <br /> .SFP 1 1 2 C16 <br /> Mr. Eric Kruger Mr. Robert Chelli ENV1RpS Briners' /yrkjEl/1 <br /> Kruger Foods <br /> Highway 4 17750 East Highway 4 PERr4ITZSERV�ESTH <br /> Stockton, California 95215 Stockton, California 95215 <br /> REVIEW GROUNDWATER CORRECTIVE ACTION MEASURES, SMS BR/NERS, INC. <br /> KRUGER FOODS, INC. SAN JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (hereinfter <br /> Regional Water Board) has completed its review of the 14 February 2006 Groundwater <br /> Corrective Action Measures Report. This report describes the proposed groundwater <br /> treatment system to remediate the chloride and total dissolved solids plume. Below are <br /> several concerns we have with the report: <br /> • The Discharger stated in their 2005 Annual Groundwater monitoring report that <br /> "Chloride concentrations in MW4A exhibited an increasing trend from about 150 mg/L in <br /> 1992 to 470 mg/L in 2002. Concentrations dropped somewhat to 370 mg/L in October <br /> 2003. In 2004, concentrations ranged from 540 mg/L in April to 290 mg/L in October, <br /> and increased to 670 mg/L in December 2005." Waste Discharge Requirements Order <br /> No. R5-2004-0157 established the water quality protection standard for chloride in the <br /> shallow aquifer at 600 mg/I. In the Groundwater Corrective Action Measures Report, <br /> none of the model scenarios show evidence that the groundwater quality around MW4A <br /> will be improved. Therefore, the groundwater treatment system must be modified to <br /> address the water quality surrounding MW4A. <br /> • The Discharger's recommended corrective action is pumping well MW1R at a rate not <br /> exceeding 2 gpm for an estimated 20-year period. The extracted water would be <br /> discharged to an existing on-site deep well that has an USEPA Class I permit. While <br /> the model indicates that MW1R is in a good location for an extraction well, the <br /> Discharger must select a pumping rate that can be supported by physical data. The <br /> extraction system's radius of influence must be measurable (0.01 ft) at the boundary of <br /> the chloride plume throughout the entire time that corrective action measures are <br /> necessary. Therefore, the plan must be amended to address how this data will be <br /> monitored, evaluated and reported. <br /> • Please provide a revised Groundwater Corrective Action Measures Report by <br /> 1 November 2006 that incorporates the above comments. <br /> California Environmental Protection Agency <br /> Qa Recycled Paper <br />