COMPLIANCE INFO_FILE 1 - Laserfiche WebLink

Home Browse Search

MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: William J. Marshall , Chief FROM: Robert A. Evans Waste Discharge to Land Unit DATE: 11 December 1991 SIGNATURE: SUBJECT: VICTOR VICTOR FINE FOODS - SAN JOAQUIN COUNTY Victor Fine Foods (VFF) submitted Closure Plans for the closure of an unlined, unclassified surface impoundment (Pond 2) and a Class II surface impoundment (Pond 1) . I have reviewed the closure plans and two technical reports, dated 1 June 1989 and 20 November 1989. These technical reports were prepared by Nolte Associates to address the closure of Pond 2. Below are comments regarding the Closure Plans and related technical reports for both ponds: POND 2: I reviewed the 28 October 1991 Victor Fine Foods (VFF) Pond 2 Closure Plan to determine its compliance with Title 23, California Code of Regulations, Division 3, Chapter 15 (Chapter 15) , especially Section 2510, 2582, or 2593. In general the Closure Plan does not comply with the requirements of Sections 2510 (Applicability) , 2582 (Surface Impoundment Closure Requirements) , and 2593 (Mandatory Closure) . The Closure Plan does not propose clean closure or closure-in-place per Section 2582. To do so, the Closure Plan would have to propose either removal of all salt- laden soils or closure of Pond 2 as a landfill with a final cap. Since the Closure Plan does not propose either of these options, VFF's Closure Plan must demonstrate that the prescriptive standard is not feasible and provide an engineered alternative that is consistent with the performance goal of the relevant prescriptive standard and affords equivalent protection against water quality impairment. The Closure Plan proposes flushing the salts from the soils beneath the pond into the ground water below and capturing the salt and ground water via an extraction well system. VFF assumes that soil characteristics, salt leaching rates, aquifer characteristics, and capture effectiveness of the extraction well system will make soil flushing a favorable alternative. While Nolte intends to characterize the physical and chemical properties of the soil and water in the vadose zone, no technical or economic evidence has been presented to demonstrate the above assumptions are true or that a clean closure or closure-in-place is not feasible. Some of the deficiencies in the Closure Plan involve the capture effectiveness of the existing extraction well system and the proposed soil sampling. With respect to capture effectiveness, the design is based on 100% capture of the polluted ground water and an inadequate pump test conducted in 1987. Subsequent aquifer pump tests indicated that additional monitoring wells were necessary to determine the effectiveness of the existing extraction well system. The additional monitoring wells have never been installed and VFF has yet to determine the lateral extent of the ground water contamination plume or define the capture zone of the existing extraction well system. Furthermore, recent ground water monitoring data indicates