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Linda S. Adams Acting Secretary for ivironmental Protection 13 April 2011 California - -1gional Water Quality Cr trol Board Central Valley Region Katherine Hart, Chair 11020 Sun Center Drive, #200, Rancho Cordova, California 95670-6114 (916) 464-3291 • FAX (916) 464-4645 http://www.waterboards. ca.gov/centraIvalley Jesse Solorio, P.E. Senior Engineer Lawrence and Associates 3590 Iron Court Shasta Lake, CA 96019 Edmund G. Brown Jr. Governor RECEIVED APR 15 2011 ENVIRONMENTAL HEALTH PERMIT/SERVICES REVIEW OF WORK PLAN FOR SLUDGE IMPOUNDMENT CLOSURE, DIAMOND PET FOOD PLANT, RIPON, SAN JOAQUIN COUNTY The Central Valley Water Board staff has reviewed the Work Plan for Sludge Impoundment Closure at the Diamond Pet Food Plant. The sludge impoundment is one of two impoundments utilized by the former paper mill owner, Neenah Paper, to dispose of inert sludge generated from the paper making process. Previously, the former owners closed the first of two sludge ponds by leaving in place the inert sludge and covering with a minimum of one foot thick vegetative soil cover graded to drain. This method of closure is described in Waste Discharge Requirement (WDRs) Order 5-01-148. The Discharger proposes to close the second sludge pond in a similar fashion utilizing soil from the western berm as final cover, graded to drain toward the west allowing storm water to runoff into the West Percolation Field. Post closure maintenance will include frequent inspections of the closed pond. The work plan proposes to conduct inspections of the final cover following each significant storm event during the first two winters. Repairs will be performed either during the wet season or prior to 15 October each year, depending on the severity of the erosion to the final cover. During closure construction of the sludge pond, the Discharger proposes to destroy well OB -9 due to its proximity to the western berm. Monitoring wells OB -12 and OB -18 provide detection monitoring of groundwater quality in the vicinity of well OB -9 and staff concurs with the destruction of this well prior to construction of the final cover. The Discharger must permit and destroy the well per the San Joaquin County Environmental Health Department guidelines and the Department of Water Resources Well Standards. Due to the nature of the material discharged to the pond, it is not subject to regulations in California Code of Regulations (CCR) Title 27 as discussed in Finding No. 24 of WDRs Order 5-01-148. Staff concurs with the closure plan as described in the 28 December 2010 work plan. The Final Construction As -built Report shall be submitted by 30 September 2011. This report must incorporate all construction quality assurance (CQA) inspections and monitoring well California Environmental Protection Agency ZaRecycled Paper