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California Rc,,Ional Water Quality ( ,,,ntrol Board - <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwaaeneggcr <br /> Secretaryfor <br /> Environmental Sacramento Main Office Governor <br /> Protection Internet Address:httpd/www.swrcb.ca.gov/mgcb5 <br /> 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 •Fax (916)464-4797 <br /> REUM M ULD <br /> 18 December 2003 DEC 2 2 2003 <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Mike Lescisin <br /> Diamond Walnut Growers Inc. <br /> 1050 South Diamond Street <br /> Stockton, California 95201 <br /> WORK PLAN FOR BENCH SCALE TREATABILITY STUDY,DIAMOND WALNUT <br /> GROWERS, STOCKTON PLANT, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board)have <br /> reviewed the 29 October 2003 Third Quarter 2003 Monitoring Report(QMR) and the <br /> 31 October 2003 Workplan for a Bench Scale Treatability Study for Reducing Hexavalent <br /> Chromium (Work Plan) submitted by ATC Associates Inc. (ATC) on behalf of Diamond Walnut <br /> Growers Inc. (DWG) for its Stockton Plant. The QMR reported that monitoring well MW-3 <br /> contained 3,600 µg/1 of hexavalent chromium and 4,600 µg/l of total chromium during the third <br /> quarter sampling event conducted on 17 July 2003. The goal of the Work Plan is to "evaluate the <br /> potential of ferrous iron solution and calcium polysulfide to reduce and stabilize Cr VI via <br /> injection into the subsurface." The Work Plan is consistent with the stated goals but some detail <br /> is missing. Thus,we have the following comments about the Work Plan. <br /> 1. DWG was previously notified that the reinjection of treated water or injection of a reducing <br /> agent into the subsurface requires Waste Discharge Requirements (WDRs). The process to <br /> obtain WDRs begins with submitting a Report of Waste Discharge (RWD), which requires <br /> complete waste characterization information. Enclosed is a RWD Form 200 for your <br /> review; it is also available on the World Wide Web at <br /> http://www.swrcb.ca.gov/rwgcb5/business help/permit3.htm1. There are currently <br /> insufficient characterization data for us to prepare appropriate WDRs, but you can use the <br /> opportunity of the upcoming treatability study to gather the missing data. In particular, the <br /> WDRs will require that DWG monitor downgradient of the injection point for degradation <br /> products and byproducts of the reduction reactions. Characterization data are needed to <br /> establish baseline constituent concentrations in all the monitoring wells. <br /> The Work Plan does not provide for baseline analysis and characterization. Baseline <br /> analyses for soil and groundwater samples should at a minimum include total and <br /> hexavalent chromium, alkalinity, ammonium/ammonia, arsenic, total organic carbon, <br /> copper, dissolved and total iron, dissolved and total manganese,methane, nitrate, dissolved <br /> California Environmental Protection Agency <br /> ea Recycled Paper <br />