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Kruger Foods / SMS Briners 2 <br /> San Joaquin County <br /> Item Kruger Foods / SMS Briners Comments Staff Response <br /> Strikethrough Text=Discharger Removed <br /> Italic Text=Discharger Added <br /> Finding 39 ...9 after reasonable a4empts, T#he No Change Made: <br /> Discharger shall demonstrates that the <br /> removal of all remaining contamination is The discharger has discussed retrofitting <br /> infeasible. If residual contamination does the surface impoundments to Title 27 <br /> not allow for clean closure, the surface standards. Without a submitted certified <br /> impoundment shall be closed as a landfill engineering design that complies with <br /> (see Item 30) Title 27, this can only be considered a <br /> proposed plan. Therefore, the closure and <br /> removal of the present surface <br /> impoundments and associated waste shall <br /> proceed towards "clean closure". <br /> Also, Section 21400(b)(1) of Title 27 <br /> states: "Unless the discharger <br /> demonstrates, and the RW CB finds, that <br /> it is infeasible to attempt clean-closure of <br /> the impoundment, then all residual <br /> wastes, including sludges, precipitates, <br /> settled solids, and liner materials <br /> contaminated by wastes, shall be <br /> completely removed from the <br /> impoundment and discharged to an <br /> approved Unit. Remaining containment <br /> features shall be inspected for <br /> contamination and, if not contaminated, <br /> can be dismantled. Any natural geologic <br /> materials beneath or adjacent to the closed <br /> impoundment that have been <br /> contaminated shall be removed for <br /> disposal at an appropriate Unit. ...." <br /> Task Remove any remaining liquid er selid No Change Made: The solid waste <br /> 2Ci wastes from the surface impoundments and currently lying on the bottom of the <br /> discharge appropriately. impoundment is a threat to water quality. <br /> Therefore, the solid waste must be <br /> removed by 31 August 2004, <br /> Task Install a staff gauge at the lowest elevat No Change Made: The schedule requires <br /> 2Cii in each impoundment... that all liquid and solid waste be removed <br /> by 31 August 2004. The discharger has <br /> been given 30 days to install the staff <br /> gauge after both solids and liquids have <br /> been removed. <br /> Task Begin the physical removal of the surface Change Made: Staff will change the <br /> 2Civ impoundments 44-z4p64-2�2 June 2005. compliance date. The discharger should <br /> be aware that the physical removal of the <br /> impoundments may begin before 2 June <br /> 2005. <br />