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TENTATIVE WASTE DIS6eARGE REQUIREMENTS ORDER Nbe—, -5- <br /> KRUGER FOODS/ SMS BRINERS <br /> VEGETABLE BRINING FACILITY <br /> CLASS II SURFACE IMPOUNDMENT CLOSURE <br /> SAN JOAQUINCOUNTY <br /> Evaluation Monitoring Program <br /> 27. The evaluation-monitoring network is inadequate because the lateral and vertical extent of <br /> the chloride plume has not been defined. Isoconcentration contours derived from monitoring <br /> data show only an estimated extent of the chloride-contaminated groundwater. Section <br /> 20425(b) of Title 27 states: the discharger shall collect and analyze all data necessary to <br /> assess the nature and extent of the release from the Unit. This assessment shall include a <br /> determination of the spatial distribution and concentration of each COC throughout the zone <br /> affected by the release. <br /> Corrective Action Monitoring Program <br /> 28. The Discharger is extracting groundwater from the monitoring well MW 1. This well is <br /> adjacent to the western levee of the surface impoundments. Historical groundwater elevation <br /> data indicates that the well extraction flow rate has little or no influence on capturing the <br /> plume of chloride contaminated groundwater. Section 20430(d) of Title 27 states: In <br /> conjunction with the corrective action measures, the discharger shall establish and implement <br /> a water quality monitoring program to demonstrate the effectiveness of the corrective action <br /> program. <br /> Groundwater Degradation <br /> 29. Groundwater monitoring has occurred at this facility since 1987. The waste stream generated <br /> by SMS Briners is high in sodium chloride; therefore, chloride because of its mobility has <br /> served as a useful indicator for evaluating impacts of plant operations on groundwater <br /> quality. The following monitoring wells have elevated levels of chloride: MW 1,MW2 <br /> (background), MW3A, MW3B,MW4A, MW4B,D and E, and production wells A, P4 and <br /> P5. On 7 January 2003,monitoring well MW 1 had chloride detected at 4200 mg/1,which is <br /> the highest detected historically amongst all monitoring wells. Seasonal fluctuations in <br /> chloride concentrations exceed as much as 2000 mg/l,with the highest readings occurring in <br /> winter. <br />