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California Regional Water Quality (`ontrol Board Central Valley Region Robert Schneider, Chair Arnold r Dr.Alan Lloyd Secretaryfor Sacramento Main Office Schwarzenegger Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor Protection Phone(916)464.3291 •FAX(916)464-4775 http://www.waterboards.ca.gov/cmmlvalley 19 April 2005 � J Mr. Eric Kruger Mr. Robert Chelli APR 2 1 9005 Kruger Foods SMS Briners' ENVIRONMENT HEALTII 17750 East Highway 4 17750 East Highway 4 PERMIT/SERVICES Stockton, California 95215 Stockton, California 95215 REVIEW FINAL CLOSURE PLANSMS BRINERS FACILITYEVAPORATIONPONDS STOCKTON, SAN JOAQUIN COUNTY Regional Board staff has reviewed the Final Closure Plan SMS Briners Facility Evaporation Ponds Stockton, San Joaquin County, submitted on 3 February 2005 as a requirement of Waste Discharge Requirements Order No. R5-2004-0157. The discharger has presented three closure options for the ponds: ■ Option A—Excavating the residual wastes and impacted soils to 60 feet bgs,properly disposing of the excavated material,placing engineered fill in the resulting excavation to match existing grades, and re-grading the site to promote drainage (modified clean closure); Option B -Excavating the residual wastes and impacted soils to I o feet bgs,properly disposing of the excavated material,placing engineered f ll in the resulting excavation to match existing grades, and re-grading the site to promote drainage; and, ■ Option C— Consolidating near-surface impacted soils and residual waste in the bottom of the ponds,placing engineered fill providing a minimum hydraulic conductivity of I x 10-6 cm/sec over the consolidated material, grading the site to provide positive drainage, and effectively closing the ponds as a landfill. Section 21400 of California Code of Regulations Title 27 (Title 27) requires that the discharger attempt clean closure unless the discharger demonstrates, and the RWQCB finds, that it is infeasible to attempt clean-closure of the impoundment. The discharger has stated on Page 17 of the closure plan that: "the clean closure of the ponds is infeasible based on the construction efforts and cost estimates for the modified clean closure options (A and B) evaluated. The sheer volume of material to be excavated, hauled and properly disposed presents significant constructability, logistic, and environmental concerns, Therefore, the clean closure options are not recommended. We recommend that Option C be used for the final closure of the North and South Ponds.... " California Environmental Protection Agency V4 Recycled Paper The energy challenge lacing California is real. Every Cali t'ornian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at htip://www.swrcb.ca.guvirwgcb5