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SMS Briner/Kruger Foods - 2 - 19 April 2005 <br /> Option A, based on the information provide, appears to be technically infeasible based on the depth of <br /> pollution below the ponds and Option B does not comply with Title 27 without a Title 27 cover. Option <br /> C appears to be the only viable closure per the regulations, if the cover is constructed to meet Title 27 <br /> performance standards. Option C proposed cover uses clay and under Central Valley weather conditions <br /> may have problems meeting the performance standards of closure under Title 27 Section 21090 because <br /> of desiccation cracks. Therefore, the discharger should submit an engineered alternative per Title 27 <br /> Section 20080(b) or a plan "for protecting the low-hydraulic-conductivity layer from foreseeable sources <br /> of damage that could impair its ability to prevent the through flow of water..." <br /> Waste Discharge Requirements Order No. R5-2004-0157 requires closure of the surface impoundments <br /> to be completed by 31 October 2005; therefore the Discharger must resubmit the closure plan that <br /> complies with Title 27 no later than 31 May 2005. Staff looks forward to working with SMS Briners on <br /> the closu/r'e, of the surface impoundments. If you have any questions,please call the at (916) 464-4679. <br /> HOWARD HOLD <br /> Associate Engineering Geologist <br /> San Joaquin River Watershed <br /> cc. San Joaquin County Environmental Health Department <br /> Ms. Maureen Mathius, Golder Associates, Roseville <br />