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w © LUHOORFF &SCALMANINI GROUND-WATER RESOURCES ` C O N S U L T I N G E N G I N E E R S H• nv-uu-..•D -- " •M-�-"^�` March 25,2005 File No. 00-7-033 Mr.Victor Izzo Central Valley Regional Water Quality Control Board 11020 Sun Center Drive,#200 Rancho Cordova, CA 95670-6114 SUBJECT: SMS BRINERS,SAN JOAQUIN COUNTY GROUNDWATER CORRECTIVE ACTION MEASURES Dear Mr. Izzo: In accordance with the Waste Discharge Requirements for SMS Briners (WDR R5-2004-0157), enclosed are the amended Report of Waste Discharge form and the report titled Groundwater Corrective Action Measures. The amended Report of Waste Discharge was specified in the above-noted WDRs. The enclosed form updates the 2004 RWD submitted for SMS Briners. The enclosed report, which accompanies the amended RWD, describes the planned groundwater corrective action measures that will be conducted at the SMS Briners' site. The RWD reflects changes that have occurred to the disposition of non-potable waters at the facility, including process water,wastewater, and stormwater. As of October 2004, and in accordance with the WDRs,no waters, except for direct precipitation falling into the ponds,have been discharged to the ponds. The WDRs require submittal of pond closure documentation by October 31, 2005. The Final Closure Plan, SMS Briners Facility Evaporation Ponds has been submitted to the Regional Board(Golder February, 2005), and closure actions are planned to proceed,pending Board approval of the Plan,to accomplish closure in accordance with the WDRs. The Groundwater Corrective Action Measures report describes the activities planned to be conducted to restore groundwater to the Water Quality Protection Standards established for this site. These activities include: • completion of the CPT investigation; • preliminary capture zone simulation and analysis based on estimated shallow zone aquifer characteristics; • installation of a test well(i.e.,planned extraction well) and aquifer testing to assess shallow zone aquifer characteristics; • preparation of a supplemental report that will include an update of the capture zone analysis based on the additional site characterization data, a description of water demands and planned use of the extracted groundwater by Kruger Foods and SMS Briners, a discussion of facilities for extracted groundwater storage and other pertinent facilities for the groundwater remediation program; and • implementation of the corrective action monitoring program in coordination with the existing evaluation monitoring program. 500 First Street Woodland, CA 95695-4026 • 530.SS1 .0109 • Fax 530.661 .6BO6