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LUHOORFF & SCALMANINI c,RC:jN.ZD-WATSR RESOURCES N S _, L T Z '_ E N G ( N = E R S - z August 27, 2004 Project No. 00-7-033 Mr. Howard Hold Central Valley Regional Water Quality Control Board 11020 Sun Center Drive, #200 Rancho Cordova,CA 95670-6114 SUBJECT: DETECTION/EVALUATION MONITORING NETWORK IMPROVEMENTS; REVISED WORK PLAN KRUGER FOODS, INC. - SMS BRINERS, STOCKTON, CA Dear Mr. Hold: The tentative revised Waste Discharge Requirements for Closure, Post Closure and Corrective Action of Sroface Impoundments at Kruger Foods, hrc. —SMS Brinets Vegetable Brining Facility, Scan Joaquin County (tentative order)dated July 15, 2004 identifies shortcomings in the current ground-water detection and evaluation monitoring network. Particularly, the Regional Water Quality Control Board (RWQCB) has specified that additional ground-water characterization occur to assess the zone affected by the release. This letter work plan replaces the August 16 letter. The revised work plan includes updated information and expanded discussions to respond to comments provided by the RWQCB that directly relate to the proposed work. The RWQCB comments addressed in this work plan include: t. Provide an explanation how the location, depth and proposed interval for MW5A will comply with Title 27, and how the extent of the plume will be defined. 2. Reevaluate the proposed casing materials and show centralizers. As noted above, in response to the first comment, Luhdorff and Scalmanini,Consulting Engineers (LSCE) has expanded the explanation for the placement of monitoring well MW5A. With regard to the second comment, LSCE has evaluated the adequacy of the planned casing material with respect to construction guidelines and also the suitability of the proposed material for the depth of the seals to be placed in the new monitoring wells. With regard to the centralizers, this item was not shown on the original plan, as the exact positioning is not known. The enclosed diagrams are schematic and show typical anticipated completions; casing centralizers have been added to the updated figures as requested. LSCE has prepared the following revised work plan that describes the proposed ground-water monitoring facilities to refine the understanding of the extent of ground-water quality impacts in the vicinity of the ponds. Originally, five monitoring wells at four locations were planned to accomplish these objectives. However, significant modifications have been necessary to the initially planned monitoring well locations. These modifications, as further described below, .nr..o F;ryt srx eec . Woodtan�l CA 95695-4026 . 530 661 01 09 . Fax 53OBBIBE306