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TENTATIVE WASTE DISCHARGE REQUIREMENTS ORDEeNO._ -6- WASTE DISCHARGE REQUIREMENTS FOR CLOSURE, POST CLOSURE AND CORRECTIVE ACTION OF SURFACE IMPOUNDMENTS AT KRUGER FOODS, INC -SMS BRINERS VEGETABLE BRINING FACILITY SAN JOAQUIN COUNTY area. The downgradient points of compliance would change due to this seasonal variability or pumping. Therefore, compliance point monitoring wells would be required in several locations around the pond. This does not exist at the present time. 28. The Discharger has no detection-monitoring program for the unsaturated zone beneath the surface impoundments. However, soil samples collected from beneath the south pond show that overlying impoundment brine seepage has migrated to the water table. Evaluation Monitoring Program 29. The evaluation-monitoring network is inadequate because the lateral and vertical extent of the chloride plume has not been defined. Isoconcentration contours derived from monitoring data show only an estimated extent of the chloride-contaminated groundwater. Section 20425(b)of Title 27 states: the Discharger shall collect and analyze all data necessary to assess the nature and extent of the release from the Unit. This assessment shall include a determination of the spatial distribution and concentration of each COC throughout the zone affected by the release. Corrective Action Monitoring Program 30. On 26 January 1990, SMS Briners agreed to source removal and groundwater cleanup by extracting groundwater. Currently,the Discharger is extracting groundwater from the monitoring well MW 1. This well is adjacent to the western levee of the surface impoundments. Historical groundwater elevation data indicates that the extraction well flow rate has little or no influence on capturing the plume of chloride contaminated groundwater. Section 20430(d) of Title 27 states: In conjunction with the corrective action measures, the Discharger shall establish and implement a water quality monitoring program to demonstrate the effectiveness of the corrective action program. Groundwater Degradation 31. Groundwater monitoring has occurred at this facility since 1987. The waste stream generated by SMS Briners is high in sodium chloride;therefore, chloride because of its mobility has served as a useful indicator for evaluating impacts of plant operations on groundwater quality. The following monitoring wells have elevated levels of chloride: MW 1, MW2 (background), MW3A, MW3B, MW4A, and MW4B. On 7 January 2003,monitoring well MWl had chloride detected at 4,100 mg/l,which is the highest detected historically amongst all monitoring wells. Seasonal fluctuations in chloride concentrations exceed at times 2000 mg/1,with the highest readings occurring in winter. During the same monitoring event, MWl had Total dissolved solids detected at 10,000 mg/l.