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October 6, 2004 <br /> File No. 00-7-033 <br /> Mr. Howard Hold <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive, #200 <br /> Rancho Cordova, CA 95670-6114 <br /> SUBJECT: REVISED CHARACTERIZATION OF LATERAL AND VERTICAL <br /> EXTENT OF CHLORIDE-IMPACTED GROUND WATER; REVISED <br /> WORK PLAN <br /> KRUGER FOODS,INC. - SMS BRINERS, STOCKTON, CA <br /> Dear Mr. Hold: <br /> The tentative revised Waste Discharge Requirements for Closure, Post Closure and Corrective <br /> Action of Surface Impoundments at Kruger Foods, Inc. —SMS Briners Vegetable Brining <br /> Facility, San Joaquin County(tentative order) dated July 15, 2004 identifies shortcomings in the <br /> current ground-water detection and evaluation monitoring network. Particularly, the Regional <br /> Water Quality Control Board (RWQCB) has specified that additional ground-water <br /> characterization occur to assess the zone affected by the release. This letter work plan replaces <br /> the August 16 and 27 letters and updates the September 20a'letter. The revised work plan <br /> includes a characterization of the lateral and vertical extent of chloride-impacted ground water <br /> through the use of a cone penetrometer tests (CPT) system. <br /> Luhdorff and Scalmanini, Consulting Engineers, (LSCE)has prepared the following revised <br /> work plan that describes the proposed investigation using CPT to refine the understanding of the <br /> extent of ground-water quality impacts in the vicinity of the ponds. Originally, five monitoring <br /> wells at four locations were planned to accomplish these objectives. However, significant <br /> modifications have been necessary to the initially planned monitoring well locations. These <br /> modifications were necessary because the property owner(the owner of the property south of <br /> Littlejohn Creek and adjacent to the western border of SMS Briners, Arnold Sousa, had <br /> indicated opposition when an inquiry was made to him concerning well installation on his <br /> property). <br /> CPT Methodology <br /> The cone penetrometer tests (CPT) system uses an integrated electronic tool which is pushed <br /> through the subsurface using a specially designed CPT rig with a force capacity of 20 to 25 tons. <br /> The electronic tool collects continuous measurements of pore water pressure (to identify the <br /> depth to ground water) and other parameters (tip resistance, sleeve friction, dynamic pore <br />