SITE INFORMATION AND CORRESPONDENCE

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WASTE DISCHARGE REQUIREMENTS ORDER NO.5.01-057 -3- WOOD13RIDGE PARTNERS INC. VICTOR FINE FOODS FACILITY SAN JOAQUIN COUNTY WASTES AND THEIR CLASSIFICATION 14. `Designated waste' is defined in Title 27, 120210, as a non-hazardous waste which consists of, or contains pollutants which, under ambient environmental conditions at the waste management unit,could be released at concentrations in excess of applicable water quality standards,or which could cause degradation of waters of the state. 15. Previously,when the food processing plant was in operation, the facility discharged process wastewater and brine wastes to unlined and lined ponds. These wastes especially after evaporative concentration were a significant threat to water quality and therefore,the discharge was a `designated waste'. SURFACE IMPOUNDMENTS AND INJECTION WELL , 16. During meat packaging and processing operations brine wastewater was discharged to two onsite storage ponds and to a deep injection well. Locations of the ponds and the injection well are shown on Attachment B, which is incorporated herein and made a part of this order. 17. Pond.1 started taking process wastewater and brine wastes in about 1962. In 1984, Title 23, CCR Div. 3, Chapter 15 (Chapter 15)was amended to require liners for brine disposal ponds. Subsequently, Pond 1 was retrofitted with synthetic and clay liners to comply with the requirements for a Chapter 15 Class H Surface Impoundment. Chapter 15 requirements for surface impoundments are now in Division 2, Title 27 (Title 27) of the California Code of Regulations (CCR). Pond l was never closed per Title 27 requirements. 18. Pond 2 is an unlined surface impoundment (built before liner requirements) that began taking brine wastes in 1982 and was dewatered in 1991. Pond 2 may have leaked substantial quantities of brine wastes to groundwater. Soils immediately beneath Pond 2 contain elevated concentrations of TDS, chloride and sodium to a maximum depth of 25 feet. Because Pond 2 pre-dates the present liner requirements, it will be closed under State Water Resources Control Board Resolution 92-49 (Resolution 92-49). 19. The injection well was constructed in 1990 for disposal of brine wastes from processing operations and polluted groundwater from three onsite remediation wells. The injection zone ranges between depths of 2800 and 3400 feet below ground surface. The well operated under an Underground Injection Control (UIC)permit issued by the federal Environmental Protection Agency;(USEPA). The injection well was shut down in July 1994. A$20,000 bond is held by the Bank of Lodi to closed the injection well. The well is a potential conduit between the poor quality deep aquifer and good quality shallow aquifers. To protect water quality in shallow to intermediate depth aquifers the injection well should be properly abandoned after existing on site wastewaters have been discharged.