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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair G <br /> Winston H. Hickox avis <br /> Secreraryjar Sacramento Main Office i 2,Ywlor <br /> Environmental Internet Address: http://w .sw b.ca.gov/—mgcb5 A i <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 18 July 2003 N <br /> Mr. R.M. Jones <br /> I <br /> Woodbridge Partners Inc. <br /> 639 East Locke£ord St. <br /> Lodi, CA 95240 <br /> RECLAMATION OF POND 1 AND CONVERSION FROM A CLASS II SURFACE <br /> IMPOUNDMENT TO A LINED STORM WATER RETENTION POND APPEAL, VICTOR <br /> FINE FOODS FACILITY, SAN JOA QUIN COUNTY(5B392043001) <br /> Central Valley Regional Water Control Board staff(staff) has considered your appeal of staff's 22 May <br /> 2003 letter rejecting the Pond 1 Reclamation Plan. Although, staff does not believe it is impossible to <br /> the meet existing Class II impoundment closure standards at this site, Title 27 does not specifically <br /> disallow use of a Class H impoundment for containment of storm water. As previously noted, until Pond <br /> 1 is closed in compliance with requirements it remains a Class H impoundment and must be operated <br /> and maintained as such. Staff believes that long term operation and maintenance cost will exceed any <br /> short term savings realize by not closing Pond 1 at this time. <br /> Staff has reviewed your plan with addendum to clean out, repair, and operate Pond 1, a Class H <br /> impoundment to retain storm water. Staff has the following comments: <br /> 1. Addendum 1 modified the original closure plan for Pond 1 in response to staff's comments <br /> expressed in a letter of 3 April 2003. The addendum further explains the reasons for retaining <br /> the pond as a storm water pond, commits to flushing the LCRS system until the rinsate meets the <br /> National Primary Drinking Water Standards; patching the primary liner; performing electric leak <br /> testing on the secondary and primary liners; and installing a recycle sump pump in the LCRS to <br /> return future primary liner leaks to the pond. These items respond to comments 1, 2, 3, and 4 in <br /> staff's 3 April letter. <br /> 2. Other comments in the 3 April letter specifically Comments 5. a map of the stormwater <br /> collection system; Comment 6. testing of the injection well; and Comment 7. a water balance <br /> were not addressed in the addendum. Approval of storm water discharge to Pond 1 will depend <br /> on capacity of the water collection system and of the pond. The design storm for a Class 11 <br /> impoundment is a 1000-year 24 hour precipitation storm. The pond must maintain two feet of <br /> freeboard at all times. Testing the injection well and application to permit discharge of storm <br /> water to the injection well should wait until a water balance is complete. <br /> 3. Staff has also reviewed the groundwater monitoring program at this site and based on that review <br /> believes additional monitoring wells are needed to meet Title 27 requirements. Specifically, <br /> there is no functioning detection monitoring well for this Class II Surface Impoundment. Other <br /> California Environmental Protection Agency <br /> Za Recycled Paper <br />