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CEASE AND DESIST ORDER NO. R5-2004-0004 -2- <br /> WOODBRIDGE PARTNERS INC. <br /> VICTOR FINE FOODS FACILITY, LODI <br /> SAN JOAQUIN COUNTY <br /> e. Submit a technical report assessing the extent of 30 May 2001 <br /> groundwater pollution and an engineering <br /> feasibility study to remediate pollution per Section <br /> D of Monitoring and Reporting Program No. <br /> 5-01-057. <br /> To date the Discharger has failed to comply with the requirements in the facility Waste <br /> Discharge Requirements noted above. <br /> 3. On 30 August 2002 the Executive Officer, pursuant to California Water Code Section <br /> 13267, required the Discharger to submit a technical report containing a plan to close <br /> Pond 1 by November 2002 and abandonment of the underground injection well by <br /> 1 June 2003. On 30 October the discharger requested a 6-month extension for closing <br /> Pond 1 and the underground injection well. Staff denied that request and on <br /> 20 December the Discharger submitted a reclamation plan for the conversion of Pond 1 <br /> to a storm water retention pond. On 3 April 2003 staff requested additional information <br /> concerning the plan to convert Pond 1 to a storm water retention pond. On 15 April 2003 <br /> the Discharger submitted a revised reclamation plan for Pond 1. The revised plan was <br /> incomplete and did not provide the requested detailed storm water plan and water <br /> balance. On 22 May 2003 staff rejected the reclamation plan because it does not comply <br /> with facility Waste Discharge Requirements and requested a plan to clean close Pond 1 <br /> by 14 July 2003 and closure of Pond 1 by 31 October 2003 <br /> 4. On 24 June 2003 the Discharger requested that staff reconsider the 22 May letter and that <br /> they be allowed to convert Pond 1 to a storm water retention pond. On 18 July staff <br /> responded that Title 27 California Code of Regulations, Division 2 (Title 27) does not <br /> specifically disallow storm water discharge to a Class II impoundment but a Class II <br /> impoundment must be operated and managed under the requirements of Title 27 until it <br /> is closed in compliance with Title 27. <br /> 5. On 29 August 2003 the Discharger requested direct conversion of Pond 1 to a lined storm <br /> water retention pond without complying with all Title 27 requirements for operation of a <br /> Class II impoundment. <br /> 6. Pond 1 was constructed by Golden Gate Fresh Foods Co. as a Class II surface <br /> impoundment for containment of high TDS waste brine from their food processing <br /> operation. The inner liner of the impoundment is known to be breached and staff is <br /> concerned that the outer liner may also leak. It is unknown whether the soils and shallow <br /> groundwater directly beneath the pond are degraded with elevated salts. However, <br /> previous operations at the food processing facility discharged to an unlined pond that did <br /> degrade soils and groundwater. <br />