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VICTOR FINE FOODS -2- 11 December 1991 that the salt levels are increasing in the lower zone (C zone) . Since a capture zone analysis has never been done, there is no justification for the proposed soil flushing rates. VFF proposed to use lysimeters for unsaturated zone monitoring in a 20 November 1989 Nolte report. However, no lysimeters or other type of unsaturated zone monitoring are proposed in the latest Closure Plan for the project. The Closure Plan should ensure that the unsaturated zone monitoring system has an appropriate background (upgradient) point of compliance for soil pore fluid in the vadose zone. The intermittent soil sampling proposed for the project may not be sufficient to determine if salt is leaching at the desired rate. Cation-exchange-capacity (CEC) , sodium-adsorption-ratio (SAR) , or exchangeable sodium percentage (ESP) should be added to the soil sampling program since VFF intends to clean-close the impoundment for unrestricted land use. Although the relationships between test parameters may be difficult to establish in the short term, long term favorable changes in the parameters would indicate a successful clean up program as well as facilitate assessment of permissible land use in the future. Since Cease and Desist Order 88-191 required VFF to close Pond 2, the Closure Plan for Pond 2 must meet the requirements of Chapter 15, Sections 2582, 2593, and 2597 and address the above issues. VFF must demonstrate per Section 2510 of Chapter 15, that the required clean closure or closure-in-place is not feasible. Prior to resubmitting the Closure Plan, VFF should determine the following: 1. The extent of contamination at the surface and in the vadose zone. 2. The capacity and capture effectiveness of the existing extraction well system. 3. The technical feasibility of salt leaching. 4. The technical feasibility of the extraction well system removing all the polluted ground water. 5. The estimated costs for all closure and cleanup alternatives. 6. The financial mechanism that will ensure that closure and cleanup are funded until completion. POND 1: I have reviewed the August 1990 Preliminary Closure and Post-Closure Maintenance Plan for the lined Pond 1 , which also proposes soil flushing if it is determined that Pond 1 has leaked salts into the soil beneath the pond. The Closure Plan does not recognize that salts were discharged into an unlined pond at the same location prior to the construction of the lined pond. Therefore, even if it is determined that the lined pond did not leak, removal of salt-laden soils or salt from the soil , may be required. Use of soil flushing as a cleanup method may not be feasible given the existing extraction for contamination north of Pond 2 and the proposed extraction from soil flushing at the Pond 2 site. Unless an adequate capture zone analysis indicates that the additional salt laden ground water would be captured by the existing or future extraction well system, soil flushing should be eliminated from the list of methods to clean close Pond 1 .