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VICTOR FINE FOODS -3- 11 December 1991 Another concern regarding the Preliminary Closure Plan for Pond 1 is that no Construction Quality Assurance (CQA) Plan was proposed for the final cap. A CQA Plan should be submitted in order to demonstrate that all engineered structures meet the prescriptive and performance requirements of Chapter 15. Also, no testing was proposed for the repair of the existing liner. The repair of the existing liner is required because VFF proposes to drill holes through all layers of the pond liner and LCRS to collect soil samples for leak testing. Finally, VFF should notify our office of its intent to close Pond 1 as required by Section 2590(c) (5) of Chapter 15. I am concerned with VFF's intent to provide the financial resources for closure of Pond 1 . Section 7 (Financial Assurance) of the Pond 1 Closure Plan states that Golden Gate Fresh Foods, the parent company to Victor Fine Foods, has adequate financial resources. Hcwever, no legally, binding financial instrument has been put forward by Golden Gate Fresh Foods to ensure that adequate financial resources will be available. Now that Victor Fine Foods intends to cease operations on 13 December 1991, it is necessary that we secure some type of financial instrument or negotiate some type of agreement to ensure that the costs of closure of Pond 1 are met. Summary VFF needs to resubmit the Closure Plans for both Ponds 1 & 2 and ensure that the Closure Plans comply with the informational and prescriptive requirements of Chapter 15. Chapter 15 provides the basic methodology for clean closure or closure-in- place. If VFF can demonstrate that either of these methods are not feasible, then VFF can propose a specific engineered alternative which meets the prescriptive standards of Chapter 15 and provides equivalent water quality protection. The Closure Plan, submitted on 28 October 1991 for Pond 2, does not meet the requirements of Chapter 15 as an engineered alternative. Additional work is required to demonstrate compliance with the requirements of Section 2510 of Chapter 15. A capture zone analysis, which demonstrates that the extraction wells will remove all salts flushed into groundwater, is also needed before we can accept the Closure Plan. Additional testing of soils is required to document the progress of the cleanup and determine an end point for the cleanup operation. Review of the Preliminary Closure and Post-Closure Maintenance Plan for Pond 1, submitted in August 1990, indicates that VFF intends to use soil flushing as a method to remove salts from the soils beneath Pond 1 . As stated above, unless a capture zone analysis indicates that the existing or future extraction system is capable of handling the additional salt and hydraulic load, VFF should eliminate this method of closure from the closure plan. VFF must also comply with Chapter 15 notification requirements for closure of its Class II surface impoundment. After proper notification, VFF is required to submit a Final Closure and Post-Closure Maintenance Plan, which includes a Construction Quality Assurance Plan for all engineered structures, for review and approval by our office. RAE