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d. Background Information Goehring Meat Inc. (GMI) had been manufacturing various meat products (e.g. bacon, ham, and sausage) since 1961. Processed waste water with a high total dissolved solids (TDS) level was discharged to on-site, unlined surface im- poundments [regulated by Waste Discharge Requirement Resolution No. 65/66-110 adopted by the Central Valley Regional Water Quality Control Board (CVRWQCB) on April 15, 1966] . This discharge caused elevated TDS levels in the shallow groundwater aquifer underlying the facility. The CVRWQCB conducted a water quality survey of domestic wells after receiving a complaint from a homeowner in July 1986. On September 28, 1987 GMI was ordered by CVRWQCB (Cleanup and Abatement Order No. 87-733) to develop an alternative method of process waste water disposal, to assess the im- pact of their operations on groundwater, and develop a remediation plan. Meanwhile, several investigations and actions took place. On September 29, 1988, the CVRWQCB Ex- ecutive Officer requested by letter that GMI submit a $1, 000,000 performance guarantee and to complete four new domestic wells prior to October 28, 1988. A potential buyer, Newco Acquisition, met with the CVRWQCB staff on Oc- tober 4, 1988. Newco indicated that the $1, 000, 000 guarantee would cause them to back out of the acquisition, and GMI claimed they would go bankrupt if not bought out. Finally, CVRWQCB issued Cease and Desist Order No. 88-191 to Newco Acquisition (now Victor Fine Foods) and GMI was sold. Currently, extracted groundwater is diluted with fresh water to reduce the TDS level below 1200 parts per million (ppm) and then discharged to the Mokelumne river. The processed waste water is still discharged to the ponds. This conditional interim disposal of groundwater to the river and waste water to the ponds must cease by March 1, 1990. Victor Fine Foods has elected to pursue an injection well as a long-term disposal alternative. Because of the enforcement actions by the CVRWQCB, the company needs a Class I non-hazardous waste injection well permitted and completed prior to March 1, 1990. EPA's UIC program received an application from Golden Gate Fresh Foods, Inc. for one Class I non-hazardous waste in- jection well on January 19, 1989, and a letter of credit to meet the financial assurance requirements was received on January 26, 1989. On February 17, 1989, EPA notified the applicant by letter to provide additional information. EPA received the information requested on April 20, 1989, and the applicant was informed by a letter dated May 11, 1989, that the application was administratively complete. On July 7, 1989 EPA began technical evaluation of the applica- tion. 2