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CLEANUP AND ABATEMENT ORDER -3- GOEHRING MEAT, INC. NEWCO ACQUISITION SUB, INC. GOLDEN GATE FRESH FOODS, INC. dba VICTOR FINE FOODS SAN JOAQUIN COUNTY the discovery of pollution in early 1986 and the extent of pollution is still undefined. 15. Cleanup and Abatement Order No. 87-733 was issued by the Executive Officer to Goehring in September 1987 for violations of Order No. 65/66-110 that resulted in pollution of domestic and agricultural ground water supplies. Order No. 87-733 contains a time schedule for replacing water supplies, investigating the extent and source of pollution, and beginning cleanup. Goehring did not comply with the time schedule in the Order 87-733. Order 87-733 will remain in effect until cleanup has been achieved to the satisfaction of the Board. 16. Cease and Desist Order No. 88-191 was adopted by the Board on 28 October 1988, with a time schedule for ceasing discharge to the existing ponds and implementing final ground water remediation. Order No. 88-191 was issued to Newco on the condition that its purchase of Goehring be completed by 15 November 1988 (Newco Acquisition Sub. , Inc. , later changed its name to Golden Gate Fresh Foods, Inc. , doing business as Victor Fine Foods, as stated in Finding No. 1 above). The time schedule in Order No. 88-191 required Golden Gate to comply with Chapter 15, to cease discharge to existing percolation ponds by 1 March 1990, to define the extent of ground water pollution, to design and to implement final ground water remediation, and to close the existing ponds. 17. Limited corrective action measures, including operation of three extraction wells, have been in effect since February 1989. In 1990, the Discharger installed an injection well , a pretreatment plant, and retrofitted Pond 1 as a Class II surface impoundment as part of its corrective action program. However, the Discharger has not defined the extent of ground water pollution, implemented final ground water remediation or closed the existing ponds. 18. Waste Discharge Requirements, Order No. 90-047 was adopted by the Regional Board and regulates the pretreatment plant and Pond 1. Order No. 90-047 is designed to be consistent with the Underground Injection Control (UIC) Well Permit (issued by the Environmental Protection Agency) and Cease and Desist Order No. 88-191 which requires, in part, that the Discharger monitor and clean up polluted ground water to the Board's satisfaction. 19. The upper three zones of ground water, known as the A, B, and C zones have all been polluted by the past discharge practices at the facility. Zones A and B, 50 to 75 feet and 110 to 130 feet deep, respectively, have both been severely impacted by the high TDS discharges. Both zones have areas where TDS levels have exceeded or