SITE INFORMATION AND CORRESPONDENCE

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CEASE AND DESIST ORDER NO. _2_ WOODBRIDGE PARTNERS INC. VICTOR FINE FOODS FACILITY SAN JOAQUIN COUNTY and in compliance with USEPA requirements. e. Submit a technical report assessing the extent of 30 May 2001 groundwater pollution and an engineering feasibility study to remediate pollution per Section D of Monitoring and Reporting Program No. 5-01- 057. To date the Discharger has failed to comply with the requirements in the facility Waste Discharge Requirements noted above. 3. On 30 August 2002 the Executive Officer,pursuant to California Water Code Section 13267, required the Discharger to submit a technical report containing a plan to close Pond 1 by November 2002 and abandonment of the underground injection well by 1 June 2003. On 30 October the discharger requested a 6-month extension for closing Pond 1 and the underground injection well. Staff denied that request and on 20 December the Discharger submitted a reclamation plan for the conversion of Pond 1 to a storm water retention pond. On 3 April 2003 staff requested additional information concerning the plan to convert Pond 1 to a storm water retention pond. On 15 April 2003 the Discharger submitted a revised reclamation plan for Pond 1. The revised plan was incomplete and did not provide the requested detailed storm water plan and water balance. On 22 May 2003 staff rejected the reclamation plan because it does not comply with facility Waste Discharge Requirements and requested a plan to clean close Pond 1 by 14 July 2003 and closure of Pond 1 by 31 October 2003 4. On 24 June 2003 the Discharger requested that staff reconsider the 22 May letter and that they be allowed to convert Pond 1 to a storm water retention pond. On 18 July staff responded that Title 27 California Code of Regulations,Division 2 (Title 27) does not specifically disallow storm water discharge to a Class R impoundment but a Class H impoundment must be operated and managed under the requirements of Title 27 until it is closed in compliance with Title 27. 5. On 29 August 2003 the Discharger requested direct conversion of Pond 1 to a lined storm water retention pond without complying with all Title 27 requirements for operation of a Class Il impoundment. 6. Pond 1 was constructed by Golden Gate Fresh Foods Co. as a Class H surface impoundment for containment of high TDS waste brine from their food processing operation. The inner liner of the impoundment is known to be breached and staff is concerned that the outer liner may also leak. It is unknown whether the soils and shallow groundwater directly beneath the pond are degraded with elevated salts. However,