SITE INFORMATION AND CORRESPONDENCE

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CEASE AND DESIST ORDER NO. -3- WOODBRIDGE PARTNERS INC. VICTOR FINE FOODS FACILITY SAN JOAQUIN COUNTY previous operations at the food processing facility discharged to an unlined pond that did degrade soils and groundwater. 7. Because no sampling has been done below the Pond 1 it is unknown if elevated levels of salts exist in the soils. Therefore,before the pond is converted from a Class H surface impound into a stormwater pond the soils should be analyzed. The addition of stormwater from this facility to the pond would cause the pond to fill increasing the head on the liner. Any leakage would mobilize the salts in the soils and transport them to groundwater. Therefore,Pond 1 should be closed in compliance with Waste Discharge Requirements and Title 27. 8. Title 27 California Code of Regulations, Section 21400, states in part: "Closure Requirements for Surface Impoundments. (Cl 5. A2582) (a) Remove Free Liquids—All free liquid remaining in a surface impoundment at the time of closure shall be removed and discharged at an approved waste management unit(Unit). All residual liquid shall be treated to eliminate free liquid. (b) Options—Following removal and treatment of liquid waste, impoundments shall be closed in one of two ways, as approved by the RWQCB. (1) Mandatory Clean-Closure Attempt— Unless the discharger demonstrates, and the RWQCB finds, that it is infeasible to attempt clean-closure of the impoundment, then all residual wastes, including sludges,precipitates, settled solids, and liner materials contaminated by wastes, shall be completely removed from the impoundment and discharged to an approved Unit. Remaining containment features shall be inspected for contamination and, if nbt contaminated, can be dismantled. Any natural geologic materials beneath or adjacent to the closed impoundment that have been contaminated shall be removed for disposal at an appropriate Unit. For surface impoundments that are successfully clean-closed, as herein described, the RWQCB shall declare the Unit no longer subject to the SWRCB promulgated requirements of this title. If, after reasonable attempts to remove such contaminated materials, the discharger demonstrates that removal of all remaining contamination is infeasible, the surface impoundment shall be closed as a landfill or land treatment unit, as appropriate,pursuant to &(b)(2)• (2) Fallback Closure Options—In cases where clean-closure(under &(b)(1)] is infeasible, the discharger shall propose for RWQCB approval either: