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CLEANUP AND ABATEMENT ORDER -4- GOEHRING MEAT, INC. NEWCO ACQUISITION SUB, INC. GOLDEN GATE FRESH FOODS, INC. dba VICTOR FINE FOODS SAN JOAQUIN COUNTY approached 3,000 mg/l . C zone wells have been impacted less severely, with TDS levels in one downgradient well approaching 450 mg/1 . Recent monitoring data have shown a slight increase in the TDS levels in the C zone. 20. Waste Discharge Requirements, Order No. 90-047, Provision D.4. , states in part that: D. 4. The Discharger shall comply with Monitoring and Reporting Program No. 90-047, . . . " The Discharger has failed to conduct the ground water monitoring required by Waste Discharge Requirements Order No. 90-047. Ground water monitoring was done in January 1991 and no further ground water monitoring has been accomplished since then. 21. Waste Discharge Requirements, Order No. 90-047, Provision D.10. , states in part that: D. 10. "Within six months of adoption of these requirements the Discharger sha 11 submit to the Board for approval a closure and post-closure maintenance plan, describing the methods and controls to be used to assure protection of the water quality of surface and ground waters of the area during final operations and during any proposed subsequent use of the land. . . . The method used to close each WMU at the fac i 1 i ty and ma inta in protect ion of the qua 1 i ty of surface and ground waters shall comply with waste discharge requirements established by the Board and the most current version of the closure and post- closure maintenance plan which has been approved by the Board. The final report shall be submitted at least 180 days prior to the final closure of the fac i 1 i ty. " The Discharger submitted a closure plan for Pond 1 on 9 September 1990 and Pond 2 on 28 October 1991. Both closure plans propose flushing the salts in the soil into the ground water beneath the site and capturing the saline ground waters with the existing extraction system. The Discharger has not provided any technical analysis to demonstrate that the salt flushing and extraction proposal would be successful and not exacerbate the pollution problem. In a letter dated 11 December 1991 , the Discharger was informed that staff review of the closure plans for Pond 1 and Pond 2 found that the closure plans were not acceptable and needed revisions. The Discharger has not responded to the 11 December 1991 letter. The Discharger has not submitted a closure plan for Pond 3.