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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Steven T.Butler,Chair <br /> Winston H. Hickox Gray Davis <br /> SrrrctngforSacramento Main Office Gorernar <br /> Environmental Intcmct Address: hnp://www.swrcb.ca.gov/—rwgav5 <br /> Protection 3403 Roulicr Road,Suitc A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•pAX(916)255-3015 <br /> NOTICE OF VIOLATION E® <br /> 27 April 2000 APR 2 8 2000 <br /> `NVIRGIvIt,j,, v ,, <br /> PeRMIT/SERVICEg TH <br /> S. Paul Verma, P.E. <br /> City of Tracy <br /> Public Works Department <br /> 520 Tracy Blvd. <br /> Tracy, CA 95376 <br /> CITY OF TRACY LAND TREATMENT FACILITY, SAN JOAQL-LN-COUNTY, CALIFORNIA <br /> Following the case review of the City of Tracy Land Treatment facility, it is evident that requirements of <br /> Waste Discharge Requirement (WDR) and Monitoring Program (NRP)No. 94-216 have not been <br /> fulfilled. Until these requirements have been completed, as well as the closure requirements for Land <br /> Treatment Facilities under Section 21420 Article 3 of Title 27 of the California Code of Regulations <br /> (Title 27), the Central Valley Regional Water Quality Control Board (Board) cannot consider"Clean <br /> Closer" for this site. <br /> In 1995, the Board had reviewed and approved a draft closure plan for this site. In spite of the approval <br /> of the City of Tracy's closure plan, data(vadose zone and ground water) specified in the site's MRP and <br /> in the closure plan has not been received by the Board. Furthermore, this noncompliance has been <br /> ongoing, as noted in the Board's 19 April 1996 approval letter to the City of Tracy: <br /> "Neither closure nor monitoring has occurred in accordance with your WDRs. Waste Discharge-Order <br /> 94-216 requires a water quality monitoring program,pursuant to Article 5 of Chapter 15, be submitted <br /> by 1 September 1994. The as-built plans of the monitoring system and site characterization were to be <br /> submitted by I November 1994. Monitoring and Reporting Program No. 94-216, which includes ground <br /> water and vadose zone monitoring beneath the facility have not been initiated, in violation of Order <br /> 94-216. No sampling has been done to establish background levels or to determine if the discharge of <br /> these wastes are impacting waters of the State. <br /> We have reviewed the submitted closure plan dated 20 June 1995. The report provides for <br /> implementation of closure of the facility with the following details: <br /> 1. The Facility will not accept any additional wastes for storage or treatment at the site; <br /> 2. Vadose zone monitoring will not be done. Confirmation sampling of the waste management unit <br /> sidewalls and the materials beneath the liners will be provided at the time of closure to assure the <br /> vadose zone has not been impacted; <br /> 3. Surface water monitoring will be provided for the first seasonal storm event per MRP 94-216. <br /> California Environmental Protection Agency <br /> Q?Recycled Paper <br />