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Sent By: RWQCB; 2553439; Dec-3-03 17:12; Page 215 <br /> California Regional Water Quality Coitrol Board <br /> Central Valley Region a <br /> Robert Schneider,Chair Arnold 5chwarzene$ger <br /> Terry Taniminen <br /> Serretaryfor 3443 Rou6ct-Road,Suite A,Saa'amento,California 95827-3003 Govemor <br /> rRvirownewal (916)255-3000•Fax(9 16)2 55-30 15 <br /> Protection bttp://ww-iv.swreb.ca.guv/rwgcb5 <br /> 3 December 2003 <br /> Mr. Ray Baglietto and Mr. Frank Razui <br /> Tuleburg Warehouse <br /> 301 S. Aurora Street <br /> Stockton,CA 95203 <br /> NOTICE OF VIOLATION—REGIONAL BOARD ORDER NO.R5-2003-004412, <br /> SPEEDY FOODS,8200 N. HIGHWAY 99,STOCKTON,SAN JOAQUIN COUNTY <br /> This letter serves as your Notice of Violation of the discharge requirements under Regional Board <br /> Order No. 115-2003-004112 (General Order). <br /> On 24 November 2003 during an unannounced inspection and subsequent discussions with your consultant, <br /> Ground Zero Analysis,Inc, (GZA), I discovered that the groundwater treatment system at your site located at <br /> 8200 N. Highway 99, Stockton was shut down on 18 November 2003 due to system breakthrough of pollution, <br /> resulting in an unauthorized discharge of contaminated water to land. Later that day,a Fax (Enclosure)was <br /> submitted to me by GZA,which explained the events leading to the unauthorized discharge, the proposed steps to <br /> reduce the likelihood of future unauthorized discharges,and the first three rounds of analytical data required under <br /> the General Order. <br /> The General Order was approved by the Executive Officer with my recommendation on 5 November 2003- The <br /> treatment system began discharging to land on that day after analytical data showed treated effluent groundwater <br /> concentrations met the General Order requirements. The treatment system currently consists of two 2,000-pound <br /> granulated activated carbon(GAC) units in series. In my letter dated 6 October 2003,you were warned that any <br /> uncertainty in a breakthrough estimate would increase the frequency for initial sampling to more than the <br /> minimum of weekly sampling. In the Report of Waste Discharge,GZA provided an estimated breakthrough time <br /> of 31 to 64 days. Actual breakthrough occurred in less than five days,which is up to an order of magnitude <br /> (12.X)quicker than estimated. The faxed data shows Methyl tert-Butyl Ether(MtBE)breakthrough occurred in <br /> the first granulated activated carbon(GAC)unit(C 1)five days later on 10 November 2003. After breakthrough, <br /> C1,the treatment system was operated without notification of Regional Board or San Joaquin County <br /> Environmental Health Department(SJCEHD)staffs. At 1630 hours on 18 November 2003, the laboratory <br /> notified GZA by phone that MtBE(9.2 µgli.)was detected in the effluent water froln the second GAC unit(C2), <br /> which was sampled twelve days after initial startup on 17 November 2003. Groundwater was discharged to land <br /> with MtBE concentration exceeding the General Order-required Water Quality Objective of 6 µg/L. <br /> At 1712 hours on 18 November 2003, GZA shut down the treatment system. You did not notify SJCEHD and the <br /> Regional Board of the violation as required in the General Order and the Water Code, Subsequently the <br /> groundwater extraction pump was removed,and a free product skimmer was placed in the well. In addition to <br /> changing out C 1 and C2,GZA also proposes to add a 200-pound GAC unit(C3)to the treatment system as a <br /> polisher,to lessen the likelihood of future unauthorized discharges of pollution to land. <br /> California Environmental Protection Agency <br /> �c>" Recycled Paper <br />