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Sent By: RWOCB; 2553439; Dec-3-03_17:13; Page 315 `Mr. Ray Baglietto and Mr. Frank Razui - 2 - 3 December 2003 Speedy Foods, 8200 N. Highway 99, Stockton While we acknowledge the quickness in which the system was reportedly shut down once the breakthrough of C2 was discovered,we are concerned with the operation of the system to date, including: 1)The discharge of contaminated water,exceeding discharge permit levels,was not reported. This is a violation of the permit and subject to civil liabilities. Failures of the system are to be reported to the Regional Board within 24 hours. 2)Standard professional practice is to initiate a carbon change when contaminants break through the next to last GAC unit(in this case Cl)- However, even though breakthrough of C 1 occurred 6 to 12 times quicker than projected,there appears to have been no action taken(e.g. ordering new carbon,increasing sampling frequency) to reduce the treatment system down time(off). 3)Breakthrough of two 2,000-pound GAC units occurred in less than 10 days. The proposed corrective action is to add a 200 pound-canister(a 5% increase in GAC). Regional Board staff believe that this is a completely inadequate response/solution to the problem. Therefore,you are hereby directed to: By 26 December 2003,provide a report on the problem and a realistic solution. Describe why breakthrough occurred so quickly, whether the Report of Waste Discharge was in error for the estimate of breakthrough,and what modifications to the system are required to prevent future violations. • Because the Report of Waste Discharge stated that breakthrough would take 31 to 64 days, but actual breakthrough of the I"canister occurred in 5 days or less, you are to sample water from C1,C2,and the polisher GAC unit(C3/effluent)on every third day until Regional Board staff is assured that a realistic breakthrough time has been determined. C2 effluent breakthrough shall become the criteria for replacement of Cl. Influent groundwater sampling may remain on a weekly schedule. • Provide to SJCEHD and Regional Board staffs a faxed weekly progress update to include a table of all pertinent analytical data(influent,C1, C2, C3/effluent) to date, system operations field notes, and a summary page to include a description of any problems. Thi s weekly update will continue until Regional Board staff determines that quarterly reporting of the information will be adequate. Future violations of this General Order may result in fines or additional enforcement action. If you have any questions regarding this NOV,please telephone me at(916) 255-3115 or(916)4644615. �Mj' �• AMES L. BARTON,RG Engineering Geologist Enclosure cc: Mr.Jeffery Wong, San Joaquin County)environmental Health Department, Stockton Mr.John Lane,Ground Zero Analysis, Inc.,Escalon U.S. Environmental Protection Agency, San Francisco California Dept. of Fish and Game, Rancho Cordova We are currently scheduled to move to a new office on 13 December 2003. Beginning 15 December 2004 our mailing address will be 11020 Sun Center Drive#200,Rancho Cordova,CA 95670 and my new phone number wi[l be(916)464- 4615. Because of the move our files will not be available for review from l December 2003 until 5 January 2004. Ifyou need to review our files after 5 January 2004,please call ahead of time to set up an appointment. , California Environmental Protections Agency ea Reryclett Paper