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California Rional Water Quality ntrol Board- c %J a Central Valley Region Robert Schneider Chair i`N�',�f'��'=NTAL HEALI II Terry Tamminen ' I)CCWT, ^_ Arnold Schwarzenegger Secretaryfor 3443 Routier Road,Suite A,Sacramento,California 95827-3003 J Governor Environmental •Fax 916 255-3015 m i• YS Protection (916)255-3000 � � .J a03 DSC —5 P http://www.swrcb,ca,gov/rwqcb5 i 3 December 2003 M Mx. Ray Baglietto and Mr. Frank Razui Tuleburg Warehouse 301 S. Aurora Street Stockton, CA 95203 - } 1 – `--`–NOTIiCE-OFNIO—L TION-REGION BOARD ORDER NO.R 025 03-0044X2, SPEEDY FOODS, 8200 N.HIGHWAY 99, STOCKTON, SAN JOAQUIN COUNTY - i This letter serves as your Notice of Violation of the discharge requirements under Regional Board Order No. R5-2003-004412 (General Order). On 24 November 2003 during an unannounced inspection and subsequent discussions with your consultant, Ground Zero Analysis, Inc. (GZA), I discovered that the groundwater treatment system at your site located at 8200 N.Highway 99, Stockton was shut down on 18 November 2003 due to system breakthrough of pollution, resulting in an unauthorized discharge of contaminated water to land. Later that day, a Fax (Enclosure) was submitted to me by GZA, which explained the events leading to the unauthorized discharge, the proposed steps to reduce the likelihood of future unauthorized discharges, and the first three rounds of analytical data required under the General Order. r The General Order was approved by the Executive Officer with my recommendation on 5 November 2003. The treatment system began discharging to land on that day after analytical data showed treated effluent groundwater concentrations met the General Order requirements. The treatment system currently consists of two 2,000-pound granulated activated carbon (GAC)units in series. In my letter dated 6 October 2003,you were warned that any ! uncertainty.in a breakthrough estimate would_increase the frequency for initial sampling_to'more_than the , ininimurn of weekly sampling. In the Report of Waste Discharge, GZA provided an estimated breakthrough time of 31 to 64 days. Actual breakthrough occurred in less than five days, which is up to an order of magnitude (12X) quicker than estimated. The faxed data shows Methyl tert-Butyl Ether(MtBE)breakthrough occurred in the first granulated activated carbon (GAC)unit(Cl) five days later on 10 November 2003. After breakthrough, C1,the treatment system was operated without notification of Regional Board or San Joaquin County Environmental Health Department(SJCEHD)staffs. At 1630 hours on 18 November 2003, the laboratory notified GZA by phone that MtBE(9.2 µg/L)was detected in the effluent water from the second GAC unit(C2), which was sampled twelve days after initial startup on 17 November 2003. Groundwater was discharged to land with MtBE concentration exceeding the General Order-required Water Quality Objective of 6 gg/L.' At 1712 hours on 18 November 2003, GZA shut down the treatment system. You did not notify SJCEHD and the Regional Board of the violation as required in the General Order and the Water Code. Subsequently the groundwater extraction pump was removed, and'a free product skimmer was placed in the well. In addition to changing out C 1 and C2, GZA also proposes to add a 200-pound GAC unit(0) to the treatment system as a polisher, to lessen the likelihood of future unauthorized discharges of pollution to land. � k California Environmental Protection Agency Y.1 1 iiiilii.liil `y 41 ��Recycled Paper