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.� <br /> Region <br /> California al Water Quality Control Board <br /> Central Valley Region a <br /> Robert Schneider,Chair %Gray Davis <br /> Winston H.Hickox <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000-FAX(916)255-3015 <br /> 6 October 2003 ECE <br /> Mr. Ray Baglietto and Mr. Frank Razui <br /> OCT <br /> Tuleburg Warehouse EWROMMENT HEA1�k� <br /> 301 S. Aurora Street PERMITISMAGES <br /> Stockton, CA 95203 <br /> _ : •._REVIEW OFAP <br /> PLLCAT.IONLREP_4RT OF WASTE.DISCHAR_GE"FOR WASTE_DISCHARGE` <br /> REQUIREMENTS, SPEEDY FOODS STORE, 8200 N. HIGHWAY 99, STOCKTON, <br /> SAN JOAQUIN COUNTY (LUSTIS #390911), GENERAL ORDER FOR LAND DISPOSAL OF <br /> GROUNDWATER AND SURFACE WATER FROM CLEANUP OF PETROLEUM FUEL <br /> POLLUTION,NO. R5-2003-0044 <br /> I reviewed the 29 September 2003 Application/Report of Waste Discharge for Waste Discharge <br /> Requirements (Application), prepared by Ground Zero Analysis, Inc. (GZA) on your behalf. The <br /> Application includes the September 2003 groundwater.monitoring results for monitoring well MW-1, <br /> the proposed extraction point, which showed extremely high levels of total petroleum hydrocarbons as <br /> gasoline (TPHg, 280,000 gg/L), benzene (13,000 µg/L), and methyl tert-butyl ester(MtBE, <br /> 28,000 µg/L). Free product was present in MW-1 from August 2001 until March 2003. The Application <br /> proposes analyses for TPHg,benzene-toluene-ethylbenzene-xylenes, and fuel oxygenates, including <br /> MtBE. <br /> The Application does not include the following required items for the General Order for Land Disposal <br /> of Groundwater and Surface Water from Cleanup of Petroleum Fuel Pollution, Order No. <br /> R5-2003-0044 (General Order). <br /> L .An.estimate of breakthrouih time for the Granular Activated Carbon (GAC) units used for <br /> treatment of goundwater. There is a strong possibility that petroleum hydrocarbon contaminants- <br /> breakthrough of the GAC units will occur rapidly,possibly within a few days or less, at these <br /> concentrations. The Order will require that groundwater treated by both GAC units be sampled <br /> initially at intervals less than the anticipated breakthough time, which may be less than the <br /> weekly startup frequency now specified in the General Order. In other words, the initial <br /> frequency for the influent and effluent sampling of each GAC unit may require bi-weekly or even <br /> daily sampling, if contaminant breakthrough is calculated to occur at less than a weekly or bi- <br /> weekly rate. Please provide the calculations with an estimate of time to breakthrough. <br /> 2. The complete list of required laboratory analyses for influent and effluent samples. Attachment <br /> A of the General Order provides a list of specific required analyses. The Application-proposed <br /> analyses do not include the complete list of General Order-required analyses. Please review <br /> Attachment A and increase the proposed list of analyses to include all required analyses. <br /> California Environmental Protection Agency <br /> �a Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can.tt:gve demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5 <br />" J <br />