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y <br /> Mr. Ray Baglietto and Mr. Frank Razui - 3 - 18 July 2005 <br /> Our comments to the Report are the following: <br /> 1. In the future, do not discharge to land from the GWP&TS prior to conducting the effluent water sampling <br /> and receiving approval from Regional Board staff, as required by the General Order. This requirement includes <br /> all maintenance which may affect the discharge(adding de-scaling compounds, changing out the GAC, etc.). <br /> 2. Please review the latest(July 2005) quarterly monitoring data as soon as you receive it,to determine <br /> whether the discharge has affected water quality, and contact Mr. Barton immediately if there is such evidence. <br /> 3. We concur with exchanging the GAC and to pressure washing the air stripper, as proposed by GZA. <br /> 4. We cannot concur with the use of phosphate sequestrant until we receive the necessary information <br /> previously requested in Mr. Barton's email (attached)dated 19 May 2005 to GZA, and complete our evaluation <br /> of the potential impacts to water quality from the phosphate sequestrant. Note that Mr. Barton's attempts to <br /> speak with the manufacturer have been unsuccessful to date. <br /> 5. We concur with enlarging the discharge area. Previously a garden hose was used to discharge <br /> approximately 1 gallon per minute(gpm) from the GWP&TS. During Mr. Barton's site inspection on <br /> 5 June 2005, six days after the GWP&TS was shut down,the discharge area was dry, indicating that either the <br /> effluent is infiltrating at a rate of greater than 1 gpm and/or evaporation is removing water ponding on the soil <br /> surface. There is adequate room (several acres of open field) owned by you for a larger discharge area; the <br /> solution may be this expansion coupled with multiple emitters to eliminate ponding. This minor change <br /> (expanding an existing WDR discharge zone without any possibility of exacerbating the condition of the <br /> previous discharge zone)would not require modification to the Order. Temporarily fencing the discharge zone <br /> would reduce the potential for damage previously reported as caused by the mower. <br /> The recommendations proposed in the Report are approved and shall be completed forthwith (as soon as possible) <br /> but by no later than 1 August 2005. Mr.Barton plans to visit the site and collect split samples from the GWP&TS <br /> on that day, to verify that you have complied with the General Order prior to restarting. Please let Mr. Barton <br /> know if you can complete the repairs prior to that date, so that he may reschedule my inspection. <br /> Future violations of this General Order may result in fines or additional enforcement action. If you have any <br /> questions, please telephone James Barton at(916)464-4615. <br /> } <br /> ROBERT BUSBY, C.E.G. <br /> Senior Engineering Geologist <br /> Enclosure <br /> cc: Mr. Jeffery Wong, San Joaquin County Environmental Health Department, Stockton <br /> Mr. John Lane, Ground Zero Analysis, Inc., Escalon <br /> U.S. Environmental Protection Agency, San Francisco <br /> California Dept. of Fish and Game, Rancho Cordova <br />