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MR. BILL DUCKENFIELD 2 2 May 1991 VICTOR FINE FOODS Review of June 1990 to March 1991 monthly monitoring reports indicates that VFF has allowed the freeboard in the Equalization/Emergency Storage Basin(EESB) to be less than 12 feet since 17 November 1990 and is a violation of Specification B.14 of WDRs Order No. 90-047 which states: B.14: "The equalization/emergency storage basin shall be designed, constructed, and operated to maintain a freeboard of 12 feet +/- I foot. In the event that the activated sludge portion of the treatment plant and/or the injection well are down for maintenance or repairs wastewatermay be diverted to acid he-1-1 in the EESB for up to 30 days or until the freeboard reaches 2 feet plus that needed for the 1000 year, 24-hour storm. Immediately after such an event water levels must be lowered at a minimum rate equal to 3 days for every day of diversion. At no time shall the freeboard in the EESB be less than 12 feet +/- 1 foot for more than 120 consecutive days." In November 1990, VFF began having operational problems with the pretreatment plant and injection well. These operational problems have resulted in at least 16 feet of head on the liner for an extended period of time. VFF failed to notify our office when operational problems initially occurred and no explanations were provided in the monthly reports for either operational problems or missed sampling events. This is a violation of Provision D.9. of WDRs Order No. 90-047 which states: D.9: "The Discharger shall immediately notify the Board of any flooding, equipment failure, slope failure, or other change in site conditions which could impair the integrity of waste or leachate containment facilities or of precipitation and drainage control structures." VFF has failed to have a duly authorized representative sign the monitoring reports as required in Standard Provisions and Reporting Requirements (SP&RR), Reporting Requirements for Monitoring, D.6. which states in part: D.6: 'All report shall be signed by: (a) In the case of a corporation, by a principal executive officer at least of the level of vice president or his duly authorized representative, if such representative is responsible for the overall operation of the facility from which the discharge originates; ..."