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MR. BILL DUCKENFIELD 4 1 May 1991 <br /> VICTOR FINE FOODS <br /> The QMR also contained data collected regarding the injection well. Review of the Deep <br /> Injection Well Data required by EPA's UIC Permit No. CAS900000002 indicates that <br /> several violations of the injection well permit occurred between October and December <br /> 1990. First, the maximum injection rate of 195 gpm was exceeded at least three times, <br /> which is a violation of Part II, Section B, Item 6 of the UIC Permit. Second, the minimum <br /> annular pressure was less than 100 psi at least nine times during the last quarter of 1990 <br /> which is a violation of Part II, Section B, Item 7 of the UIC Permit. VFF should check the <br /> injection well to insure there are no leaks in the injection well. Third, VFF failed to provide <br /> a narrative description of all non-compliance which occurred during the reporting period as <br /> required in Part II, Section D, Item 1(d) and Item 3 of the UIC Permit. Finally, the <br /> injection well became operational in July 1990; therefore, the quarterly monitoring reports <br /> for the first two quarters of operation were due on 28 October 1990 and 28 January 1991. <br /> However, the first report was never submitted and the second report was submitted on 13 <br /> February 1991, which is a violation of Part II, Section D, Item 4. <br /> SUMMARY <br /> A majority of the violations are related to failure to discuss operational problems or non- <br /> compliance issues, failure to provide written and graphical summaries of data collected <br /> during a reporting period, and failure to submit required monitoring reports by the due date. <br /> We expect a significant improvement in all future technical and monitoring reports <br /> submitted to our office or enforcement actions may be recommended by Regional Board <br /> staff. <br /> If you have any questions, please contact me at (916) 361-5737. <br /> RGBER T A. EVANS <br /> Area Engineer <br /> RAE <br /> cc: Mr. Steven Ihnen, U.S. Environmental Protection Agency, San Francisco <br /> L_,Mr. Ron Valinoti, San Joaquin County Public Health Services, Stockton <br /> Mr. Michael Leacox, Harding Lawson Associates, Sacramento <br /> Mr. Richard Stratton, Nolte Associates, Sacramento <br />