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California R*nal Water Quality Aktrol Board <br /> Central Valley Region <br /> Robert Schneider, Chair +# <br /> u <br /> Terry Tamminen Sacramento Main Office <br /> Secretary for Internet Address: http://w .sw cb.ca.gov/mgcb5 Arnold Schwarzenegger <br /> Environmental 11020 Sue Rancho Cordova,CA <br /> 5Governor <br /> Protection Phon (9116)464291 Fax(916)464-4797iRfECEII,ED <br /> JUN 0 3 2004 3 June 2004 <br /> Ronald A. Burt ENVIRONMENT HEALTH <br /> Patterson Planning & Services, Inc. PERMIT/SERVICES <br /> 4525 West End Avenue, Suite 215 <br /> Nashville, TN 37205 <br /> REVIEW OF FOUR MONTH FULL-SCALE TREATMENT SYSTEM OPERATION REPORT, <br /> KEARNEY KPF, 1624 EAST ALPINE AVENUE, STOCKTON, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Quality Control Board has reviewed the 20 May 2004 Review of First <br /> Four Months of Full-Scale Treatment System Operation (Report) submitted by Dudek &Associates, Inc. <br /> on behalf of Kearney-National, Inc. (Kearney) for the Kearney-KPF facility at 1624 East Alpine Avenue in <br /> Stockton. As required by Waste Discharge Requirements (WDRs) Order No. 5-01-269,the Report <br /> discusses the sampling and water level monitoring results during full-scale operation of the groundwater <br /> pump and treat system from 11 December 2003 to 11 March 2004 and then restart on 7 April. The <br /> Department of Toxic Substances Control may provide comments on the Report under separate cover. <br /> We have the following comments on the Report: <br /> 1. It is unclear when maintenance of the treatment air stripper occurred. Page 2 of the Report states <br /> the maintenance was performed in April 2004, but the system was shut down on 11 March. <br /> Kearney needs to provide a detailed explanation of the steps that occurred from the time the <br /> exceedences in effluent shut the system down to when the air stripper was cleaned, including the <br /> shutdown events to remove pieces of filter pack from the Y-strainer through 25 April, so that it is <br /> clear why the process took 45 days. The Report states the system was shut down on 25 April to <br /> clear the Y-strainer but does not discuss when the system was restarted. A timeline of events <br /> would be an effective means of illustrating the events to bring the treatment system back into <br /> compliance with the WDRs. <br /> 2. Although the Report includes logs, it does not discuss the retention basin or the status of the <br /> pumps,piping, or wells. Kearney needs to discuss this information. <br /> By 2 July 2004, please submit an addendum to the Report that addresses the above comments. If you <br /> have any questions, you'may contact me at (916) 464-4719 or lewisd@rb5s.swrcb.ca.gov. <br /> &-Aa � �`' <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> cc: Mr. Doug O'Neal, Department of Toxic Substances Control, Sacramento <br /> Mr. Harlin Knoll, San Joaquin County Environmental Health Department, Stockton <br /> Kearney National, Inc., New York,NY <br /> Mr. H. Derrick Peterson, Esq., Austin, TX <br /> Mr. Peter Quinlan, Dudek&Associates, Encinitas <br /> California Environmental Protection Agency <br /> Co Recycled Paper <br />