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California Regional Water Quality Control Board ' Central Valley Region r- Steven T. Butler,Chair i "W- Winston H.Hickox W Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Intemet Address: http://www.swrcb.ca.gov/—rwgcb5 - Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 .. Cn -- 1 August 2000 Ms. Jill Jefferson Kinder Morgan Energy Partners 1100 Town & Country Orange, CA 92868 NOTICE OF VIOLATION, TRANSMITTAL OF INSPECTION REPORT,AND WATER CODE SECTION 13267 REQUEST FOR INFORMATION,HOLT GROUNDWATER PETROLEUM REMEDIA TION PROJECT, SANJOAQUIN COUNTY Enclosed is a copy of the inspection report of the Holt Groundwater Petroleum Remediation Project. The inspection included a site visit, review of the First Quarter 2000 self-monitoring report, review of the existing waste discharge requirements and independent sampling and analysis of the influent, effluent, and receiving waters. On 20 January 2000, Discharger self-monitoring revealed detectable quantities of contaminants in excess of permissible effluent limits of General Order No. 92-150. TPH-gasoline and TPH-Diesel exceeded the allowable 30-day median(50 µg/1) and daily maximum (100 µg/1) effluent limits. Benzene and xylenes exceeded the 30-day median effluent limit of 0.5 µg/1. These Group II Pollutants exceeded the effluent limitations by more than twenty percent and are considered a significant violation as specified in California Water Code Section 13385 (h)(1) and 13385 (h)(2). The facility appeared to be adequately operated and maintained at the time of the inspection. No obvious violations of the mechanical operations were noted during the inspection of the facility. However, sodium hypochlorite and a sequestrian agent are used to aid the treatment process. The use of these chemicals was not disclosed to the Regional Board in the application for the general order discharge. It is unclear if the use of these chemicals diminishes the effectiveness of the carbon filters or alters effluent quality. The use of these chemicals must cease immediately since they are not covered by the General Order Permit. Pursuant to Section 13267 of the California Water Code, we require you to submit a technical report to this office by 15 September 2000. The report shall briefly evaluate the need to continue use of sodium hypochlorite and the sequestrian agent at this facility. The report shall evaluate the estimated daily quantity of the chemicals to be used and the effect of these chemicals on the efficiency of the treatment process. The report must also describe what safeguards or processes will be used to prevent these chemicals from affecting the quality of the effluent. California Environmental Protection Agency (a Recycled Paper