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Northern California Office 5075 Commerci TCircle Suite A <br /> Concord , CA 94520 ( 925 ) 363 - 7322 Fax ( 925 ) 363 - 7275 <br /> t <br /> RA a <br /> 09 �1 C JAN 13 2003 <br /> ENVIIINMENT HEALTH <br /> PERMIT/SERVICES <br /> We're gaining new ground. <br /> January 9, 2003 <br /> Mr. Mark Madison <br /> City of Stockton <br /> Department of Municipal Utilities <br /> 2500 Navy Drive <br /> Stockton, CA 95206-1191 <br /> Re: Notice of Violation <br /> 2103 Country Club Boulevard, Stockton <br /> Dear Mr. Madison: <br /> In response to the Notice of Violation letter of December 17, 2002, I would offer the <br /> following explanation: <br /> 1) Though activated carbon has been used to treat extracted groundwater at this site, <br /> previous permit conditions did not actually require treatment, since dissolved hydrocarbon <br /> concentrations were below maximum discharge limits. Dissolved MtBE concentrations on <br /> site are generally below detection Iimits. New permit conditions in August changed the <br /> MtBE discharge limits from essentially unlimited (as much as would result in the 100mg/L <br /> TPH limits to be exceeded) to below detection limits of 0.5 µg/L. Under previous permit <br /> conditions, there was no need to track the carbon units for MtBE loading, even at the <br /> minimal concentrations. At very low levels of MtBE, it is difficult to predict carbon <br /> breakthrough but the sample data indicates that the carbon has reached its absorptive <br /> capacity for MtBE. It is possible that since the analytical results are just at detection limits, <br /> another sample for verification might have been below detection limits. We did not pursue <br /> resampling because: 1) we did not want to risk the possiblity of continuing to violate the <br /> permit by further operation and; 2) we had schedulted to terminate operations under this <br /> permit at about this time anyway. A new permit will be required when we wish to resume <br /> discharge. <br />