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VHI �rE�►I_�I� <br /> GROUND ZERO ANALYSIS,INC. �'t"�, ' , SFPV!CE <br /> 1714 MainStreet PM 12. 06 <br /> Escalon,California 95320-1927 <br /> Telephone:(209)838-9888 <br /> Facsimile:(209)838-9883 <br /> December 10, 2003 <br /> Mr. James L.L. Barton <br /> CA Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Routier Road, Suite A`"' - — - - - --- - - <br /> Sacramento, CA 95827-3098 <br /> Subject: Notice of Violation-Regional Board Order No. R5-2003-004412 <br /> Speedy Foods Store, 8200 N. Highway 99, Stockton, CA <br /> Dear Mr. Barton: <br /> Ground Zero Analysis, Inc. (Ground Zero) received a faxed copy on December 3, 2003 of the <br /> Notice of Violation of the discharge requirements under Regional Board Order No. R5-2003- <br /> 004412. Ground Zero would like to respond to your specific concerns listed on page 2 of your <br /> letter: <br /> I. The discharge of contaminated water, exceeding discharge permit levels, was not reported. <br /> This is a violation of the permit and subject to civil liabilities. Failures of the system are to be <br /> reported to the Regional Board within 24 hours. <br /> Although the Regional Board was not immediately notified by telephone when the discharge <br /> exceeding discharge permit levels was discovered, the treatment system was shut down within <br /> 45 minutes of.receiving verbal results from the laboratory to,prevent.fipther discharge. Based--- <br /> " upon analytical resulfs of 9.2 pp MTBE,the discharge exceeded the discharge permit levels but <br /> remained below the Primary California MCL of 13 ppb. In addition, the Regional Board was <br /> notified in writing well within the two weeks required by the Order. <br /> 2. Standard professional practice is to initiate a carbon change when contaminants break through <br /> the next to last GAC unit(in this case Cl). However, even though breakthrough of C1 occurred <br /> 6 to 12 times quicker than projected, there appears to have been no action taken (e.g. ordering <br /> new carbon, increasing samplingfrequency) to reduce the treatment system down time (ofj). <br /> Ground Zero received faxed preliminary results for the November 10, 2003 treatment system <br /> samples on November 14, 2003, in which C 1 was reported to have 17 ppb MTBE and no other <br /> detected contaminants. Ground Zero immediately notified Carbon Resources to schedule a <br /> G:IGROUNDZEITULEBURGIReporislharton NOV,doc <br />