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California6gional Water Quality Con I Board <br /> Central Valley Region <br /> Karl F. Longlm SO'). P.E_. Chair <br /> Linda S, .-\Jams %mold <br /> < mr- O,r Sacramento <br /> Fm vunnmAchwarer <br /> m�d 111,21,ti n en,rr Une x� 1,. L+neho ttna (:d � N .nIrn,"n... <br /> Mom,19161 464-1291 • I'.4S(916)464-1641 <br /> hnp .c.c.. ..merhnards ca 2ov!ccrorah ello <br /> To: Alex MacDonald, Senior Engineer FROM: Marie McCrink, EG <br /> Site Cleanup Program Site Cleanup Program <br /> DATE: 20 November 2008 SIGNATURE: <br /> SUBJECT: LINCOLN CENTER ENVIRONMENTAL REMEDAITION TRUST. RESPONSE <br /> TO DRAFT ROV AND NOV. AND ASSESSMENT OF MMPS <br /> On 4 September 2008, the Central Valley Water Board sent the Lincoln Center Environmental <br /> Remediation Trust (Discharger) a draft Record of Violations (ROV) and Notice of Violation for <br /> the period of 1 January 2000 through 30 April 2008, detailing the assessment of Mandatory <br /> Monitoring Penalties (MMPs) for the Groundwater Extraction and Treatment System (GETS). <br /> The Discharger responded by letter dated 30 September 2008. In the following discussion, <br /> the Discharger's comments have been addressed, and a correction has been made to the <br /> Record of Violations for incorporation into the Administrative Civil Liability Complaint (ACLC). <br /> Comment No. 1 — Tetra chloroethene (PCE) Effluent Exceedance <br /> Violation 7. The result reported for August 23, 2007, was 0.53 pg/L. The Discharger contends <br /> that the value should be rounded down to the same number of decimal places as the limit. 0.5 <br /> pg/L effecting a result that is now equal to. not in excess of, the discharge limit. <br /> This violation has been deleted from the list of violations subject to mandatory minimum <br /> penalties <br /> Comment No. 2 — All Remaining Exceedences <br /> The Discharger contends that the Trust has operated the system consistently during the entire <br /> time period of the violations, and was issued a new permit in October 2005. If there were <br /> concerns about compliance that would justify penalties, these should have been highlighted <br /> early in the process. <br /> These MMPs have been mandated by and issued pursuant to California Water Code (CWC) <br /> section 13385. for violations of Waste Discharge Requirements (WDR) Order No. R5-2005- <br /> 0144 (NPDES No. CA0084255) by the Lincoln Center Environmental Remediation Trust <br /> Groundwater Extraction and Treatment (GET) system <br /> This violations have not been deleted from the list of violations subject to mandatory minimum <br /> penalties <br /> Comment No. 3 — Statute of Limitations <br /> California Environmental Protection Agency <br /> jRn-V rlyd Par.... <br />