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CITY OF SSTOCKTON ell— A;P DEPARTMENT OF MUNICIPAL UTILITIES CERTIFIED MAIL 2505 r I<..✓'r,._P.r✓E RE RECEIPT '3TOCJ�CrJ 35206-" '131 Sg78910 (209)537-6750 G: ,d P 834 331 516 =AX f209)9---z-7-a706 J, August 3, 1995 to - ... Ci V Marie Lacey, Remedial Project Manages ib McCormick and Baxter SuP erfund Site T U.S. Environmental Protection Agency Gr 75 75 Hawthorne Street San Francisco, CA 94105-3901 McCORMICK & BAXTER SUPERFUND SITE In reference to your Wastewater Discharge Permit for the McCormick and Baxter Superfund Site,located at 1214 West Washington Street, I have reviewed recent correspondence between Bart Thiltgen, Deputy City Attorney; Richard Sherwood, Senior Staff Counsel, Department of Toxic Substances Control; and Elizabeth Miller Jennings,Senior Staff Counsel, State Water Resources Control Board(copies enclosed). Ms. Jennings states in her letter, dated July 10, 1995, that the dilution of hazardous wastes with good quality groundwater in order to dispose of the wastewater in a POTW may violate federal pretreatment regulations and, therefore, the City's National Pollutant Discharge Elimination System(NPDES)permit, the federal Clean Water Act and the California Water Code. Section 7-089.1 of the Stockton Municipal Code prohibits the discharge of any waste defined as hazardous by any definition set forth in any federal, state, or local regulation, statute, or ordinance, unless such waste has been delisted or decertified by the agency having authority to do so or a variance has been granted by the appropriate federal, state, or local agency, including provisions for discharge to the City sewer, which variance must be approved by the Director of Municipal Utilities. This section also states that, for the purpose of verifying compliance, the City may use a single grab sample collected from any device which may discharge waste to the sanitary sewer. This sample may be collected at the source of the discharge prior to the dilution with any other waste streams. Based on this information, I have determined that the appropriate location for monitoring potential hazardous constituents in the wastewater discharge at the McCormick and Baxter site is at each individual well discharge, prior to dilution with any other waste streams. Effective August 5, 1995, your Wastewater Discharge Permit limitations for Pentachlorophenol, Dioxin and Aquatic Toxicity will be applicable at each individual well discharge; and, effective 3U days following receipt of this notice, your Wastewater Discharge Permit shall be amended to reflect self-monitoring for these constituents ate each individual well discharge. A copy of the amended Self-Monitoring Sample Program is enclosed and shall be incorporated in your Wastewater Discharge Permit 30 days following receipt of this notice. "STG`C KTL�N...0 1_Jr=CRNIA'S Sl NRiSrE S.T.IPCPT"