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ATTYley 33gg96 19 07-31 15%07 14303 P,®2,,03 <br /> CAUFORMA-CALIFORNIA MARONM Al PROTECTION AGENCY <br /> PETE WILSON.i;0.W,0, <br /> ,EPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> 400 P STREET.4TH FLOOR <br /> P.O.®OX 808 <br /> SACRAMENTO,CA 968/2.0806 O <br /> (916) 324--0556 <br /> c JUL 3 1 <br /> i <br /> CITY ATT'O.R.NEy <br /> July 27, 1995 a1TY OF 8TUCKTON <br /> Mr. Bart J. Thiltgen <br /> Deputy City Attorney <br /> City of Stockton <br /> Office of the (City Attorney <br /> 425 North E1 Dorado St. <br /> Stockton, California 95206 <br /> MCCORMICK & BAXTER SUPERFUND SITE <br /> Dear Mr, Thiltgen: ' <br /> I am responding to your letters dated June 12 , 1995 and July <br /> 26, 1995. You have inquired whether my letter of May 30, 1995 <br /> addressed to Mr. Morris Allen is an "Official California <br /> Environmental Protection Agency Opinion Letter". My May 30, 1995 <br /> letter sets forth the position of the Office of Legal Counsel, <br /> Department of Toxic Substances Control, with regard to the <br /> application of hazardous waste laws to facts at issue at the <br /> McCormick & Baxter site. It does not bind Cal/EPA enforcement <br /> agencies or local enforcement agencies. <br /> I also want to make clear that the position expressed in my <br /> May 30, 1995 letter only applies to the McCormick & Baxter site, <br /> and does not apply to categorical industrial dischargers. This is <br /> because the analysis provided in the May 30, 1995 letter is based <br /> on facts which are specific to the McCormick & Baxter site. <br /> Lastly, with regard to the July 10,. 1995'Memorandum written by <br /> Elizabeth Miller Jennings, Senior Staff Counsel, of the State water <br /> Resources Control Board, I agree with Ms. Jennings that the <br /> discharges from the McCormick & Baxter site must comply with the <br /> federal Clean Water Act, the California Water Code, the City of <br /> Stockton,s National Pollutant Discharge Elimination System (NPDES) <br /> Permit and local ordinances. My May 30, 1995 letter to Mr. Allen <br /> PM-1-y- addressed the groundwater treatment issues as regulated by the <br /> California Hazardous Waste Control Law (Division 20, Chapter 6. 5 of <br /> the Health & Safety Code) . The letter was not intended to, nor did <br /> it address the application of other legal requirements including <br /> the Clean Water Act to the discharges at the McCormick & Baxter <br /> site. <br /> ®w <br /> :r <br />