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deputy City AVrorney city of Stockton 6ffice of the Cit ttorney 425 North E1 Dera St. Stockton, California 95206 MCCORMICR & BAXTER SUPERFMM SITE Dear Mr. Thiltgen: I am responding to your letters dated June 12 , 1995 and July 26, 1995. You have inquired whether my letter of May 30, 1995 addressed to Mr. Morris Allen is an ,Official California Environmental Protection Agency opinion Letter" . My May 30, 1995 letter sets forth the position of the office of Legal Counsel, Department of Toxic Substances Control, with regard to the application of hazardous waste laws to facts at issue at the McCormick & Baxter site. it does not bind Cal/EPA enforcement agencies or local enforcement agencies. I also want to make clear that the position expressed in my May 30, 1995 letter 2DJy applies to the McCormick & Baxter site, and does not apply to categorical industrial dischargers. This is because the analysis provided in the May 30, 1995 letter is based on facts which are specific to the McCormick & Baxter site. Lastly, with regard to the July 10,. 1995 Memorandum written by Elizabeth Miller Jennings, Senior Staff Counsel, of the State Water Resources Control Board, I agree with Ms. Jennings that the discharges from the McCormick & Baxter site must comply with the federal Clean Water Act, the California Water Code, the City of Stockton°s National Pollutant Discharge Elimination System (NPDES) permit and local ordinances. My May 30, 1995 letter to Mr. Allen only addressed the groundwater treatment issues as regulated by the California Hazardous Waste Control Law (Division 20, Chapter 6. 5 of the Health & Safety Code) . The letter was not intended to nor did it address the application of other legal requirements including the Clean Water Act to the discharges at the McCormick & Baxter site. .r