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TEL No . Jul 25 ,95 8:0? No .003 P .01 <br /> State of Caiifornla <br /> ? �! $ <br /> m <br /> ® Richard Sherwood Date, <br /> Senior Statf Counsel <br /> Department of Toxic and <br /> Substances Control Post-It"brand fax tran8rnittal rn9m 7MHarp. a <br /> 400 P Street �o <br /> Sacramento` CA 95814 Co. IDI t sonF " <br /> c m�p6. one <br /> lizabeth Miller �e trigs <br /> Senior Staff Counsel <br /> From OFFICE OF THE CHIEF COUNSEL <br /> STATE WATER RESOURCES CONTROL BOARD <br /> 901 P Street, Sacramento. Cit 96814 <br /> Mail Code 6-8 <br /> Subject: MCCORMIC:K & BAXTER SUIPERFUND SITE <br /> I am writing to comment on your letter, dated May 30, 1995, to <br /> Morris L. Allen, City of Stockton, regarding the issue of <br /> discharging from wells to Stockto ' s publicly-awned treatment <br /> works (Pow) . Apparently, the. City's Department of Municipal <br /> Utilities raised concerns about the discharge of ground water <br /> which contains level of Pentachlorophenol above the STLC to the <br /> POTW. <br /> In your letter, you explained that the contaminated ground <br /> pater is first mixed with good quality ground water before its <br /> is discharged to the PUTW. You conclude that this dilution is <br /> "treatment" within the meaning of the Hazardous Waste Control <br /> Law, Health and S6fety Code section 25100 et Beg. ( CL) . You <br /> conclude that "treatment" of the contaminated ground water i <br /> by dilution is acceptable as treatment of a hazardous waste <br /> prior to discharge to a POTW and is lawful under the Y-WC . <br /> I believe that a more complete analysis is required before <br /> determining that this process is lawful. The practice of <br /> diluting hazardous wastes with good quality ground water in <br /> order to dispose of the waste water in a POTW may in fact <br /> violate the federal pretreatment regular-ions and, therefore, <br /> the City's stational Pollutant Discharge Elimination System <br /> (N1ad)k;S) permit, the federal Clean water ACt and the California <br /> Water Code. The federal pretreatment regulations require the <br /> Citgo to adopt, a pretreatment ordinance in conformance with the � <br /> regulations. 40 Code of Federal Regulations (CFR) Part 403 . r �`•' <br /> The regulations prohibit specific substances, including <br /> hazardous wastes, through ca.Le orical pretreatment standards v <br /> and requirements, and local limitations. To determine whether ' <br /> the hazardous constituents in this discharge are prohibited, <br /> �a • <br />