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TEL No . Jul 25 ,95 8:0? N0 .003 P .02 <br /> Richard W. Sherwood -2- 1111 1 0 1995 <br /> the City' s ordinance must be reviewed. EPA also lists <br /> prohibited wastes by characteristic (40 CFR 9403 .5) and by <br /> reference to a list at 40 CFR Chapter 1, Subchapter N. If the <br /> constituent is prohibited, either through L federal-listed <br /> constituents or through the ordinance, and unless diluLion is <br /> specifically authorized, it in unlawful to dilute the discharge <br /> in order to meet the pretreatment requirements. <br /> if the dilution of the hazardous waste prior to discharge in <br /> the POTW is unlawful under the water code, then it is also <br /> unlawful under the HWCL. In a number of locations throu9bout <br /> the HWCL, it is stated that actions must be consistent with Lhe <br /> Calitornia Water Code. See, e.g. Health and Safety Code <br /> 11 25187 and 25204.5. Section 25187(a) (2) clearly requires <br /> that all corrective actions incorporate waste discharge <br /> requirements issued by the Regional Water Quality Control <br /> Board. In this case, the Central Valley Regional Water Control <br /> Board did issue waste discharge requirements in the form of a <br /> NPDES permit to the City of Stockton. The permit incorporates <br /> the federal pretreatment requirements, and the city must comply <br /> with its pretreatment ordinance as a permit condition. Thus, <br /> DTGC must ensure that the remedy including any discharge to the <br /> POTW is in compliance with the pretreatment ordinance. <br /> In conclusion, I recommend that the City's pretreatment <br /> ordinance be reviewed carefully to ensure that any discharge to <br /> the POTK complies with the ordinance, and with the EPA <br /> regulations prohibiting dilution in order to achieve <br /> pretreatment standards and requirements. If you have any <br /> questions regarding this matter, please call me at <br /> (916) 657-2421. <br /> e <br /> CC: jes,. Pat Leary <br /> Central Valley Regional Water <br /> Quality Control Board <br /> 3443 Routier Road <br /> Sacramento, CA 95027-3098 <br /> Mr. Bart J. Thilt9en <br /> Deputy City Attorney <br /> City of Stockton <br /> 425 North El Dorado street <br /> Stockton, CA 95202-997 <br /> Ms. Barbara Ettl inger <br /> Assistant Regional counsel <br /> USEPA <br /> 75 Hawthorne Street <br /> San Prancisco, 94105 <br />