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STATE OF CALIFORNIA—CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY PETE WILSON,Governor <br /> DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> 400 P STREET,4TH FLOOR <br /> P.O.BOX 806 3 <br /> SACRAMENTO,CA 95812-0806 <br /> (916) 324-0556 <br /> May 30, 1995 <br /> Mr. Morris L. Allen <br /> Director, Department of Municipal Utilities <br /> City of Stockton <br /> 2500 Navy Drive <br /> Stockton ' California 95206 <br /> MCCORMICK & BAXTER SUPERFUND SITE <br /> Dear Mr. Allen: <br /> Your Department has raised concerns regarding the present <br /> discharge of groundwater from two wells on the McCormick & Baxter <br /> Site to the sanitary sewer. Groundwater from well A8 which <br /> sampling has shown to contain levels of Pentachlorophenol above the <br /> State Soluble Threshold Limit Concentration (STLC) is being mixed <br /> with groundwater from well DSW4C in a sump before discharge to the <br /> sanitary sewer. Although sampling at the point of discharge to the <br /> sanitary sewer has apparently shown that Pentachlorophenol <br /> concentrations in the groundwater do not exceed California <br /> Hazardous Waste Control Law (HWCL) , Health and Safety Code <br /> section 25100 et seq. , regulatory threshold limits, there is a <br /> concern that the mixing of groundwater from well A8 with well DSW4C <br /> is unauthorized dilution of a hazardous waste. <br /> The term "treatment" is broadly defined under the HWCL to mean <br /> "any method, technique, or process which changes or is designed to <br /> change the physical, chemical, or biological character or <br /> composition of any hazardous waste or any material contained <br /> therein, or removes or reduces its harmful properties or <br /> characteristics for any purpose including but not limited to , <br /> energy recovery, material recovery or reduction in volume. " <br /> Title 22 California Code of Regulations (CCR) §66260 .10 . Dilution <br /> of the hazardous constituents in the groundwater extracted from <br /> well A8 by blending or mixing that groundwater with groundwater <br /> extracted from well DSW4C is a form of treatment. <br /> ®i <br />