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v 0 Mr. Curtis Fujii -2- 7 July 1994 NORCAL Waste Systems, Inc. "a. What regulations, if any, would govern the discharge?" The Porter-Cologne Water Quality Control Act and Federal Regulations for stormwater discharges issued by the U. S. Environmental Protection Agency on 16 November 1990 (40 CFR Parts 122, 123 and 124) provided the basis for development of the General Storm Water permit, which would govern the discharge of storm water to surface waters. Stormwater collected in impoundments which may percolate to ground water may be regulated by Chapter 15, unless exempt. "b. What permits, if any, would be required?" For discharge of waste to surface waters, an NPDES permit is required. The NPDES permit may be a General Storm Water permit or a specific NPDES permit. Since we have not received any information about the discharge, such as volume and quality of discharge, we cannot tell what type of NPDES permit is appropriate. For more details, please contact Larry Nash at (916) 255-3058. For discharges to ground water, waste discharge requirements may be necessary. C. Would/could the RWQCB still waive WDR?" If WPWMA is either covered by a General Storm Water permit, or does not discharge storm water to surface waters; and demonstrates that wastes are not hazardous or designated, then Chapter 15 WDRs may be waived. "d What Best Management Practices (BMP's), if any, would the RWQCB require?" Best Management Practices may be proposed by WPWMA in an effort to demonstrate that its wastes will not adversely impact water quality or that waste will not be discharged to surface water. We do not have a list of acceptable Best Management Practices specific to composting facilities. however, I have enclosed copies of our April 1993 and March 1994 Stormwater newsletters. They have general information and the April 1993 newsletter provides information on available Best Management Practice guidance documents on page 6. 3. "Is a General Storm Water permit required if a roof is placed over the compost pile?" Yes, our understanding is EPA regulations require issuance of a General Storm Water, or NPDES permit even if a roof is placed over the site. Of course a roof should make it easier to comply with permit requirements. I suggest that you submit information regarding possible waste discharge to surface water and the proposed Chapter 15 classification of wastes to be handled at your facility. This information could then be evaluated to determine how the Regional Board should respond to your proposed project.