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Gurdip Kelley ` C✓ - 2 - 12 December 2008 <br /> o Where is the 100-percent replacement area? <br /> • The underground stormwater disposal system raises some groundwater quality protection <br /> issues. Please address the following: <br /> o How will spilled fuel,.motor oil, and other contaminants likely to be present in <br /> stormwater be prevented from degrading groundwater quality? <br /> o What will happen to stormwater if the underground stormwater system becomes <br /> plugged or can't percolate all the stormwater that falls on the site? <br /> Regional Treatment System Considerations and CEQA <br /> Because the project proposes the use of an on-site wastewater system, environmental review <br /> documents should include evaluating the impact of the system. Continued use of on-site <br /> systems when centralized systems can be constructed or improved is not protective of water <br /> quality. As a result, the Regional Water Board prefers regional treatment systems rather than <br /> individual systems. In this case, the Regional Water Board recommends additional discussions <br /> with the City of Lathrop regarding providing water and sewer service. <br /> Antide radation Considerations <br /> All wastewater discharges must comply with the Antidegradation Policy (State Water Board <br /> Resolution 68-16) and the Antidegradation Implementation Policy contained in the Basin Plan. <br /> The Antidegradation Policy is available on page IV-15.01 at: -http://www.waterboards.ca.gov/ <br /> centralvalley/water issues/basin_plans/sacsjr pdf. In part it states: _ <br /> Any discharge of waste to high quality waters must apply best practicable treatment or <br /> control not only to prevent a condition of pollution or nuisance from occurring, but also to <br /> maintain the highest water quality possible consistent with the maximum benefit to the <br /> people of the State. <br /> This information must be presented as an analysis of the impacts and potential impacts <br /> of the discharge on water quality, as measured by background concentrations and <br /> applicable water quality objectives. <br /> If the project proponent is-unable to obtain water and wastewater service from the City of <br /> Lathrop, a Regional Water Board permit will be needed. The antidegradation analysis is a <br /> mandatory element in the permitting process and collection of the groundwater data will be a <br /> critical element in that process. The project proponent needs to investigate groundwater <br /> quality, and potential impacts to groundwater quality, as part of their evaluation of the project's <br /> impact on the environment. <br /> Please call me at (916) 464-4616 if you have any questions regarding this request for additional <br /> information. <br /> I <br /> TIMOTHY R. O'BRIEN <br /> Waste Discharge to Land Unit <br /> cc: See attached list. <br /> W ASta1T50bHenTtSan loaquin%KSC Travel CcntehKeiley S Dee 08.doc <br />