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lca. Cal/EPA Department of Toxic Substances Control March 3, 1997 Pete Wilson 400 P Street, Governor 4th Floor James M. Strock P.O. Box 806 Ms. Elizabeth C. Jennings Secretary for Sacramento, CA Staff Attorney Environmental 95812-0806 Protection State Water Resources Control Board 901 P Street Sacramento, California 95814 LINCOLN CENTER SITE, STOCKTON, CALIFORNIA Dear Ms. Jennings: This is in response to your question to me regarding the issues raised in the letter from Mr. Robert C. Thompson of LeBoeuf, Lamb, Greene & MacRae to Ms. Wendy Cohen of the Central Valley Regional Water Quality Control Board, dated December 10, 1996, in the matter of the Lincoln Center Site located in Stockton, California. Your question is whether the proposed treatment of groundwater contaminated with hazardous waste at the Lincoln Center Site requires a hazardous waste facility permit from the Department of Toxic Substances Control (DTSC) under Section 25201 of the Health and Safety Code (HSC). Pursuant to HSC Section 25201(d), a hazardous waste facility permit is not required for a facility that meets the requirements of Section 13263.2 of the Water Code. As I understand, you have looked into the requirements of Water Code Section 13263.2 and the only pending issue is concerning subsection (b)(1) of section 13263.2, as to whether such treatment requires a hazardous waste facility permit pursuant to the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901 et seq. You requested that DTSC assist you in making a determination on this issue. Given the circumstances and the proposed treatment at the Lincoln Center Site, it is DTSC's position that pursuant to section 270.1(c)(2)(v) of Title 40 of the Code of Federal Regulations (CFR), a RCRA permit will not be required for the proposed treatment if the proposed treatment falls under the definition of a "wastewater treatment unit" under 40 CFR section 260.10. ^- Cry