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Mr. Francis Lau -2 - 14 April 1998
<br /> Therefore, a discharge by the SDCDs that exceeds their NPDES permit limitations would prompt the
<br /> Board to investigate to determine the cause and culpability. This discharge would not necessarily be
<br /> a violation of the County of San Joaquin-City of Stockton's Order. It is unlikely that the Board
<br /> would find the County in violation providing it can demonstrate substantial compliance with its
<br /> SWMP (Provision D.6).
<br /> 2. The second issue is the possibility that a discharge by the SDCDs that violates the NPDES limits
<br /> would result in contamination in an area that is not part of the SDCDs' existing cleanup
<br /> responsibility and would lead to the County having liability for the discharge. As noted above,the
<br /> County of San Joaquin-City of Stockton's Order requires that the BMPs be applied. Continued
<br /> implementation of the S WMP, along with the WDRs for the SDCDs which require extensive
<br /> monitoring safeguards to ensure that the effluent is treated sufficiently before discharging to the
<br /> storm drain, will demonstate substantial compliance with County's Permit as it pertains to SDCDs'
<br /> Lincoln Village Center discharge.
<br /> If you have any questions, you may call me at(916)255-3077.
<br /> ` G�Gr� ..
<br /> KIT CU TIS
<br /> Associate Engineering Geologist
<br /> KHC:khc
<br /> cc: Ms. Lori Senitte, State Water Resources Control Board, Sacramento
<br /> Mr. Glen Birdzell, City of Stockton Dept. of Municipal Utilities, Stockton
<br /> San Joaquin County Environmental Health, Stockton
<br /> Mr. Ronald Aronovsky,Esq., San Francisco
<br /> Mr. A.J. Birkbeck,ESQ., Fulcrum Environmental Law, Oak Park, IL
<br /> Mr. Donald T. Bradshaw, Levine Fricke Recon, Inc., Emeryville
<br /> Mr. Michael Donovan, Esq.,Zevnick Horton Guibord& McGovern, Palo Alto
<br /> Mr. David D. Durrett, Jacobs &Durrett, Sacramento
<br /> Mr. Kenneth M. Fahn, Metro Properties, Sacramento
<br /> Ms. Anne Farr, Farr Associates, Folsom
<br /> Mr. John Gregory, Esq., LeBoeuf, Lamb, Greene & MacRae,L.L.P., San Francisco
<br /> Mr. Stephen R. Henshaw, Esq., Henshaw Associates, Mountain View
<br /> Mr. John Meyer, Esq., Fulcrum Environmental Law, San Jose
<br /> Mr. Douglas Michaud, Esq., Zevnick Horton Guibord & McGovern, Chicago,IL
<br /> Mr. Wilbur Smith II,Esq., Lincoln Properties, Ltd., Stockton
<br /> Mr. Robert C. Thompson, Esq., LeBoeuf, Lamb, Greene &MacRae, San Francisco
<br /> Mr. Barry Williams, Esq., JAMS/ENDISPUTE, San Francisco
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