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California R*ional Water Quality#ontrol Board rA" . Central Valley Region 9 �,, ¢° Peter M.Rooney � ? � Sacramento Main Office Secretaryfor �t '`i,, Internet Address: http://www.swrcb.mgov/—rwgcb5 Ed J.Schnabel Environmental 3443 Routier Road,Suite A,Sacramento,California 95927-3003 Chair Protection Phone(916)255-3000•FAX(916)255.3015 2 November 1998 Mr. Tony Martin Kleinfelder, Inc. - 2825 East Myrtle Street = Stockton, CA 95205 SPRECKELS MANTECA,SAN JOAQUIN COUNTY(Case No. 860) I have reviewed the Proposed Water Quality Protection Standard(WQPS)report submitted in response to the facility's Waste Discharge Requirements (WDRs) Order No. 97-204. The report presents constituents of concern,points of compliance,monitoring points, and concentration limits for constituents of concern as required by Title 27. My first concern about the report is the discussion on concentration limits. The report states on page 5 that"since groundwater is already impacted and active remediation of groundwater has been shown to be not cost effective [see Kleinfelder correspondence dated August 18, 1997,pages 22 through 241, it would serve no purpose to set Concentration Limits for individual constituents at background levels." This approach is not consistent with the requirements of Title 27,the sources of drinking water policy in State Board Resolution 88-63, or the Basin Plan. The 18 August 1997 correspondence from Kleinfelder cited in the WQPS report provided a cost estimate for groundwater cleanup. The estimate was $2.3 million over a five year period to treat about 500 million gallons of groundwater. The correspondence did not provide an economic analysis nor did it demonstrate that cleanup was not economically or technically feasible. Therefore,the statement in the WQPS report that remediation is not cost effective was not substantiated in a manner that would allow the Board to approve concentration limits greater than background on the basis of economics. In addition,the 18 August 1997 correspondence noted that background water quality was poor with elevated levels of total dissolved solids and chloride. The beneficial uses of drinking water and agricultural supply were considered to not exist in shallow groundwater because it exceeded applicable standards for these two constituents. The correspondence concluded that additional degradation from the lime ponds will not affect these current or future beneficial uses because water quality is already degraded and its beneficial use is diminished. The conclusion that certain beneficial uses do not exist in water that exceeds selected water quality objectives, whether naturally or from other pollution sources, is flawed. So too is the implication that additional degradation from waste disposal units is permissible under these circumstances. State Board California Environmental Protection Agency Co&,ycled Paper