SITE INFORMATION AND CORRESPONDENCE

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F �• Mr. Tony Martin - 2 - 2 November 1998 Resolution No. 88-63,the sources of drinking water policy, specifies that all surface and ground waters of the state are to be protected as existing or potential sources of municipal and domestic supply. The specific exceptions allowed by the Resolution include waters with existing total dissolved solids concentrations greater than 3,000 mg/l, which is not the case here. The Basin Plan states that controllable factors, such as human activities subject to regulation by this Board, are not allowed to cause further degradation of water quality in instances where uncontrollable factors have already resulted in water quality objectives being exceeded. In an area where background water quality may exceed certain water quality objectives,then the background values become the objectives. This means that while there is no obligation to improve naturally poor water quality, we need to ensure that it is not made any worse by waste constituents from the disposal ponds. Finally,the proposed concentration limit for TDS exceeded its MCL. Title 27 prohibits the Board from setting concentration limits greater than MCLs. We recognize the standard for TDS is a secondary MCL, but Title 27 makes no distinction between primary and secondary MCLS. Given the pending groundwater investigation at the facility, I suggest we postpone further discussion of concentration limits until additional information is available. The 18 August 1997 correspondence includes a comment [page 25, item 5] that present groundwater concentrations would decrease naturally over a period of 3 to 5 years. If it can be demonstrated that contaminant levels will decrease to background concentrations in that time period,then there may be no need to set concentration limits greater than background. The facility's WDRs include a due date of 1 July 1998 for submittal of a corrective action plan in compliance with Title 27. This due date can only be revised by the Board through the adoption of a revised order. Given that much of the effort at the site since adoption of the WDRs has been focused on proper management of the lime waste piles, it seems reasonable to me that we delay submittal of corrective action plan until after installation of the wells and additional removal of the lime waste. The WDRs need to be revised by the Board to reflect the change in ownership at the facility. The due date for the corrective action plan can be changed at the same time. We can discuss new submittal dates during preparation of the revised order. If you have any questions, please call me at(916) 255-3131. 4-0� STEVE E. ROSENBAUM Associate Engineering Geologist SER cc: Mr. Ron Rowe, San Joaquin County Public Health Services, Stockton Mr. Bing Kirk,Atherton Kirk Development Company, Stockton