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Chas. Carnahan -2- Sept. 26, 1969 On May 10, 1969 McCormick and Baxter were again discharging from the sump into Mormon Slough. An analysis of samples collected on May 10 indicates that McCormick and Baxter were in violation of Item 2. (phenolic materials) and again in violation of Item 5 (deleterious materials) of their require- ments. The discharge contained an extremely high level of pentachlorophenol (815 ppm). Mormon Slough near the discharge contained 8.2 ppm pentachlorophenol which greatly exceeds the lethal level to fish. Copper was also present in the discharge and in Mormon Slough in excess of levels found to be lethal to fish. The requirements now in effect on McCormick and Baxter (Resolution 65-44) do not adequately protect fish in Mormon Slough. Adherence to the phenolic level and zinc level in Item 2 of the existing requirements could still allow a fish kill since the allowable levels of thast, items exceed the level found to be lethal to fish. Copper is not included in the existing resolut- ion although on both dates copper was found in the discharge and receiving waters in amounts exceeding the lethal level to fish. We feel that the present waste disposal practices of McCormick and Baxter pose a continual threat to fish life in Mormon Slough. We are, therefore, request- ing your Board to consider chanf;ing the waste discharge requirements of Resolution. 65-1+4 as follo;s: ve recom_mend that Item 2 of Resolution 65-44 be deleted and the following wording be substituted: 2. There shall be no discharge of phenolic materials, arsenic, or heavy metals into Mormon Slough. Sincerely, en Glading Regional Manager Region II cc: Department of Public Health - Sacramento, Berkeley Department of Water Resources Department of Fish & Game, 1 ater Projects Branch :. San Joaquin County Health Department Inspector Hooker, Captain Wictum 1,1ardens Del Nero, Fisher Charles Hazel, Pollution Lab