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STATE OF CALIFORNIA-Environmental Protectisent;y PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION 'p`I;? kt s Al 3443 Routier Road, Suite A i pM. +` s T`4L i �hL�' Sacramento, CA 95827-3098 '. .' ';,CE " PHONE: (916)255-3000 93 Jvt hn r`l 8 !+ r FAX: (916)255-3015 f 1 J' 16 June 1993 Mr. Gabe Karam Department of Public Works County of San Joaquin 1810 East Hazelton Avenue Stockton, CA 95205-6232 DRAFT EIR FOR LOVELACE TRANSFER STATION EXPANSION We have reviewed the Draft Environmental Impact Report (Draft EIR) for the expansion of Lovelace Transfer Station and are concerned about two issues regarding the project. The first issue is the discharge into the unlined retention pond. The major concern is whether or not any constituents in the facility washdown water or constituents picked up by stormwater runoff are present above designated waste levels. In our 18 May 1990 letter to your office, we stated that the County would have to determine if the discharge to the pond was a designated waste. To date, the County has not submitted a document stating the discharge is not a designated waste. In a 27 May 1993 phone conversation, you indicated that a separate tank would contain the facility washdown water for management at an on-site or off-site treatment facility. Therefore, only stormwater runoff will be discharged into the retention pond. The County still needs to determine if the stormwater discharge is a designated waste. We would also like to see the plans for the collection and treatment system for the washdown water. The second issue is the disturbance of an old existing landfill at the site. Our office was unaware that this landfill existed. The County's proposed mitigation is to remove all wastes within five feet of the proposed structure as recommended in the 7 January 1993 Kleinfelder geotechnical report and take these wastes to an approved landfill . The Draft EIR was not specific as to the volume of waste to be removed from the site. The County should send a letter to us stating the volume and description of the waste and which landfill received the wastes. At this time, we will not write waste discharge requirements for the expansion of the Lovelace Transfer Station. However, if future information indicates that waste discharge requirements are necessary, we will request a Report of Waste Discharge for the facility.