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CENTRAL VALLE i REGIONAL WATER QUALITY . ONTROL BOARD SITE: LOCATION & COUNTY CONTACT(S): INSPECTION DATE: INSPECTED BY: INSPECTI=REPORT Marley Cooling Tower Company, Groundwater Treatment System Stockton, San Joaquin County David Lieb, Marley Cooling Tower Company 20 September 2002, plus follow-up visits on 23 and 24 September 2002 John Russell, SEG, DoD/Clean-Up Section Antonia K. J. Vorster, SWRCE, DoD/Clean-Up Section On the night/early morning of September 16`h/17`h, 2002 there was a discharge of high pH treated groundwater effluent from the groundwater treatment system at the Marley Cooling Tower Company (MCTC) site. This high pH discharge in tum raised the pH in the Stockton Diverting Canal, where the treated groundwater is discharged, causing a significant fish kill in the canal. Although no follow-up sampling in the Canal was conducted by MCTC to determine the length of the waterway affected, at least 6,600 feet downstream of the outfall was involved, with the fish kill being probably absolute in that stretch of the waterway, according to Department of Fish and Game (DFG) staff. According to DFG estimates, approximately 1,000 dead fish were noted, and the total number estimated to be killed was upwards of 4,000 to 5,000. The affected fish included black bass, catfish, buffalo carp, Sacramento suckers, bluegill, and assorted smaller sunfish -type fish. Tadpoles and crayfish were also killed. Although the spill occurred sometime during late September 16`h or early September 17'h, the spill was not reported to our office by the MCTC, as required by the NPDES permit, until the early evening of September 19`'. The spill was caused by a pH meter malfunction on a meter that controlled the pH adjustment pump. This false pH signal in tum caused the caustic pH adjustment pump to continuously operate despite the fact that the actual pH level was not low. Moreover, because the meter signal was "frozen" and sending a false "low pH" signal, it did not activate the system shutdown feature as it was designed to do. This resulted in a discharge of approximately 2160 gallons (estimated maximum amount) of 50% by weight sodium hydroxide into the canal. The attached Figure 1 shows a map of the area of interest including the reference locations discussed later in this report. The inspection indicates that the MCTC has violated specific provisions and limitations in its National Pollutant Discharge Elimination System (NPDES) Order No. 93-221, which resulted in the fish kill in the Stockton Diverting Canal. MCTC has also violated specific provisions and limitations in the Standard Provisions And Reporting Requirements For Waste Discharge Requirements (National Pollutant Discharge Elimination System), dated 1 March 1991. These violations were not reported to our office as required by the permit. Background Information: The MCTC owns and operated a cooling tower fabrication plant in the East Stockton Area in San Joaquin County. As part of the fabrication operations, MCTC operated a wood preservation process utilizing solutions containing copper, chromium and arsenic. Wood preserving was discontinued at this facility in January 1991, however past operational practices have resulted in contamination of soils and groundwater underlying the site. Soils have been contaminated with copper, chromium, and arsenic; groundwater has been polluted with