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California Regional Water Quality Control Board <br />Central Valley Region (@ <br />. <br />Robert Schneider, Chair Cray Davis <br />Winston It. llickox Go'rnmr <br />Scerciaryfor Sacramento Main Office <br />Environmental Internet Address: http://w .swrcb.ca.gov/mgcb5 <br />Protection 3443 Routicr Road, Suite A, Sacramento, California 95827-3003 FEB 11 2003 <br />Phone (9 16) 255-3000 • FAX (916) 255-3015 <br />February 10, 2003 <br />Mr. David Lieb <br />Marley Cooling Technologies <br />150 North Sinclair Ave. <br />Stockton, CA 95215 <br />ENVIRONMENT HE__i H <br />PERMIT/SERVICES <br />CERTIFIED MAIL <br />#70000520002425714935 <br />NOTICE OF VIOLATION, NATIONAL POLLUTANT DISCHARGE.ELIMINATIONSYSTEM <br />PERMIT NO. C40081787, ORDER NO. 93-221, MARLEY COOLING TOWER COMPANY, SAN <br />JOAQUIN COUNTY <br />Based on our site inspection and review of available data, the Marley Cooling Tower Company (MCTC) <br />has violated specific provisions and limitations in its National Pollutant Discharge Elimination System <br />(NPDES) Order No. 93-221 by causing a fish kill in the Stockton Diverting Canal. This fish kill was a <br />result of a discharge of high pH water from the onsite groundwater treatment system. <br />Background Information <br />On the night of September 16"717`11, 2002 there was a discharge of high pH treated groundwater effluent <br />from the groundwater treatment system at the MCTC site. This high pH discharge in tum raised the pH <br />in the Stockton Diverting Canal, where the treated groundwater is discharged, causing a significant fish <br />kill in the canal. Although no follow-up sampling in the Canal was conducted by MCTC to determine <br />the length of the waterway affected, at least 6,600 feet downstream of the outfall was involved, with the <br />fish kill being probably absolute in that stretch of the waterway, according to DFG staff. According to <br />Department of Fish and Game (DFG) estimates, approximately 1,000 dead fish were noted in the canal, <br />and the total number estimated to be killed was upwards of 4,000 to 5,000. The affected fish included <br />black bass, catfish, carp, suckers, bluegill, and assorted smaller sunfish -type fish. Tadpoles and crayfish <br />were also killed. Although the spill occurred sometime during late September 16th or early September <br />17a', the spill was not reported to our office by MCTC, as required by the NPDES permit, until the early <br />evening of September 19th. The spill was caused by a pH meter malfunction on a meter that controlled <br />the pH adjustment pump. This false pH signal in tum caused the caustic pH adjustment pump to <br />continuously operate despite the fact that the actual pH level was not low. Moreover, because the meter <br />signal was "frozen" and sending a false "low pH" signal, it did not activate the system shutdown feature <br />as it was designed to do. This resulted in a discharge of approximately 2160 gallons (estimated <br />maximum amount) of 50% by weight sodium hydroxide into the canal. The attached Inspection Report <br />California Environmental Protection Agency <br />Za Recycled Paper <br />The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br />For a list of simple ways you can reduce demand and cut your energy costs, see our Web -site at http://w .swrcb.ca.gov/mgcb5 <br />