FIELD DOCUMENTS AND WORK PLANS 1990

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• MEMORANDUM * CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: Antonia K. J. Vorster -GEN E ROM: John J. Tomko Senior Engineer H Associate Engineer San Joaquin Regulatory JUL 2 3 1990 tNVPERMIT/SERVICESLTH DATE: 15 July 1990 SIGNATURE: SUBJECT: REPORT OF WASTE DISCHARGE, MARLEY COOLING TOWER COMPANY, SAN JOAQUIN COUNTY I talked to Mr. Tom Hickey of Black and Veatch on 13 July 1990 regarding the informational requirements of the Report of Waste Discharge for the Marley Cooling Tower Company (Marley) . I informed him that I would summarize the discussion in writing and send him a copy as soon as possible. Marley intends to commence the operation of their interim groundwater extraction system, to control the migration of contaminants at the North Yard and at the downgradient plume perimeter, by October of this year. At the North Yard they intend to discharge treated (onsite treatment) groundwater to the Diverting Canal . At the plume perimeter they plan to discharge untreated groundwater to the SRWCF sewerage system. The time schedule in the RAP, for the final system, calls for design to be completed by December of 1990, with commencement of operations in September 1991. I informed Mr. Hickey that the Regional Board will consider modifying the existing NPDES permit to allow the discharge of additional flows to the Diverting Canal on a conditional basis only. I discussed with him the reservations staff has had with the alternative analyses of groundwater disposal alternatives in the RAP (RAP comment letters dated 1 December 1989 and 19 June 1990) . I also informed him that the permit will contain a provision requiring a reevaluation of disposal alternatives and the conductance of a small scale reinjection well test. The specific information requirements discussed with Mr. Hickey included the following: 1) A complete description of the proposed interim and final groundwater remedial schemes (including the discharge to the SRWCF) including flows, waste characteristics, disposal methods and locations of discharge, proposed treatment units, time schedules, and a discussion of the potential impacts to the beneficial uses of the receiving water due to the proposed increase in the discharge to the Diverting Canal . 2) Plans and time schedule to conduct a reevaluation of the groundwater disposal alternatives to address the Regional Board concerns regarding reuse/reinjection. Including a workplan and implementation schedule for a small scale reinjection well test to determine the technical and economic feasibility of reinjection. This reevaluation must consider the entire groundwater extraction flow (including the interim discharge to the SRWCF) , and existing plant operation and stormwater flows.