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30 January 2003 <br /> RESPONSE TO COMME-NTS <br /> 13 and 14 March 2003 MEETING OF THE REGIONAL BOARD <br /> MARLEY COOLING TOWER COMPANY <br /> GROUNDWATER EXTRACTION AND TREATMENT SYSTEM <br /> SAN JOAQL D; COUNTY <br /> TENTATIVE WASTE DISCHARGE REQUIREv1ENTS ORDER <br /> NPDES NO. C A008178 7 <br /> A tentative Waste Discharge Requirements (WDRs) Order, National Pollutant Discharge <br /> Elimination System (NPDES)Permit No. CA0081787 for the Marley Cooling Tower Company, <br /> Groundwater Extraction and Treatment System was circulated to known interested parties for review <br /> and comment on 6 August 2002. Additionally, a Notice of Public Hearing concerning the tentative <br /> Order was posted at the Marley Cooling Tower Facility on 23 January 2003. Comments on the <br /> proposed action by persons or parties who directly received the tentative Order were due 10 <br /> November 2002. Comment letters were received from Deltakeeper (23 September 2002), and the <br /> SPX Corporation,parent of the Marley Cooling Tower Company(10 November 2002). The <br /> Regional Board will include in the administrative record for this matter these written comments. <br /> These comments (paraphrased), and staff responses to these comments, are summarized below-: <br /> A. Comments from the Discharger, SPX Corporation.Marley Cooling Tower Company <br /> I. Comment: Lowering the permit limits for hexm alent chromium (Cr+6) and copper <br /> (Cu) based on the aquatic toxicity of the undiluted.VCTC`wastewater discharge is <br /> unreasonable. In addition, lowering the Total Dissolved Solids limit from 1000 mall <br /> to 500mg/1 will require MCTC to remove the YDS rhat is naturally occurring in the <br /> groundwater, i.e. TDS concentrations in ground:vater are about 500—650 mg/7 as <br /> stated in the NPDES permit and thereby precludes meeting the proposed TDS limit of <br /> 500 mg/1,particularly when ion exchange used to remove the contaminant of the <br /> concern requires small additions ofsalt to regenerate the ion exchange resin. <br /> Lowering the permit limits for Cr- e Cu and YDS are unwarranted as follows: <br /> • Without the MCTC discharge during the period of April Ito October 1 each year <br /> the Stockton Diverting Canal would be dr.- and there would be 100% aquatic <br /> toxicity, i.e. no aquatic organisms would sun-,'ve without water. <br /> Response: As noted in Finding 15 of the Tentative Order (TO), the Stockton <br /> Diverting Canal (SDC), absent the discharge, is at times a seasonal and/or <br /> ephemeral waterbody. This seasonal and/or ephemeral nature of the SDC means <br /> that the designated beneficial uses must be protected,but that no year-round <br /> credit for receiving water dilution is available. Although the discharge, at times, <br /> maintains the aquatic habitat, constituents mai-not be discharged that may cause <br /> harm to aquatic life. At other times, flows � thin the SDC help support aquatic <br /> life. Both conditions may exist x itnin a sho-time span, where the SDC would <br /> be dry without the discharge and.periods when sufficient background flows <br />