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v1ARLEYCOOLING TOWPO-PANY • <br /> GROUNDWATER)='-TRACTION A:NID TREATMENT SYSTEM 3 <br /> SA-N JOAQUIN COL-NTY <br /> RESPONSE TO CONL\, EN'TS <br /> 30 January 2003 <br /> • A-,licatior or' the drinking water standards to the Stockton Diverting Cana.' <br /> rr�.,ces no sense. To the best of our knowledge no drinking water intakes are <br /> downstream of the _dCTC discharge. The Canal is essentially dry during 6 <br /> months of the year and therefore the Canal is an unreliable drinking water <br /> sz�Dvly. <br /> • Groundwater is a source of drinking and irrigation water supplies downstream of <br /> AfCTC discharge and in the vicinity of the Stockton Diverting Canal and the <br /> AfCTCfacil: ;. As the RWOCB has noted during the dry period the MCTC <br /> dscharge e:---orates and/or percolates to the groundwater, wrich is a source of <br /> drinking and irrigation water. The RWQCB also agrees that the naturally <br /> occurring groundwater 7DS levels are higher than the 500 mg,!1 limit proposed <br /> for the MCTC wastewater discharge permit. If the groundwater that is used for <br /> drinking and irrigation has YDS levels greater than 500 me-/1, it makes no sense <br /> for RWQCB to require the MCTC discharge cleanup the naturally occurring <br /> levels of YDS that obviously have not adversely impacted the use ofgroundwater <br /> for drinking and irrigation. <br /> Response: <br /> Beneficial Uses of the SDC: Municipal and domestic water supply, agricultural <br /> supply, including both irrigation and stock watering, warm freshwater habitat, <br /> cold freshw-a:er habitat, warm and cold migration of aquatic organisms, warm and <br /> cold habitat spawning,reproduction, and/or early development, and wildlife <br /> habitat are icF::fied in the Basin Plan as existing beneficial uses of the Calaveras <br /> R :-er, from Nem Hogan Reservoir to the Delta. As noted in the Findings of the <br /> TO, the SDC s tributary to the Calaveras River. <br /> In compliance with state and federal law, the Regional Board staff applied the <br /> beneficial uses of the Calaveras River to the SDC as specified in the Basin Plan, <br /> State Board Resolution 88-63, and the Clean Water Act. Due to the <br /> impracticabiLry of designating the beneficial uses of all water bodies, the <br /> Regional Boar's Basin Plan contains the so-called "tributary rule". To <br /> implement tt-s ,rovision, the Regional Board staff evaluared whether, based on <br /> the available W=ormation, the unidentified water body (SDC) has the beneficial <br /> uses of the id- fied downstream water body. EPA regulations at 40 CFR <br /> section 131.10 require the state to specify the beneficial uses to be achieved and <br /> protected, including public water supplies, protection and propagation of fish and <br /> wildlife, recreation, agriculture, industry, navigation, and other uses. The <br /> tributary rule was applied, in part, based on the fact that the Clean Water Act <br /> Section 101(e, establishes an interim goal of protecting fish and wildlife and <br /> recreation uses. Regardless of state-designated uses, the states must protect those <br /> uses. Aquatic s ecies can and likely do move in and out of the SDC depending <br /> upon seasonal =ow and water quality conditions. Evidence from the recent <br /> incident involing the release of caustic materials revealed that there is substantial <br />