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MARLEY COOLING TOWS*OMPV: • 5 <br /> GROUNDWATER EXTRACTION AND=2EATMENT SYSTEM <br /> SAN JOAQUIN COUNTY <br /> RESPONSE TO COMMENTS <br /> 30 January 2003 <br /> Effluent Limits Based Upon iVJUNj Beneficial Use <br /> As noted previously, e MUN designation applies to all waters based on <br /> SWRCB Resolution tS-63 "Sources of Drinking Water"Policy, which states that <br /> "all surface and gro- -4 waters of the State are considered to be suitable. or <br /> potentially suitable, =cr municipal or domestic water supply and should be so <br /> designated by the Rezional Boards . . . ". Therefore, the SDC has the designated <br /> beneficial use of IviZ1. Resolution No. 88-63 provides discretion to the Board to <br /> grant exceptions to -_' _ NfUN designation, if the water body fits within one or <br /> more of the excepticrs specified. The Water Code and Resolution 88-63 require <br /> a site-specific Basin?_zn amendment to de-designate the beneficial use of MUN. <br /> The SDC does not ar=ear to fit any of the exceptions to the Sources of Drinking <br /> Water Policy. Howe.-, the TO does provide a time schedule that should allow <br /> the Discharger sufficient time to propose a Basin Plan amendment or otherwise <br /> comply with the pe.—,'t conditions. <br /> At page III-3.00, the Basin Plan provides chemical constituent water quality- <br /> objectives for inland =face waters stating"At a minimum, water designated for <br /> use as domestic or m='cipal supply(MUN) shall not contain concentrations of <br /> chemical constituents :=excess of the maximum contaminant levels (MCL's)..." <br /> Both the state and federal government have promulgated a secondary MCL for <br /> total dissolved solids i-DS) of 500 milligrams per hter(mg/L, ppm). <br /> Considering the ML1-.eneficial use of the SDC, the promulgated MCL, and the <br /> fact that the SDC pre,.:°es little or no dilution for the discharge during many <br /> times of the year, a nc-:: maximum monthly average TDS effluent limitation of <br /> 500 mg/L (ppm) has .-_ea established in the TO. <br /> 2. Comment: Finding 2. V TC has ceased all operations at the facility,except for the <br /> operation of the Ground: =:er Extraction and Treatment System <br /> Response: Comment noted and text changes will be made to the TO reflecting the <br /> change in operations. <br /> 3. Comment: Finding 4. Because an impermeable cap was placed over the <br /> contaminated soil area, ,te 3elieve that the requirement for reinjecting 5% of the <br /> treated water into the sra::ry soil to flush contaminants defeats the purpose of an <br /> impermeable cap and shcu:;:therefore be eliminated. Returning 5% of the treated <br /> water will not have a sigri=cant impact on minimizing the dewatering of the aquifer. <br /> Response: Reinjection o:seated water to flush contaminants from soil is required as <br /> part of the Final Remedic' 4-cion Plan (RAP) dated July 1990. Removal of the soil <br /> flushing requirement ma% `e accomplished through a RAP amendment. Under <br /> separate cover. Marley s'_=_-'d submit a proposal for a RAT amendment to the <br /> Department of Toxic S_'-s-_rces Control and Regional Water Quality-Control Board <br /> for consideration. <br />