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MARLEY COOLING TOWER*vIPANY , 6 <br /> GROUNDWATER EXTRACTION AND TREATMENT SYSTEM <br /> SAN JOAQUIN COUNTY <br /> RESPONSE TO COMMENTS <br /> 30 January 2003 <br /> 4. Comment: Finding 19. The Stockton Diverting C.:7:_:'is a man-made canal <br /> constructed to divert the natural river flow to protiice irrigation water and flood <br /> control from October 1 to April 1 of each year. Dung the period from April I to <br /> October I of each year the Stockton Diverting Can:::has limited or no flow except for <br /> the 111ICTC Stockton CA wastewater discharge. If rhe MCTC, Stockton CA facility <br /> wastewater discharge were eliminated there would be no aquatic organisms because <br /> 'there would be insufficient water to support aqua:c fe. Therefore, we believe that <br /> establishing the effluent limits for Copper (Cu) base" on the acute and/or chronic <br /> aquatic life toxicity without the dilution is inapprcpr'ate. The dilution factor of the <br /> Calaveras River should be the appropriate dilurior-jactor, i.e. the point at which the <br /> Canal reconnects with the Calaveras River. The punose of the groundwater <br /> extraction and treatment system is to cleanup the groundwater and capping the <br /> contaminated soil areas was intended to prevent s:ormwater contamination. In fact, a <br /> pilot test of an insitu groundwater treatment is piar-r-ed that may lead to cleanup of <br /> the contaminated groundwater to meet the grour-c--a:er quality criteria in the next <br /> few years. The discharge will then cease and the S:cckton Diverting Canal will be dry <br /> each year during April 1 to October 1. We do no: ceieve that MCTC should be <br /> required to maintain an unnatural aquatic environment. Therefore, we don't think <br /> that it is appropriate to impose the Cu limit based on acute and chronic aquatic <br /> toxicity criteria for the undiluted waste discharge. !?: addition, aquatic toxicity testing <br /> to date has demonstrated that the discharge cons :tly meets the criteria. <br /> Response: See response to Comment 1. Also, taeSeptember 2002 incident involving <br /> the accidental discharge of effluent with an elect a j+H and the associated reported <br /> fish kill is additional evidence that there is viable hLlitat and aquatic life in the SDC, <br /> which can be impacted by the quality of effluent discharged by the MCTC. <br /> 5. Comment: Finding 20. Our objections to the pro-rosed new limit Cr+6 based on the <br /> acute and chronic aquatic toxicity are the same as fur objections for the proposed <br /> new Cu limit. <br /> Response: See response to Comment 1. <br /> 6. Comment: The monitoring requirements are e;_-a__:Ve and unnecessary particularly <br /> considering the extensive history of monitoring:_ :e, and the consistent compliance <br /> with existing permit discharge limits. <br /> Response: Monitoring requirements in this TO. i=cisding the selection of parameters <br /> and their sampling frequency, are designed to asses- compliance with effluent and <br /> receiving water limitations. In response to this cc­ment, the sampling frequencies <br /> for some of the parameters were re-evaluated and-ve been revised. The revised <br /> sampling frequencies are included as Attachmear '. The selected constituents and <br />