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MARLEY COOLING TOWER *PANY • 8 <br /> GROUNDWATER EXTRACTION-AND TREATMENT SYSTEM <br /> SAN JOAQUIN COUNIY <br /> RESPONSE TO COMMENTS <br /> 30 January 2003 <br /> April I wet period is sulftcient based on the consisten = r":he discharge that has <br /> been demonstrated over the past years and the extens--e rstorical quarterly testing <br /> of the Canal that has verified that there is no impact c- he River. <br /> Response: Sampling in the SDC is also necessary f07 tmsuring compliance with <br /> water quality objectives of the Basin Plan and receiv-_�_water limitations in the TO. <br /> Monitoring of the SDC would not be required when is no flow in the SDC. <br /> 10. Comment: Monitoring and Reporting Program: We 'o not see the need for ., <br /> continued toxicity testing. We have done the required-es ng. The groundwater <br /> quality is very consistent and the groundwater extrac.:n and treatment system <br /> effluent discharge to the Canal has consistently met rrz:ermit parameters. The <br /> extensive aquatic toxicity testing done monthly since:99:has shown that the <br /> discharge meets or exceeds the RWOCB aquatic toxic-: criteria. Therefore, unless <br /> the effluent discharge quality changes which is high%. ::likely, the toxicity testing is <br /> no longer needed. We have established the toxicity q ..-ce _fluent discharge. The <br /> groundwater quality has been well documented and c_ s:ent. The concentrations of <br /> the key contaminants can only go down as the pump-.!.,;rd treating continues to <br /> cleanup the contaminated groundwater. <br /> Response: Sporadic instances of unknown toxicity:: e been reported in short term, <br /> toxicity testing accomplished by MCTC in the past. =er.in the TO has been revised <br /> to indicate the frequency of testing may be reduced tc =ual if toxicity is not <br /> identified after the first year of quarterly monitoring. <br /> 11. Comment: Attachment E: We think that it is inappr:-rye for the regulatory <br /> requirement offour quarterly sampling events of the ent and upstream in the <br /> receiving stream to be included in a five-year perm;:. 5 e have already completed the <br /> three of the four required sampling and analysis even:..=. In addition, we think that the <br /> regulation requiring the testing the MCTC d;scharge_�rparameters such as volatile <br /> organic chemicals, semi-volatile organics, PCBs and esecides that are not used by <br /> or present in the MCTC discharge unfairly burdened'-ICTC with costs unrelated to <br /> the MCTC discharge or operations. <br /> Response: As noted in Finding 17 of the T 0,mor.;:_-_required by Attachment E <br /> is intended to be consistent with, and not duplicative := 10 September 2001 CWC <br /> Section 13267 Letter issued by the Executive Office-. =e study requirement is <br /> necessary of all NPDES dischargers to fulfill requires=n:s of the SIP. The time <br /> schedules provided to conduct the study and to com__.,-.-,-4:h any new limits are based <br /> on the SIP. <br /> B. Comments from Deltakeeper <br /> 1. Comment: The Hearing Notice states that persons -vr:rg to comment on this <br /> noticed hearing must submit comments by 10 Septerr.=er=002 and that comments <br />