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NvIARLEY COOLING TO'WER�.��Y � 10 <br /> GROUNDWATER EXTRACTION AND TREAT�MN'T SYS:_N1 <br /> SAN JOAQUIN COUNTY" <br /> RESPONSE TO COMMENTS <br /> 30 January 2003 <br /> minimization efforts currently underway or completed; (c) a proposed schedule for <br /> additional or future source control measure. Dolluranr minimization actions, or <br /> waste treatment(i.e.faciiiry upgrades); and 'd) a demonstration that the proposed <br /> schedule is as short as practicable. " The dT:nition of practicable" is not what is <br /> simply practical but, rather, what is "technically feasible. " <br /> We can find no informa�on in the Permit : these e.:plicit requirements have been <br /> met. Please provide the date when a com_...mce schedule was requested, <br /> documentation regarding source control--rd or pollution minimization efforts, and <br /> the justification for a :e-year compliance _crtedule. If the discharger failed to <br /> request a compliance schedule and docurr. ::diligent efforts to implement and <br /> quantify source control measures, the com=.-:ante schedule must be placed in a Cease <br /> and Desist Order. In the absence of competing evidence that compliance cannot be <br /> achieved in less than ive years, the time sc.;edule must be shortened. A reasonable <br /> schedule to install and operate a relative?-:small treatment train would likely be one <br /> or two years. <br /> Response: The Disc'arger operates a gro-_d:vater exrsaction and treatment system <br /> as part of an ongoing groundwater correcwe action. During the permit reissuance <br /> process, a new reasonable potential analyses was conducted considering the <br /> requirements of the CTR,NTR, and SIP. Pvor to issuance of the TO, the Discharger <br /> was unaware of the outcome of the reasonable potential analysis, and establishment <br /> of new effluent limitations. The Discharge did not have an opportunity to comment <br /> on Findings in the pe.—Irdt prior to issuance the TO, and has not had an opportunity <br /> to contest items of the T O with which the.: c not agree. The Discharger has made <br /> diligent efforts to quantify pollutant level -d their sources. Source control and/or <br /> pollutant minimization measures are not r-evant to this groundwater remedial action. <br /> Text in the TO has bee:..revised to read the if a compliance schedule justification is <br /> not submitted within 60 days of permit adoption, the final effluent limitations will <br /> become effective on that date. <br /> 4. Comment: The Permit contains an interni performance-based limit and five year <br /> compliance schedule or total dissolved scads pursuant to 40 CFR [Section] 122.47. <br /> However, 40 CFR [Sec:onj 122.47(a)( _:zees that "[ajny schedules' of compliance <br /> under this section sr. require complicr_e ;s soon as possible, but not later than :he <br /> applicable statuton deadline under the C%std. " Please provide justification of why <br /> the discharger is provided a fall five yecrs :o achieve compliance. Major POTW's <br /> successfully complete major upgrades w_i:r.five years. The subject facility is a <br /> small, comparatively simple treatment s:_cam and should be able to achieve <br /> compliance in signipcantly less time. <br /> Response: The Discharger has h:storica:: utilized reverse osmosis as a part of the <br /> designed treatment process to remove g-,=dwater contaminants of concern, <br /> discharging brine the treated water. Also, considering that the concentration of <br /> total dissolved solids; :iocal groundwa:--exceeds the proposed new monthly <br />