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SPX CORPORATION ORDER R5-2019-0018 SPX MARLEY COOLING TECHNOLOGIES GROUNDWATER CLEANUP NPDES NO. CA0081787 limitations is not required to protect beneficial uses. Calculating effluent limitations based on the lowest measured ambient hardness is not required by the CTR or SIP and is not reasonable as it would result in overly conservative limits that will impart substantial costs to the Discharger and ratepayers without providing any additional protection of beneficial uses. In compliance with applicable state and federal regulatory requirements, after considering the entire range of ambient hardness values, Board staff has used the ambient hardness values shown in Table F-6 to calculate the proposed effluent limitations for hardness-dependent metals. The proposed effluent limitations are protective of beneficial uses under all flow conditions. iii. Using an ambient hardness that is higher than the minimum of 56 mg/L will result in limits that may allow increased metals to be discharged to the river, but such discharge is allowed under the State Antidegradation Policy (State Water Board Resolution 68-16). The Central Valley Water Board finds that this degradation is consistent with the antidegradation policy (see antidegradation findings in Section IV.D.4 of the Fact Sheet). The Antidegradation policy requires the Discharger to meet waste discharge requirements which will result in the best practicable treatment or control of the discharge necessary to assure that: a) a pollution or nuisance will not occur, and b) the highest water quality consistent with maximum benefit to the people of the State will be maintained. iv. Using the ambient hardness values shown in Table F-4 is consistent with the CTR and SIP's requirements for developing metals criteria. Table F-4. Summary of CTR Criteria for Hardness-dependent Metals Ambient CTR Criteria CTR Metals Hardness (lag/L, total recoverable)' (mg/L)2,3 acute chronic Copper 123 17 11.1 Chromium III 123 2060 250 Cadmium 89 (acute) 4.0 2.9 123 chronic Lead 89 70 2.7 Nickel 123 560 62 Silver 89 3.3 -- Zinc 123 143 143 ' Metal criteria rounded to two significant figures in accordance with the CTR (40 C.F.R. §131.38(b)(2)). 2 The ambient hardness values in this table represent actual observed receiving water hardness measurements from the dataset shown in Figure F-1. 3 The CTR's hardness dependent metals criteria equations vary differently depending on the metal, which results in differences in the range of ambient hardness values that may be used to develop effluent limitations that are protective of beneficial uses and comply with CTR criteria for all ambient flow conditions. Background The State Water Board provided direction regarding the selection of hardness in two precedential water quality orders; WQO 2008-0008 for the City of Davis Wastewater Treatment Plant (Davis Order) and WQO 2004-0013 for the Yuba City Wastewater Treatment Plant (Yuba City Order). The State Water Board recognized that the SIP ATTACHMENT F- FACT SHEET F-15