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SPX CORPORATION ORDER R5-2019-0018 SPX MARLEY COOLING TECHNOLOGIES GROUNDWATER CLEANUP NPDES NO. CA0081787 Table F-6. Verification of CTR Compliance for Silver Receiving water hardness used to compute effluent limitations 56 mg/L Effluent Concentration Allowance (ECA) for Silver' 3.3 pg/L Downstream Ambient Concentrations Under Worst- Case Ambient ReceivingWater Conditions Ambient Silver Complies with CTR Criteria Concentration CTR Criteria? Hardness /L (pg/L) 1Q10 124 5.9 3.3 Yes 7Q10 124 5.9 3.3 Yes Max receiving water flow 56 1.5 1.5 Yes ' The ECA defines effluent quality necessary to meet the CTR criteria in the receiving water. There is no effluent limitation for silver as it demonstrates no reasonable potential. 2 This concentration is derived using worst-case ambient conditions. These conservative assumptions will ensure that the receiving water always complies with CTR criteria. 3. Determining the Need for WQBEL's Clean Water Act section 301(b)(1)(C) requires effluent limitations necessary to meet water quality standards, and 40 C.F.R. § 122.44(d) requires NPDES permits to include conditions that are necessary to achieve water quality standards established under section 303 of the CWA, including State narrative criteria for water quality. Federal regulations at 40 C.F.R 122.44(d)(1)(i) state, "Limitations must control all pollutants or pollutant parameters (either conventional, nonconventional, or toxic pollutants) which the Director determines are or may be discharged at a level that will cause, have the reasonable potential to cause, or contribute to an excursion above any State water quality standard, including State narrative criteria for water quality." Additionally, 40 C.F.R. section 122(d)(1)(vii) requires effluent limits to be developed consistent with any available wasteload allocations developed and approved for the discharge. The process to determine whether a WQBEL is required as described in 40 C.F.R. § 122.44(d)(1)(i) is referred to as a reasonable potential analysis or RPA. Central Valley Water Board staff conducted RPA's for nearly 200 constituents, including the 126 U.S. EPA priority toxic pollutants. This section includes details of the RPA's for constituents of concern for the Facility. The entire RPA is included in the administrative record and a summary of the constituents of concern is provided in Attachment G. For priority pollutants, the SIP dictates the procedures for conducting the RPA. For non-priority pollutants the Central Valley Water Board is not restricted to one particular RPA method, therefore, the RPA's have been conducted based on EPA guidance considering multiple lines of evidence and the site-specific conditions of the discharge. a. Constituents with No Reasonable Potential. Central Valley Water Board staff conducted reasonable potential analyses for nearly 200 constituents, including the 126 U.S. EPA priority toxic pollutants. All reasonable potential analyses are included in the administrative record and a summary of the constituents of concern is provided in Attachment G. WQBEL's are not included in this Order for constituents that do not demonstrate reasonable potential to cause or contribute to an instream excursion of an applicable water quality objective; however, monitoring ATTACHMENT F— FACT SHEET F-21