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SPX CORPORATION ORDER R5-2019-0018 <br /> SPX MARLEY COOLING TECHNOLOGIES GROUNDWATER CLEANUP NPDES NO. CA0081787 <br /> reasonable potential to cause, or contribute to an excursion above any <br /> State water quality standard, including State narrative criteria for water <br /> quality." For priority pollutants, the SIP dictates the procedures for <br /> conducting the RPA. pH is not a priority pollutant. Therefore, the Central <br /> Valley Water Board is not restricted to one particular RPA method. Due to <br /> the site-specific conditions of the discharge, the Central Valley Water <br /> Board has used its judgment in determining the appropriate method for <br /> conducting the RPA for this non-priority pollutant constituent. <br /> USEPA's September 2010 NPDES Permit Writer's Manual, page 6-30, <br /> states, "State implementation procedures might allow, or even require, a <br /> permit writer to determine reasonable potential through a qualitative <br /> assessment process without using available facility-specific effluent <br /> monitoring data or when such data are not available...A permitting <br /> authority might also determine that WQBELs are required for specific <br /> pollutants for all facilities that exhibit certain operational or discharge <br /> characteristics (e.g., WQBELs for pathogens in all permits for POTWs <br /> discharging to contact recreational waters)." USEPA's TSD also <br /> recommends that factors other than effluent data should be considered in <br /> the RPA, "When determining whether or not a discharge causes, has the <br /> reasonable potential to cause, or contributes to an excursion of a numeric <br /> or narrative water quality criterion for individual toxicants or for toxicity, the <br /> regulatory authority can use a variety of factors and information where <br /> facility-specific effluent monitoring data are unavailable. These factors <br /> also should be considered with available effluent monitoring data." (TSD, <br /> p. 50) <br /> The Facility is a ground water extraction and treatment system that treats <br /> contaminated groundwater. Although the Discharger has proper pH <br /> controls in place, the pH for the Facility's influent varies due to the nature <br /> of the groundwater being treated, which provides the basis for the <br /> discharge to have a reasonable potential to cause or contribute to an in- <br /> stream excursion above the Basin Plan's numeric objective for pH in the <br /> receiving water. Therefore, WQBELs for pH are required in this Order. <br /> (c) WQBEL's. Effluent limitations for pH of 6.5 as an instantaneous minimum <br /> and 8.5 as an instantaneous maximum are included in this Order based <br /> on protection of the Basin Plan objectives for pH. <br /> (d) Plant Performance and Attainability. Based on available effluent pH <br /> data, it appears the Discharger is able to comply with these limitations. <br /> The Central Valley Water Board concludes, therefore, that immediate <br /> compliance with these effluent limitations is feasible. <br /> 4. WQBEL Calculations <br /> a. This Order includes WQBEL's for electrical conductivity, copper, chromium VI, and <br /> pH. The general methodology for calculating WQBEL's based on the different <br /> criteria/objectives is described in subsections IV.C.4.b through e, below. See <br /> Attachment H for the WQBEL calculations. <br /> b. Effluent Concentration Allowance. For each water quality criterion/objective, the <br /> ECA is calculated using the following steady-state mass balance equation from <br /> ATTACHMENT F- FACT SHEET F-27 <br />