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Report of Waste Discharge -2- 30 September 1991 <br /> Marley Cooling Tower Company <br /> RWD must provide estimates of the flows to the Stockton Diverting Canal and to <br /> the subsurface soil flushing system. <br /> We remain extremely concerned that there continues to be violations of the <br /> effluent limits despite the installation of the parallel electrochemical <br /> reduction and precipitation system this past winter. During the last year, a <br /> significant number of violations have occurred, as shown in the enclosed table. <br /> However, we believe that significant impacts on the receiving water have not <br /> occurred due to the no flow conditions in the canal . <br /> We recognize that Marley is committed to the cleanup of the site. However, <br /> repeated violations of your NPDES permit indicate that Marley needs to take <br /> additional steps in the areas of a reevaluation of staffing needs, additional <br /> training and equipment and other technical back-up measures for the existing <br /> treatment systems. These minimal measures need to be provided prior to system <br /> automation. Your RWD must therefore, include a revised and detailed operational <br /> plan showing how the treatment systems will meet effluent requirements on a <br /> consistent basis. The plan must also show the commitment by Marley to allocate <br /> adequate resources for staff, training and other technical back-up measures. The <br /> operation plan must be updated when the treatment system is automated to provide <br /> for a smooth transition and to assure consistent compliance with the permit. <br /> You have requested that the effluent limits for arsenic, copper . and total <br /> dissolved solids be relaxed in the revised permit. We are currently reviewing <br /> the effluent limits in the existing permit and will consider your concerns, in <br /> addition to the recently adopted Inland Surface Waters Plan, in revising the <br /> limits. Therefore, the RWD should include the most recent available water <br /> quality data of the receiving water, including general minerals and heavy metals, <br /> upstream of the discharge. This information will be used to assess the potential <br /> impact of the discharge on the receiving water. <br /> I��ffyou have any questions, please call me at (916)361-5670. <br /> Titti7'lLGG�.tL`G(�i+��^;�/JYGO/ <br /> CAMILLA WILLIAMS <br /> Engineering Geologist <br /> CKW:cw <br /> Enclosure <br /> cc: Mr. Jim Austreng, Department of Toxic Substances Control , Region 1, <br /> Sacramento <br /> Mr. Ron Valenoti , San Joaquin County of Public Health Services, Stockton <br /> Mr. Tom Hickey, Black and Veatch, Kansas City, Missouri <br />