FIELD DOCUMENTS AND WORK PLANS 1991

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WASTE DISCHARGE REQUIREMENTS _4- MARLEY COOLING TOWER COMPANY SAN JOAQUIN COUNTY Discharger needs to conduct a Toxicity Reduction Evaluation to determine the cause and develop a corrective action plan. 16. During the first quarter of 1990, the Discharger had repeated violations of Effluent Limitation 1 in Order No. 88-124 for chromium, copper and TDS. The Discharger was notified of the violations by letter dated 12 July 1990. 17. The Discharger was notified by letter dated 1 October 1990, that the RWD generally addressed the concerns associated with the permit violations except for those contingency plans for the operational and monitoring measures to be taken during wet weather events and in case of breakthrough. The Discharger was required to submit revised inserts for the Operation and Maintenance (O&M) Manual for the treatment plant. The 0&M Manual should also address the necessary monitoring of the existing and interim treatment systems to determine removal efficiencies for both treatment systems and to assure compliance of the combined effluent. 18. The Board, on 28 November 1984, ratified a Settlement Agreement between the Department of Health Services, the Discharger and the Board. The Settlement Agreement required the Discharger to conduct a Remedial Investigation/Feasibility Study (RI/FS) to define the extent of contami- nation, to develop Remedial Action Plan (RAP) and to implement all measures necessary to remediate existing site contamination. 19. The RI/FS is essentially complete and the Discharger prepared a Draft RAP for the site. The Department of Health Services modified the Discharger's Draft RAP and on 29 August 1990, following discussions with Board staff, formally adopted the RAP which included the conceptual design of the ground water remedial project. 20. The recommended ground water remedial action in the RAP includes the discharge of up to 0.72 mgd of treated storm water and/or ground water to the Stockton Diverting Canal . In order to minimize the local dewatering of the aquifer caused by overdraft and to restore the aquifer as a usable drinking water source by recharge of the treated ground water and/or storm water, reuse and aquifer reinjection are to be evaluated as viable discharge alternatives. The Discharger has agreed to reevaluate two major discharge alternatives. These alternatives are: a. Discharge to the Stockton Diverting Canal for seasonal agricultural use and infiltration to the underlying aquifer; and b. Reinjection to the aquifer for direct discharge. The RAP anticipates up to 18 months will be required for the Discharger to complete its review of these alternatives.