FIELD DOCUMENTS AND WORK PLANS 2000-2003

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WASTE DISCHARGE REQUINMENTS ORDER NO.R5-2002-XXXX 10 MARLEY COOLING TOWER COMPANY SAN JOAQUIN COUNTY 23. Previous Order No. 93-221 included a daily maximum and monthly average effluent limitation of 1000 mg/L (ppm) for Total Dissolved Solids (TDS). Concentrations of Total Dissolved Solids (TDS) in extracted groundwater range from 330 to 860 mg/L (ppm). As a result of the treatment process, final effluent concentrations of TDS at Outfall 001 have been reported as high as 976 mg/L(ppm) (10115101). For Chemical Constituents at page 1II-3.00, the Basin Plan states `At a minimum, water designated for use as domestic or municipal supply(MRN)shall not contain concentrations of chemical constituents in excess of the maximum contaminant levels (MCLS) specified in the following provisions of Title 22 of the California Code of Regulations...' As a result, and considering the fact that the Stockton Diverting Canal has, at times, little or no flow and therefore provides little or no dilution, this Order includes a new 500 mg/L (ppm) monthly average effluent limitation for TDS applied at the point of discharge which is necessary to comply with the secondary California MCLS contained in Title 22, California Code of Regulations (CCR) and incorporated as chemical constituent water quality objectives in the Basin Plan. There are no USEPA TDS water quality criteria for protection of aquatic organisms. However, its presence can be growth limiting to certain agricultural crops and TDS affects the taste of water for human consumption. The Regional Board has considered the factors specified in California Water Code (CWC) Section 13263, including considering the provisions of CWC Section 13241 where appropriate. The Regional Board is not required to consider the factors in CWC Section 13241 in applying existing water quality objectives of the Basin Plan, including adopting the new monthly average TDS effluent limitation in this Order. The Regional Board must implement the CWC consistent with the Clean Water Act (CWA). The CWA precludes the consideration of costs when developing effluent limitations for NPDES permits necessary to implement water quality standards (See Ackels v. EPA(91h Cir. 1993) 7 F.3d 862, 865-66). The Regional Board may consider costs in developing compliance schedules. The Regional Board finds, on balance, that these requirements are necessary to protect the beneficial uses of the Stockton Diverting Canal and the Calaveras River. This Order provides for time schedules for meeting this new average monthly effluent limitation. Time schedules are authorized to be included in this Order based upon 40 CFR Section 122.47. Currently, monthly average concentrations of TDS in the final effluent exceed the new effluent limitation established in this Order. As this is a new effluent limitation, the Discharger has not had an opportunity to provide a cost estimate for additional treatment or alternative disposal methods which may be necessary to comply with this limitation. A time schedule for compliance with this new TDS effluent limitations is provided in a Provision of this Order. In the interim, this Order retains the average monthly limitation for TDS in the previous Order of 1000 mg/L(ppm), as results of monitoring indicate the Discharger is capable of meeting this existing limitation. 24. Results of monitoring submitted by the Discharger for the period of January 2001 through May 2002 indicate effluent chlorine residual concentrations have ranged from less than detectable concentrations to 0.2 milligrams per liter(ppm) (13 June 2001).