SITE INFORMATION AND CORRESPONDENCE_2005-2014

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TIME SCHEDULE ORDER NO.R5-2005- 2 U.S. DEPARTMENT OF DEFENSE DEFENSE LOGISTICS AGENCY DEFENSE DISTRIBUTION DEPOT SAN JOAQUIN SHARPE GROUNDWATER REMEDIATION SYSTEM SAN JOAQUIN COUNTY 3. The effluent limitation specified in Order No. R5-2005-213 for arsenic is based on the Basin Plan chemical constituents objective and the US Environmental Protection Agency(USEPA) Maximum Contaminant Level (MCL). The Discharger has requested an extension on the TO compliance date for the arsenic in order to test and construct, as necessary, sufficient disposal ponds to eliminate all discharge of treated groundwater to local surface waters. NEED FOR TIME SCHEDULE ORDER(TSO) AND LEGAL BASIS 4. The Discharger operates the groundwater treatment system as part of a remedial action to clean groundwater polluted with volatile organic compounds (VOCs). Extracted groundwater is treated by air-stripping. This site is on the USEPA's National Priorities List for cleanup. Cleanup activities for the polluted groundwater began in 1987, and the remediation work is being conducted under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) at the direction of Remedial Project Managers from the Regional Board,USEPA, and the Department of Toxic Substances Control (DTSC). Through operation of this facility, the Discharger has removed a significant amount of the VOC mass from the underlying groundwater. The Discharger expects to test and construct sufficient on-site disposal ponds and eliminate discharge of treated groundwater to surface waters by 23 January 2009. Local shallow groundwater is heavily mineralized and the Discharger's effluent is not expected to adversely impact groundwater quality and will help recharge local groundwater. 5. California Water Code (CWC) Section 13300 states: "Whenever a regional board finds that a discharge of waste is taking place or threatening to take place that violates or will violate requirements prescribed by the regional board, or the state board, or that the waste collection, treatment, or disposal facilities of a discharger are approaching capacity, the board may require the discharger to submit for approval of the board, with such modifications as it may deem necessary, a detailed time schedule of specific actions the discharger shall take in order to correct or prevent a violation of requirements." 6. Federal regulations, 40 CFR Part 122.44 (d)(1)(i),require that NPDES permit effluent limitations must control all pollutants which are or may be discharged at a level which will cause or have the reasonable potential to cause or contribute to an in-stream excursion above any State water quality standard, including any narrative criteria for water quality. Beneficial uses, together with their corresponding water quality objectives or promulgated water quality criteria, can be defined per federal regulations as water quality standards. TP ILA 7. Immediate compliance with the new effluent limitation for arsenic is not possible or practicable. 10 The Clean Water Act and the California Water Code authorize time schedules for achieving compliance as soon as possible,up to a maximum duration of 5 years, which is the maximum term of any NPDES permit.