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MARLEY COOLING TOWER COMPANY 2 23 March 1994 SITE INSPECTION - NPDES COMPLIANCE It was agreed in the meeting, if the relative volumes of water processed through the two treatment systems varies by more that 10% then a notation will be made in the text of the monthly report to call attention to the variation. Due to some of the changes of which are described herein, the permit reporting will be somewhat unconventional for the month of October. A sample format was handed out during the meeting that is acceptable for future use of monthly reporting. Part of the forms included a description of the receiving water conditions. There was a question regarding quarterly sampling of the receiving water and how to fulfill this requirement, knowing that flow in the Stockton Diverting canal usually is intermittent. We discussed that during the first two months of each quarter a sample can be drawn to meet the quarterly sampling requirements. If there is no flow in the canal during the first two months of a quarter, then in the final month of the quarter a storm event occurs resulting in flow in the canal which would facilitate a sample, then a notation in the report should be made as to the timing of the flow event and the results of the lab analysis would be reported the following month. If no flow occurs during the entire quarter then this explanation for no sample is adequate for reporting. In the permit under Discharge Prohibitions, item 4, reference is made to hazardous substances listed in 40 CFR Part 117 and/or 40 CFR Part 302. The intent of this item is to prohibit any discharge other than those regulated in the NPDES permit. The sludge disposal plan required to be submitted by 1 April 1994 should include proposed number of samples, laboratory analysis, and QA/QC procedures. The plan should describe the treatment process and slude management from generation to disposal. Any attempts to reduce the volume and/or weight of the sludge should also be addressed in this plan. Mr. Bates requested that I send him a copy of Chapter 15, Division 3, Title 23, as quoted in the permit with regard to sludge disposal. This document is attached. Bioassay samples were proposed to be collected from the effluent water as follows: acute bioassays conducted in January, May, July and November and chronic bioassays in March and September. This sampling strategy meets the intent of the NPDES permit. After meeting we conducted a brief site inspection of the treatment plant noting where new composite samplers will be located after the flow equalization basin and the influent holding tank. We walked out to the northern edge of the property where the sampling port for the combined effluent is to be taken, this is also the point in the system where water for the injection/soil flushing system is pumped to the holding tanks located above the retort pit. Finally, we went out to the out fall point at the diverting canal. The effluent appeared to be clear creating a pool of water in the canal from which a small streamlet could be seen flowing down the center of the canal and past the Fremont Street bridge. The effluent piping does not need modification to handle the increase in flow as it was originally sized with the expansion in mind. cic