FIELD DOCUMENTS_2000-2003 - Laserfiche WebLink

Home Browse Search

SPX Corporation VIA OVERNIGHT INUIT. Daniel McGrade Director, Environmental,Health&Safery SPX Corporation November 10, 2002 13515 Ballantyne Corporate Place Charlotte,NC 28277 John Russell Tel:(704)752-4430 Senior Engineer Fax:(704)752-7435 California Regional Water Quality Control Board Central Valley 3443 Routier,Road Suite A Sacramento, CA 95827-3003 Re: Marley Cooling Tower Company, Stockton CA Groundwater Extraction and Treatment System Order No. R5-2002-X0CXX/1NPDES No. CA0081787 Comments on Tentative Wastewater Discharge Requirements Dear Mr. Russell: I am submitting comments on the above captioned Tentative NPDES/vVastewater Discharae Permit for-^:e Marlev Cooling Tower, Stockton CA on behalf of SPX Corporation, the parent of Marley Cooling Tow:- Company (MCTC). We have reviewed the tentative wastewater discharge requirements and believe that '-e _onitorin4 requirements are excessive and unnecessary particularly considering the extensive history of monitoring-.o date, the consistent compliance with existing permit discharge limits except for the recent unfortunate malfimcton of the pH meter and the reduction in the extent of the groundwater plume of contamination exceeding the grotmdwater cleanup standards. We have taken the necessary steps to assure that there will not be a recurrence of the pH meter malfunction. Our comments are not directed at the pH limits or the pH monitoring requirements. We are commenting on the draft permit conditions, limits and monitoring requirements, other _an pH. In particular, we think that lowering the permit limits for hexavalent chromium (Cr+6) and copper (Cu) used on the aquatic toxicity of the undiluted MCTC wastewater discharge is unreasonable. In addition, lower^g :l:e Toral Dissolved Solids limit from 1000 mg/l to 500mg/l will require MCTC to remove the TDS that is niarz-a-1.,occurring in the groundwater, i.e. TDS concentrations in groundwater are about 500 - 650 mg/l as stated �_e V'PDES permit and thereby precludes meeting the proposed TDS limit of 500 mg/l, particularly when ion exc=a-a_e used to remove the contaminant of the concern requires small additions of salt to regenerate the ion exchange resin. We believe that lowering the permit limits for Cr+6, Cu and TDS are unwarranted as follows: - ✓ Without the MCTC discharge during the period of April 1 to October 1 each year the Stockton Diverting Canal would be dry and there would be 100% aquatic toxicity, i.e. no aquatic organisms would survive without water. ✓ Aquatic toxicity testing conducted since 1995 has shown that the MCTC discharge consisre-nw meets the aquatic toxicity criteria. - ✓ The RQWCB set the original TDS permit limit at 500 mg/1 and subsequently raised the limit to 11000 m21 because the groundwater had naturally occurring levels of TDS higher than 500 mgl. ✓ The RWQCB presents no factual data that the 1000 mg/l TDS adversely affects agricultural crops. The RWQCB simply states "its presence can be growth limiting to certain agricultural crops". In :act, based on the RWQCB description of the Stockton Diverting Canal, during the dry period when the MCTC is the only water in the Canal we find it difficult to imagine that after evaporation and percolation. :Hat there is sufficient water for irrigation use. ✓ The TDS limit should be based on the dilution during the period when the Calaveras Rive: s diverted through the Canal. The RWQCB states that they are required to apply the beneficial uses of municipal and domestic supply to the Stockton Diverting Canal because State Board Resolution No. 88-63 was Page t of 4 C:\WINDOW$\TEMP AYPDU oomrtrtm_doo DI/I7/0J