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SPX Corporation influent testing is no longer necessary should be eliminated. The groundwater =onitoring provides sufficient information of the influent water quality. We request that the requirement for fifluent monitoring be removed. We will monitor the influent as needed to investigate the rare occ_ence of a permit exceedance. > Effluent Monitoring: Because we are pumping primarily groundwater. we do not*�fiat analyzing the effluent for the general parameters, i.e. electrical conductivity, temperature, disso::—d oxygen. chlorine (C12), hardness, total suspended solids (TSS) and turbidity is necessary. Monitoring --or these parameters provides no useful information to meeting the discharge requirements but adds sub=-dal cost. TSS and turbidity are not an issue with groundwater at this site as the extensive monitoring t,; demonstrated over the many years of monitoring. C12 is not found in the groundwater and monitoring for C_- is unquestionably not necessary. Dissolved oxygen, hardness and temperature in groundwater are ver: c_otm, as monitoring to date has amply demonstrated. We see no reason to continue to collect data : ssttply verifies the consistency of the groundwater quality and adds no value to the protection of the en _- tent. > Stockton Diverting Canal Sampling: Quarterly sampling of the Stockton Diver Canal is excessive based on the extensive testing of the Canal over the past ten years. During the period cf April 1 to October 1, the RWQCB states that there is limited or no flow in the Canal except for tLbre MCTC discharge. Consequently,the effluent monitoring of the MCTC discharge should be representative of the water quality in the Canal. Secondly, monitoring the Canal once during the October 1 to April 1 a::period is sufficient based on the consistency of the discharge that has been demonstrated over the past y=ss and the extensive historical quarterly testing of the Canal that has verified that there is no impact on the 2ver. > Toxicity Testing: We do not see the need for continued toxicity testing. We have dole-e required testing. The groundwater quality is very consistent and the groundwater extraction and 7e_-:at system effluent discharge to the Canal has consistently met the permit parameters. The extensive ac=dc toxicity testing done monthly since 1995 has shown that the discharge meets or exceeds the RW- CB aquatic toxicity criteria. Therefore, unless the effluent discharge quality changes which is highly -zLikely, the toxicity testing is no longer needed. We have established the toxicity of the effluent discha,__. The groundwater quality has been well documented and consistent. The concentrations of the key con>�nants can only go down as the pumping and treating continues to cleanup the contaminated groundwater. > Attachment E: We think that it is inappropriate for the regulatory requirement of.56=quarterly sampling events of the effluent and upstream in the receiving stream to be included in a five -y,- permit. We have already completed the three of the four required sampling and analysis events. In add=,n. we think that the regulation requiring the testing the MCTC discharge for parameters such as volar.: :irganic chemicals, semi-volatile organics, PCBs and pesticides that are not used by or present in the MC7_- discharge unfairly burdened MCTC with costs unrelated to the MCTC discharge or operations. We hope that the RWQCB favorably considers our comments and thereby, makes the ice: permit conditions address the true environmental issues associated with MCTC wastewater discharge to the Stock-on Diverting Canal. If you have any questions,please contact me at(704) 752-4430. Sincerely, Cc: Dave Lieb (MCTC, Stockton CA) Karl Lytz(Latham&Watkins, John Burtis Page l of e C.% DMWS\TE,%IMdnR NPDES wm nts.dm