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STATE OF CALIFORNIA <br /> 3EORGE DEUKMEJIAN,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL EIOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD �o <br /> SACRAMENTO.CA 95827-3098 <br /> 1 October 1990 <br /> OCT 5 <br /> ENVIRONMENTAL HEALTH <br /> Mr. David W. Bates PERMIT/SERVICES <br /> Chief Production Engineer <br /> The Marley Cooling Tower Company <br /> 5800 Foxridge Drive <br /> Mission, Kansas 66201 <br /> VIOLATION OF NPOES PERMIT NO. CA0081787, MARLEY COOLING TOWER, SAN JOAQUIN <br /> COUNTY, CALIFORNIA <br /> We have received your consultant's response, dated 18 August 1990, to our Notice <br /> of Violation letter, dated 12 July 1990, regarding violations of your NPDES <br /> discharge permit. In our 12 July 1990 letter you were required to submit to us <br /> your plans, including time schedules, to prevent a recurrence of specific NPDES <br /> permit violations. <br /> Your consultant' s 18 August 1990 submittal entitled "Technical Report On Existing <br /> Water Treatment Plant Operations" appears to adequately address our concerns <br /> regarding the violations, except for the following items: <br /> 1) Your daily analytical results during the 90-day supplemental testing <br /> program of the 24-hour composite split effluent samples, for both <br /> the on-site Hach test and the contract laboratory, must be submitted <br /> in the appropriate monthly monitoring report. <br /> 2) The proposed 1 November 1990 revision to the treatment plant' s 0&M <br /> manual , incorporating the 0&M procedures to periodically wash the <br /> ion exchange media during storm water treatment, must be submitted <br /> by 15 November 1990. The revised manual must also include the on- <br /> site 'Hach monitoring procedures that will be employed to monitor the <br /> effectiveness of the treatment system, and the contingency plans <br /> that will be followed in the event that these tests indicate non- <br /> compliance with NPDES permit requirements. <br /> 3) <br /> This QA /QC prram o <br /> program must u <br /> tbe submitted laboratory <br /> by 15Ocwas not submitted. <br /> October 1990, <br /> 4) Your plans to reduce the TDS levels in your effluent appear <br /> reasonable. However, your plans to operate the treatment plant <br /> without decreasing the influent pH must be included in the proposed <br /> 1 November 1990 revision to the plant's 0&M Manual . Also, your <br /> consultant states that the treatment plant' s recycled regeneration <br /> wastes contribute to the TDS load, and that alternative methods to <br /> handle this waste will reduce the TDS in the effluent. However no <br /> plans, nor time schedules, were submitted to study and/or implement <br /> alternatives to the recycling of the regeneration wastes. <br />