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Mr. David W. Bates -2- 12 July 1990 <br /> Your letter of 4 June 1990 implies that the reason for the long period of <br /> violations is due to your contract laboratory's inability to complete its <br /> analyses in a timely manner. Your letter suggests that MCTC is currently taking <br /> measures to ensure a more timely laboratory turn-around of results, to monitor <br /> the treatment system and effluent more frequently using a Hach unit, and to <br /> conduct a QA/QC program on the contract laboratory. <br /> You further state in your 4 June 1990 that the reason for the violations of the <br /> chromium and copper effluent limits was the fouling of the ion exchange resin due <br /> to the ferric chloride treatment of the storm water. Furthermore, you state in <br /> your letter that this problem also occurred last year. Operational procedures <br /> should have been incorporated into the facility' s O&M Manual , following last <br /> year's problems with the ion exchange units, to preclude a recurrence of this <br /> type of problem. Your plans to wash the ion exchange resin beds at least twice <br /> during the rainy season appears reasonable. However, the contingency plan for <br /> the Hach monitoring program must include the operational and monitoring <br /> procedures to be followed in the event that effluent limitations are exceeded <br /> ( i .e. , shutdown, resin washing, start-up, and proposed monitoring during these <br /> phases) . In addition, the results from the resin manufacturer regarding the <br /> condition of the ion exchange resin must be submitted. <br /> Finally, the TDS effluent limitations in your NPDES permit are exceeded on a <br /> regular basis, even when the treatment system is operating effectively and <br /> meeting the chromium and copper effluent limitations. Based on historical <br /> monitoring reports, the treatment system usually increases TDS levels 101. to 609. <br /> above influent levels. Therefore, MCTC shall develop and implement specific <br /> measures to comply with the TDS effluent limitation in its NPDES permit. <br /> If you have any questions please contact John J. Tomko at (916) 455-5712. <br /> or myself at (916) 361-5670. <br /> IeZ04— <br /> ANTONI K. J. VORSTER <br /> Senior Engineer <br /> JJT:jt <br /> Enclosure <br /> cc: Environmental Protection Agency, Region 9, W-5, San Francisco, CA <br /> Mr. Jerry Mensch, Region II , Department of Fish and Game, Rancho Cordova <br /> Mr. Jim Austreng, Department of Health Services, Toxic Substances Control <br /> Pr.rogram, 10151 Croydon Way, Sacramento, CA 95827 <br /> Ron Valinoti , San Joaquin County Public Health Services, Stockton <br /> Mr. Thomas Hickey, Black and Veatch, P.O. Box 8405, Kansas City, MO <br />