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Marley Cooling Tower Company 3 19 June 1990 <br /> MCTC plans to implement the following actions to ensure that this problem will not <br /> recur: <br /> 1 . Wash the resin beds at least twice during the rainy season (more if <br /> necessary to maintain exchange capacity) . <br /> 2. Implement the onsite Hach monitoring program. <br /> 3. Implement a QA/QC program for the contract laboratory. <br /> Since this problem was identified last season, MCTC should have been prepared for it <br /> this year. Their current plans to prevent a recurrence appear reasonable provided that <br /> they receive the detailed Hach monitoring program discussed earlier, and provided the <br /> contingency plan include operational and monitoring procedures to be followed in the <br /> event that effluent limitations are exceeded (i .e. , shutdown, resin washing, start-up, <br /> and proposed monitoring during these phases) . In addition, the results from the resin <br /> manufacturer regarding the condition of the ion exchange resin should be submitted. <br /> Finally, the TDS effluent limitations are exceeded on a regular basis, even when the <br /> treatment system is operating effectively and meeting its chromium and copper <br /> limitations. Based on historical monitoring reports the treatment system usually <br /> increases TDS levels 10 % to 60 % above influent levels. MCTC should prepare and <br /> submit to the us a technical report, including a time schedule, detailing their plans <br /> to comply with the TDS effluent limitation in their NPDES permit. <br />