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Performance Monitoring -2- 5 November 1992 <br /> Marley Cooling Tower Company <br /> In direct response to your request for a revision to the PMP, we do not find <br /> it appropriate to reduce sampling and evaluation of the wellfield performance <br /> until cleanup operations can be shown to be effective and the contaminant <br /> plume is hydraulically controlled by the extraction regime. The first <br /> quarterly Monitoring Report, submitted in August 1992, did not present <br /> adequate capture with the start-up of the remedial wellfield, nor were any <br /> recommendations given for improving performance operations. The report did <br /> not contain any information on the status of the soil flushing system, and the <br /> installation of the requested additional monitoring wells was not mentioned. <br /> A reduction in the quarterly reporting from the agreements outlined will not <br /> be considered until capture of the ground water plume has been demonstrated <br /> and compliance with the effluent limits required in your NPDES Permit has been <br /> established. <br /> The current NPDES influent monitoring requires: <br /> Constituent Unit Type of Sample Frequency <br /> Total Chromium µg/1 Grab Daily <br /> Hexavalent Chromium µg/l Grab Daily <br /> Copper µg/l Grab Daily <br /> Arsenic µg/1 Grab Daily <br /> Total Dissolved Solids mg/l Grab Daily <br /> This data is collected to aid in evaluation and operation of the treatment <br /> plant. Since start-up of the expanded treatment plant numerous excursions <br /> from the discharge limitations have occurred as a result, it is important to <br /> know the quality of the influent during those excursion events in order to <br /> modify future operations. For example, total dissolved solid (TDS) have been <br /> a reoccurring problem in the discharge from the treatment plant, if this <br /> continues it may be necessary to segregate ion exchange waste in order to <br /> reduce influent TDS substantially. Sample analysis under the existing permit <br /> must follow EPA methods described in SW 846. From the data submitted <br /> regarding correlation of on-site and off-site analysis, we believe that the <br /> Hach meters are only good for approximation and not able to adequately comply <br /> with the current NPDES. <br /> CORI CONDON <br /> Associate Engineering Geologist <br /> cc: Mr. David Bates, Marley Cooling Tower Company, Mission, Kansas <br /> Mr. Duncan Austin, Department of Toxic Substance Control , Sacramento <br /> Mr. Ron Valenoti , San Joaquin County Public Health, Stockton <br /> Mr. Tom Hickey, Black and Veatch, Kansas City, Missouri <br /> Mr. Peter Quinlan, Hargis and Associate, La Jolla <br />