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Paul Franzia - 2 - 23 November 2005 <br /> Clean In Place (CIP) Solutions Use of CIP solutions in food processing results in significant increases of <br /> FDS in wastewater. There are many opportunities to eliminate, reduce, <br /> change the character of, or divert the discharge of CIP solutions. Please <br /> provide further information on the impact that CIP solutions will have on <br /> the overall wastewater quality and methods to remove this wastestream <br /> from the discharge. <br /> Ion Exchange Water Softening Use of ion exchange to treat boiler feed water results in significant <br /> for Boiler Feed Water increases of FDS in wastewater. Alternatives to discharging ion <br /> exchange regeneration brine to wastewater systems include using a <br /> Reverse Osmosis (RO)water treatment system for the feed water, <br /> segregation of ion exchange regeneration brine, or use of ion exchange <br /> vessels that are regenerated off-site. <br /> Boiler Blowdown Discharge of boiler blowdown can result in significant increases of FDS <br /> in wastewater. Alternatives to boiler use may include alternative means <br /> of generating steam or use of portable water heaters for tank cleaning. <br /> Cooling Tower Blowdown Discharge of cooling tower blowdown can result in significant increases <br /> of FDS in wastewater. Alternatives to cooling tower blowdown include <br /> using closed loop refrigeration units and using rented trailer mounted <br /> refrigeration units to cool fermentation. <br /> Wine Ion Exchange Treatment Discharge of wine ion exchange regeneration brine can result in <br /> significant increases in FDS. The chemicals that are described in the <br /> RWD (sulfuric acid and ammonium hydroxide) can be taken up by the <br /> crop grown on the LAA. Stabilization of the regeneration brine and <br /> metering the waste into the wastewater will result in better distribution <br /> across the LAA. Alternatively,the regeneration brine can be segregated <br /> and hauled to an appropriate waste disposal facility. <br /> Sanitation Chemicals The sanitation chemicals proposed in the RWD would result in increased <br /> FDS concentrations in wastewater and chlorine residuals will generate <br /> Trihalomethanes (THMs). Several alternatives exists to chlorine based <br /> sanitation agents,they include: peracetic acid, ozone, hydrogen peroxide, <br /> etc. <br /> By 23 December 2005, Barrel Ten shall provide an Interim Response that describes potential <br /> improvements to the facility. By 28 February 2006,please submit an Engineering Report, Report of <br /> Waste Discharge Addendum II that describes the improvements that will be implemented and the <br /> anticipated improvements to wastewater quality and groundwater quality protection. These <br /> improvements must be such that the resulting effluent will not impact background groundwater quality <br /> (approximately 475 mg/L of total dissolved solids). If not, staff will recommend that the facility be <br /> regulated under California Code of Regulations Title 27. <br /> W\Slaff\ObriennSan loaquinlBaml Ten Escalon Wincry7mmia 11 Oct 05.doc <br />