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Greg K. Vaughn . -3- 1 May 1987 <br /> Due to the sensitive nature of the issues surrounding this revision, <br /> they will need further consideration. Therefore, we will submit <br /> comments on Revision 4 in the near future. <br /> Revision 5. <br /> This revision will be incorporated into the revised permit. <br /> Revision 6. <br /> Information contained in this section should be adequate to address <br /> General Provision A. 13 . , Safeguard to electric power failure. <br /> Revision 7 . <br /> This revision will be added to the information sheet for the revised <br /> permit. <br /> Comments on the Water Treatment Plant Description of Operations <br /> Comment 1. <br /> Your original proposal had a cation-anion configuration of the ion <br /> exchange treatment units. In your new proposal, the configuration of <br /> the ion exchange units is anion-cation. Our experience with other <br /> dischargers utilizing ion-exchange systems has shown that clogging <br /> of the anion exchanger may occur when anion-cation treatment is <br /> performed. This is due to the fact that the metal cations <br /> (specifically magnesium hydroxide) sometimes precipitate out during <br /> the high pH anion exchange process. Analyses of the groundwater has <br /> shown the presence of magnesium and also calcium. Has this potential <br /> problem been taken into consideration in the new exchanger <br /> configuration? <br /> Comment 2 . <br /> As a result of the treatment process, a significant amount of sodium <br /> and sulfates will be discharged with the treated effluent. Effluent <br /> limits for these constituents will be added to the permit. The value <br /> of these limits will be dependent on the background levels in the <br /> receiving water. The limits will have to be low enough to assure <br /> that water quality degradation of the receiving water will not <br /> occur. <br /> Comment 3 . <br /> We concur that sampling and analyses of the system is important. <br /> Sampling points should be located in areas of the treatment system <br /> that will provide representative characterization of both the <br /> influent and effluent waste streams. These locations should be shown <br /> on the schematic for the treatment plant. <br />