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California Agional Water Qualityf ontrol Board _ <br /> Central Valley Region ' <br /> Robert Schneider,Chair �''�'` <br /> Terry Tamminen Arnold Schwarzene er <br /> Secretary for Sacramento Main Office - Governor gB <br /> Environmental Internet Address: htt1W/www.swrcb.ca.gov/rwgcb5 <br /> Protection 11020 Sun Center Drive 4200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 <br /> 22 July 2004 <br /> Mr. David Lich 0- 2 g 2044 <br /> Environmental Manager <br /> Marley Cooling Technologies ENPERMITISERVICESTH <br /> 200 N. Wagner Avenue <br /> Stockton, California 95215 <br /> MARLEY TREATMENT SYSTEMDEMONSTRATIONSTUDY WORKPLAN, FORMER <br /> MARLEY COOLING TOWER FACILITY, 150 N. SINCLAIR AVENUE, STOCKTON, <br /> CALIFORNIA <br /> The Regional Water Quality Control Board(Regional Board) staff has reviewed Marley System <br /> Demonstration Workplan dated 27 April 2004 (received on 27 May 2004), and Request for Approval- <br /> Marley System Demonstration Workplan dated 16 July 2004,prepared by TRC on behalf of SPX <br /> Corporation and Marley Cooling Technologies (SPX-Marley). SPX-Marley proposes to conduct a <br /> demonstration study of an ion exchange (IX) treatment utilizing a brine precipitation system for <br /> groundwater impacted with hexavalent chromium. SPX-Marley intends to collect performance and cost <br /> data over a four-week period. If the proposed system is successful in removing hexavalent chromium <br /> from the groundwater while meeting the requirements of the existing National Pollutant Discharge <br /> Elimination System(NPDES) Permit (Order No. R5-2003-0030) for discharge of treated water to the <br /> Stockton Diverting Canal, SPX-Marley plans to replace the existing IX system and Electrochemical <br /> Precipitation System(ECS System)with the new IX system utilizing a brine precipitation system. <br /> The proposed IX process differs from the current process of removing chromium from groundwater as it <br /> is expected to eliminate the hazardous regeneration chemicals, sodium hydroxide and sulfuric acid, and <br /> replace them with sodium chloride. Other potential benefits include elimination of the ECS and pH <br /> control system,reduction of(1) Total Dissolved Solids (TDS) in the effluent, (2) energy consumption, <br /> and(3) quantity of residuals to be managed. <br /> The work plan for the demonstration study presents a description of the technology,preliminary <br /> modeling results, sampling, reporting, and a project schedule. If the Demonstration system proves <br /> successful as a replacement technology, the workplan states that a revision to the current NPDES permit <br /> is not anticipated since the treatment train will be the same and that only changes to the system <br /> Operation and Maintenance (O&M)plan will be needed. <br /> Demonstration Study <br /> The demonstration study will be conducted using a patented IX System (Demonstration System) <br /> provided by Basin Water(equipment vendor) in two Phases, 1 and 2 described below. The fieldwork is <br /> planned to start in the next few weeks. The existing online continuous pH and chromium analyzers, <br /> California Environmental Protection Agency <br /> Qa Recycled Paper <br />