SITE INFORMATION AND CORRESPONDENCE

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Mr. Gil Moore, President • - 2 - ! 20 April 2006 New West Petroleum of the fluidized bioremediation bed reactor, nor did it demonstrate or provide data to support that water quality objectives would not be exceeded by the discharge. Provide the information outlined in the Memo. 4. A detailed map showing the discharge point at the Site and a larger area map showing the location of the specific waters of the United States to which the discharge will reach were not included. Submit these figures or modify existing figures. 5. There is a discrepancy between the Application's proposed total discharge of 25 to 30 gallons per minute (qpm) rate versus the rate of 25 to 30 gpm proposed in the GROUNDWATER PUMPING TEST RESULTS REPORT(Report), also received from APEX on 22 March 2006. It is my understanding that the proposed pumping rate was increased to adequately depress the water table to capture the groundwater pollution. We have major concerns with the capacity of the CSA 31 storm sewer at the Report's increased flow rate. 6. The Application did not include the complete list of required laboratory analyses for influent and effluent samples. The Forms discussed in Item 1 provide a list of specific required analyses. The proposed analyses do not include the complete list of the required analyses. Review the Forms and increase the proposed list of analyses to include all required analyses, and submit the data. 7. The General NPDES Permit does not appear to be appropriate for this discharge. The Memo states the rationale for a Site-specific NPDES Permit. B. A complete Operations Plan was not included with the Application. Submit the operations plan, which should also state when and how will the fluidized bed reactor will be maintained, and how GAC units be changed out (e.g., if breakthrough occurs with the first unit, then the last unit replaces first unit and a new unit replaces the last unit). 9. The Application did not include a Figure of the Equipment Compound Detail that reflects the actual treatment system as described in the Application text. Submit a detailed figure of the treatment system with the NPDES forms. 10.The Application states that water samples will be collected monthly. While this is standard procedure for the groundwater treatment system once the start-up period is completed, we typically request more frequent sampling at start-up, to confirm the system is operating as designed and breakthrough is not occurring. 11.The Application does not include an estimate based on concentrations of untreated water, of the time to breakthrough for the GAC units. Provide the estimate and the calculations for the estimate.