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Brian Newman - 2 - • 19 April 2006 processes, and that monitoring data is available to demonstrate this. If additional effluent limitations and/or monitoring and reporting requirements need to be included for this discharge, the General Order would not be appropriate, and an individual Order would need to be adopted. Based on my initial review, I believe an individual Order will be necessary for this discharge. 4. The location of the proposed discharge is unclear. The Discharger indicates that the discharge would be to a storm drain leading to White Slough. However, I believe any storm drain from the development would lead to Highline Canal or to Dredger Cut. The Discharger needs to provide clarification regarding the discharge location. 5. 1 understand that there is also a discrepancy between the Groundwater Pumping Test Results Report and the NPDES application regarding the flow rate needed for the remediation. The NPDES application indicates that the discharge flow will be between 25- 35 gallons per minute as a combined flow for all extraction wells, whereas the report indicates says that this much flow must be pumped from each of 5 extraction wells in order to depress the water table sufficiently for plume capture. The NPDES application indicated the treatment process is not designed for this flow rate, and it is not clear whether the storm drain is designed to handle these flows during storm events. 6. While I have not made a detailed review at this time, the effluent characterization appears to be incomplete with regard to the analyses needed to assess compliance with the Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California (State Implementation Policy or SIP), as well as constituents for which drinking water MCLS have been prescribed in the California Code of Regulations. We can provide a more detailed analysis of this deficiency at a later time, but the Discharger may need to conduct additional sampling prior to issuing a NPDES permit.