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.Gary Reents 2 27 April 1989 <br />determined. Based on these results, an estimation of the pumping <br />requirements and treatment parameters should be made. This information <br />should be contained in a revised RWD and a permit will be written that allows <br />for complete cleanup of the aquifer. Once a permit is adopted and the <br />treatment plant is constructed the existing extraction wells should be <br />operated on an interim basis while additional plume identification work is <br />completed. Future modifications to the extraction network could be warranted <br />based on the reevaluation. <br />This reevaluation is not only necessary to optimize the cleanup but is also <br />needed to determine design capacities of the treatment plant and effluent <br />limitations in the NPDES permit. The permit, once written, should not have <br />to be amended shortly thereafter because of flow or loading rates not <br />anticipated in the RWD. <br />A comprehensive monitoring well system must be designed. The monitoring well <br />network must be capable of verifying the extent of contamination and <br />assessing the effectiveness of the cleanup method. <br />Design details and critical parameters must be presented for the treatment <br />system. For example, the following questions and comments must be addressed: <br />What is the anticipated influent concentrations of BTX and TPH? <br />Is recent monitoring data being used for the design of the treatment <br />system? <br />What are the design parameters of the aeration basin and the carbon <br />adsorption unit? <br />What are the anticipated effluent concentrations? <br />What safeguards will be included to assure compliance with effluent <br />limitations? <br />If this information has already been used in the design of the treatment <br />system, it should be provided for our verification of design parameters and <br />formulation of waste discharge requirements. <br />In summary, waste discharge requirements can not be formulated without more <br />specific information. It is recommended that SPPL suomit a RWD that includes the <br />final design of the extraction system and treatment system. The RWD should include <br />the parameters and calculations used to design the extraction and treatment <br />systems. SPPL must also include specific effluent descriptions and comparisons <br />between receiving water and effluent characteristics.