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Kearney—KPF 4 13 September 1990 <br /> Modified Closure Plan <br /> In addition, the details of the ground water treatment system as <br /> well as the specifics of the injection well design and operation <br /> must be submitted to the Board for review. Monitoring of the <br /> treatment system will be required to assure that the treated ground <br /> water meets the specified treatment standards. For any treated <br /> ground water which is to be disposed of through injection directly <br /> into the aquifer, the discharger must be able to demonstrate that <br /> the treated ground water quality is better than the water quality of <br /> the water bearing zone into which it is being injected. This <br /> demonstration is necessary to assure that ground water quality will <br /> not be degraded. <br /> Whether the treated ground water is disposed of by infiltrating or <br /> by injection, this disposal would probably not warrant revision of <br /> the WDRs for the interim treatment system. However, the final <br /> ground water treatment and disposal systems will probably require <br /> revision of the WDRs. <br /> The disposal alternatives for treated ground water are, in order of <br /> preference, 1) recycle / reuse; 2) waste discharge to land; 3) <br /> discharge to a publicly operated treatment works (POTW) ; and 4) <br /> discharge to surface waters. Because of the regional dewatering of <br /> the aquifer, recycle / reuse would be strongly favored. If the <br /> selected disposal alternative for the treated ground water is to <br /> surface waters, then an National Pollution Discharge Elimination <br /> System (NPDES) permit must be issued. In this case, the discharger <br /> must demonstrate that there are no wastes in the treated ground <br /> water and that the other three alternatives would be technically and <br /> economically infeasible to implement. <br /> Page 3. If the infiltration basin and associated injection wells are to be <br /> used for the disposal of both the treated ground water and the <br /> disposal of all site drainage, then the Plan is not acceptable. The <br /> injection of any waste stream directly into the aquifer without any <br /> water quality data, monitoring or treatment of those waste streams, <br /> poses a threat to ground water quality. <br /> Page 4. A downhole well injection test will be performed to develop the <br /> design injection rates for the dry wells. A work plan which <br /> outlines the design details of the test must be submitted to the <br /> regulatory agencies for review prior to performing the test. <br /> Page 5. The plan for removal of unwanted soils did not include the <br /> landfarmed cuttings and drilling mud soils. The cuttings and <br /> drilling muds disposal areas must be removed before the construction <br /> of the disposal basin. The landfarmed cuttings from Phase I of the <br /> RI will need to have a minimum of the upper six inches removed which <br /> is based on the size of the discs use to landfarm these wastes. The <br /> landfarmed drilling mud from Phases I and II of the RI must be <br /> removed to a depth of at least one foot and up to 18 inches. This <br />