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DISCUSSION <br /> Exhibit D of the Remedial Action Order presents certain steps suggested to <br /> cease discharge to the storm water retention pond. Under the Toxic Pits <br /> Cleanup Act (TPCA) , discharges of liquid hazardous wastes or hazardous <br /> wastes containing free liquids are to cease by June 30, 1988. The Marley <br /> Cooling Tower Company (MCTC) intends to fully comply with the TPCA, but <br /> intends to modify the activities suggested in the Order to cease discharge. <br /> MCTC has started closing the storm water retention pond and has completed <br /> the following activities: <br /> 1. Liquid waste removal from the pond. <br /> 2. Phase I of the pond area characterization efforts. <br /> Phase II is presently being completed. <br /> The preliminary results of Phase I pond characterization are included as <br /> Attachment A. Evaluation of the Phase I results confirm that the wood <br /> treating chemicals in the pond are of two types: geochemically mobile and <br /> geochemically immobile. <br /> Hexavalent chromium is geochemically mobile and has passed through the pond <br /> soils and has been detected in the groundwater in the vicinity of the pond. <br /> The hexavalent chromium will be captured through use of the groundwater <br /> extraction and treatment system. <br /> Arsenic, copper and trivalent chromium are geochemically immobile and are <br /> retained by the soil as evidenced by non-detection in groundwater and by <br /> the attenuation of these constituents in the pond bottom samples. Refer to <br /> Figures 1 and 2 for graphical depictions of the typical attenuation <br /> pattern. Similar attenuation is evidenced in results from the interior <br /> pond berms. These immobile constituents have only permeated a short <br /> distance into the pond soils. Removal of the liquids from the pond <br /> 11654.000 <br />