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Treated Water Disposal Evaluation -4- 7 January 1992 <br /> Marley Cooling Tower Company <br /> options, rather than the discharge to surface water as a backup <br /> disposal option. <br /> f. The Table indicates that compliance with NPDES and the Underground <br /> Injection Control (UIC) Program would be needed for either intermediate <br /> or deep zone injection. However, the Table did not include compliance <br /> with the permitting requirements under the Porter-Cologne Water Quality <br /> Control Act. Injection into either zone would require issuance of WDRs <br /> specific to the direct discharge into the aquifer. <br /> Page 4-9. Tables 4-2, 4-3 and 4-4 show that the difference in present worth costs <br /> between the three disposal options is approximately $1,600,000. However, <br /> the total capital costs associated with implementing an injection disposal <br /> system, far exceeds that of the existing surface water discharge system <br /> because disposal to surface waters has no new or additional capital costs. <br /> The difference in total capital costs between injection into the <br /> intermediate and deep zones is approximately $600,000 with deep zone <br /> injection having the lower associated total capital costs. Based on these <br /> costs, it appears that injection may be too costly to implement. <br /> Page 4-9. Tables 4-2, 4-3 and 4-4 show that the net present worth savings for each <br /> disposal option was calculated using a 50 year period at 8 7/8 percent. <br /> Although the Report did not indicate how long the remedial activities are <br /> estimated to be needed at the site, a 50 year period may be excessive. <br /> Projections of 15 to 30 years of remedial activities are more common <br /> because the life of the equipment is limited. The rationale for using a 50 <br /> year period should have been provided. <br /> CKW:cw <br />