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train as backup is not usually warred for removal of Each of these optioohave positives and negatives <br /> VOCs or metals. The components of these treatment associated with them, and these are summarized in <br /> trains require minimal downtime, and because ground Exhibit 8. Site managers should regularly evaluate <br /> water moves slowly,maintaining and operating parallel discharge options to determine which is most cost <br /> systems to prevent a few days of downtime per year is effective and should consider capital, negotiation, and <br /> not cost-effective. If one train of an operational sampling costs of the options in this evaluation. <br /> parallel system can treat the extracted water, managers <br /> should consider bypassing or eliminating the other train Disposal of filter cake from biotreatment or metals <br /> if savings from labor and maintenance are expected to precipitation can generally be disposed of as non- <br /> exceed the capital cost of the modification. hazardous waste if it passes Toxicity Characteristic <br /> Leaching Procedure (TCLP)testing. This costs less <br /> Consider Alternate Discharge/Disposal Options than disposal at a hazardous waste facility. If these <br /> materials are considered "listed"waste because of past <br /> The following discharge options are typically available site use,but the wastes pass TCLP testing,then "de- <br /> for treated water: listing" should be pursued. Savings of up to $200 per <br /> ton could result from a change in disposal practices. <br /> • publicly owned treatment works (POTWs) For some sites,this could translate to savings of up to <br /> $4,000 per month in costs associated with <br /> • storm sewer and surface water(both regulated transportation and disposal of such wastes. <br /> under National or State Pollutant Discharge <br /> Elimination System,NPDES or SPDES, Identify Onoortunities for System Automation <br /> programs) <br /> Common treatment components such as air strippers <br /> • reinjection to the subsurface(regulated by and GAC units, when properly designed and installed, <br /> Underground Injection Control Program) have been proven reliable through years of testing in <br /> the field. As a result,when these systems are installed <br /> with alarms,auto shut-offs for high levels,and auto- <br /> Exhibit 8 <br /> Discharge Alternatives for Water from a PST System <br /> Discharge alternative Positives Negatives <br /> Publicly-owned treatment require relatively flexible discharge may refuse to accept treated or <br /> works(POTWs) standards compared to other alternatives untreated ground water due to dilution <br /> (typically 2.13 mg/L total toxic or lack of capacity <br /> organics) require payment(approximately <br /> accept and treat some hard to treat $0.002 to$0.03 per gallon) <br /> contaminants (ketones and ammonia) often require pretreatment <br /> Storm sewer and surface typically do not require payment for resource conservation,some areas <br /> water often readily accessible from treatment do not allow discharge of ground water <br /> plant to surface water <br /> minimal capital costs discharge criteria is generally stringent <br /> (e.g.,MCLS for naturally occurring <br /> inorganics) <br /> lengthy permitting process <br /> frequent sampling requirements <br /> Reinjection to subsurface may help with hydraulic control of may hinder hydraulic control of plume <br /> (reinjection wells or plume may require substantial capital cost <br /> infiltration galleries) relatively easier permitting process potential issues with fouling of wells <br /> biotoxicity testing not required requires space for wells or galleries <br /> 15 <br />