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<br />. <br /> <br />. <br /> <br />-2- <br /> <br />Initial computer analyses made prior to beginning MOP in 1978 indicated <br />that all groundwater produced in dewatering, together with supplemental <br />surface water generated on Tract, would have to be injected to accomplish <br />the third goal stated above. Accordingly, the water management plan and <br />the'applications for related permits or approvals required, including a <br />plan for augmentation and an NPOES permit, were formulated to achieve a <br />no-discharge system within a time frame considered reasonably necessary <br />for construction and field testing of the then planned dewatering- <br />reinjection system. The planned monitoring system was essentially in <br />existence, being comprised of a number of converted exploration holes <br />and gages constructed during the baseline monitoring period in accordance <br />with the terms of the lease. <br /> <br />The construction and field-testing period has only recently been essentially <br />completed, having been prolonged by numerous complications, including <br />discovery that the dewatering rate should be more than twice the original <br />estimates, and that special provisions would be required to minimize <br />system plugging and other problems associated with an anaerobic bacteria <br />found in the groundwater. On the other hand, it was learned through the <br />monitoring system and further analyses that the spread of the cone of <br />depression would be less than originally contemplated, partially due to <br />the anisotropic nature of the aquifer and partially due to inadequate <br />accuracy in estimating the govern'ing hydrologic parameters.' Further, it <br />was learned that reinjection of all the groundwater produced through MOP <br />was neither practical nor necessary for this relatively short period. <br /> <br />1366 <br />