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<br />. <br /> <br />-3- <br /> <br />. <br /> <br />Accordingly, at the present time, the pending permit and approval program <br />has been adjusted to reflect the foregoing field conditions. Such <br />adjustments include provision of somewhat more dewatering facilities <br />than originally contemplated, addition of two reinjection wells to the <br />previously existing system, and provision of an expanded monitoring <br />system. During the elapsed first two-year period of MDP approximately <br />seventy percent of the water produced is anticipated to be discharged; <br />. all of it relatively good quality, averaging about 1,000 mg/l TDS on a <br />thirty-day basis. It should be noted that cost-effective studies, <br />submitted with the original and with a recent application by RBOSC for <br />renewal of its NPDES permit have conclusively shown that storage or <br />treatment alternatives to discharge during the relatively brief MDP <br />period are not practical. The inverse ratio of penalty costs associated <br />with the range of discharge anticipated for the forthcoming period <br />(which will result in a potential increase at Imperial of less than 0.1 <br />mg/l in TDS) to the cost of storage or treatment fa~ilities to mitigate <br />salt return have been estimated to be greater than thirty to one. <br /> <br />In general, water management planning and the associated permit program <br />of RBOSC has been concentrated on MDP until recently. The plans for the <br />commercial development phase (CD?) of Tract C-a are in the formulation <br />stage. Similarly, the water management plan, for CDP is in the formulation <br />stage; however, based on prior studies and early indicatio~s of recent, <br />substantially increased water planning studies, it is contemplated that <br />the following precepts will be adopted for the water management plan: <br /> <br />1365 <br />