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Among other things, the order required Dico to install extraction wells to collect the contaminated groundwater on the east and west sides of the Raccoon River, to treat the extracted water in an air stripping column, removing at least 96 percent of the TCE, and to discharge the treated water into the river.
The order also required Dico to install monitoring systems to measure the success of Dico's remedial measures and assure compliance with the order. However, the dico dating also informed Dico that it could request a conference with the EPA within five working days. Dico made such a request and at the conference, held on August 21,Dico raised objections to the EPA order.
Dico reiterated these objections in a letter to the EPA on September 8, The EPA responded to Dico's objections on October 21,by modifying the order to reflect some of the changes requested by Dico. By letter on October 24,the EPA further modified the order, and on November 28,the EPA agreed to Dico's suggestion to eliminate all proposed extraction wells on the west side of the river.
After the EPA had made its final modification to the order, Dico was unable to implement the order because it called for Dico to install extraction wells on property to which Dico could not obtain access.