SITE INFORMATION AND CORRESPONDENCE

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Former Apache Plastics - 3 - 17 March 2015 2050 East Fremont Street Stockton , San Joaquin Co. constituents and increases in sodium , manganese, iron, bromide , bromate , nitrate and nitrite, electrical conductivity, total dissolved solids and salinity. These measurements were collected from wells being used for injection and not monitoring wells down-gradient of the treatment zone. However, water quality was only monitored once for metals , cations, anions, total dissolved solids , and electrical conductivity since the injection events. The application of any material to groundwater may result in unintended adverse effects to groundwater quality. Conditions of eligibility to operate under the General Order include submission of a Contingency Plan to be implemented to correct unacceptable water quality effects. Background data will be used to develop trigger levels that would require implementation of the Contingency Plan when and if deleterious effects are observed , including an increase in metals , total dissolved solids and electrical conductivity more than 20% above their respective background concentrations , not to exceed their respective water quality objectives. Water quality objectives for the constituents of concern include; total chromium at 50 ug/L, hexavalent chromium at 10 ug/L, bromate 10 ug/L, nitrate 10, 000 ug/L, sulfate 250,00 ug/L, sodium 30,000 ug/L, manganese 50 ug/L , iron 300 ug/L, TDS 500 mg/L and electrical conductivity 700 umhos/cm (at 25 degrees Celsius) . If a constituent already exceeds its respective water quality objective then no increase of that constituent will be allowed in the compliance wells. A Contingency Plan was submitted by AGE in a letter response received 14 November 2014. AGE proposes that wells showing negative effects due to injection be "pumped in bulk" until water quality objectives are met. Water will not be allowed to degrade up to the water quality objective. State Water Board Resolution 68- 16 (the Anti-degradation policy) requires maintenance of water quality to highest quality possible for the maximum benefit of the people. Therefore the General Permit allows only an increase of up to 20% above background . If background already exceeds a water quality objective then no increase will be allowed . No additional details for implementing the Contingency Plan were provided. Please submit additional details explaining how polluted groundwater will be " pumped in bulk" and where the polluted groundwater will be discharged as part of the proposed Contingency Plan and results of background water quality sampling with proposed trigger levels in an Addendum to the NOI by 30 May 2015. Because this may be the final cleanup action conducted at this Site, it is appropriate to conduct public notification of the proposed actions and site conditions. San Joaquin County Environmental Health Department posted a public notice of the pending corrective actions at the site in August 2014. However, we would prefer the Public Notice notify all property owners and occupants adjacent to the site and overlying the contaminant plume of the site conditions , the proposed corrective actions and the conditions of the permit that will limit potential adverse impacts from the injection of chemicals into the subsurface. It is unclear if the list of interested parties to receive the Public Notice proposed in the NO] includes all property owners and occupants overlying the groundwater pollution. Please submit a map showing the parcels overlying the groundwater pollution that may be compared to the parcels identified to receive the Public Notice. A map figure will need to be included with the Public Notice, and must show the subject site, the estimated extent of the groundwater pollution , and the adjacent properties. The Public Notice should reference the Central Valley Water Board web site and the posting of the tentative Notice of Applicability to operate under the General Order. We can work with you and your consultant, through email to provide edits of the draft Fact Sheet, figure, and distribution list. Please ask your consultant to send a copy of the Public Notice in Microsoft word so we may make changes and modifications. An example Public Notice is enclosed and was sent to your consultant Daniel Villanueva, at AGE on 17 March 2015 .