SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Mr. Jack Badey -2 - 14 January 2011 HRC in similar lithology to Stockton to expect that HRC and HRC Primer will be able to promote the reducing conditions necessary to degrade the dry cleaning solvents. In addition, Central Valley Water Board staff have results of product analyses. Additional analyses are not required for these products. ADDITIONAL ELEMENTS REQUIRED FOR GENERAL ORDER PERMIT In its Interim Action Plan, UniFirst provided many of the elements required for the General Order for InSitu Remediation. Please provide the remaining elements as discussed below as an Addendum to the Pilot Scale Study. • Notice of Intent While a Notice of Intent was submitted along with the Pilot Scale Study, it did not include a signature, and the phone number is missing a digit. UniFirst may provide an electronic copy of the signed Notice of Intent. A copy is attached. • Annual Fee Please provide Central Valley Water Board staff with a check for $2520 made payable to State Water Resources Control Board. This is the annual fee for Waste Discharge Requirements for projects that are rated at a threat and complexity of 3B. • SIC Code Provide the Standard Industry Code for the business that caused the pollution. • Treatment Zones Provide a diagram that shows the expected extent of the treatment zone, the transition zone and compliance zone. The treatment zone is where water quality objectives are likely to be temporarily exceeded due to the addition of HRC, the transition zone is the region beyond the treatment zone where water quality is transitioning to background conditions, and the compliance zone is where water quality changes due to remediation are not expected. • Baseline Sampling The General Order will require that the groundwater quality disturbances resulting from remediation not extend beyond the treatment and transition zones. Baseline sampling outside the zones of disturbance provides a means of determining if observed geochemical changes are independent of the remediation. Prior to injections, baseline groundwater data for indicators of a reducing environment are proposed to be obtained from MW-5A, MW-513, MW-5C and nearby monitoring wells MW-7 and MW-9. Baseline sampling should also be obtained from monitoring wells that are upgradient of the reducing environment in order to track ambient water quality changes that may be occurring independently of the treatment. Unifirst should add regular baseline sampling of an upgradient monitoring well for the geochemical parameters of nitrate, ammonium, dissolved manganese, dissolved iron, alkalinity, and dissolved organic carbon. This sampling should continue throughout the remediation period. A baseline sampling schedule should be incorporated into a proposed monitoring and reporting program. • Draft Monitoring and Reporting Program A template for a draft monitoring and reporting program for General Order No. R5-2008- 0149 has been provided to AMEC Geomatrix by email, and is also found at the Central Valley Water Board website