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i Mr. Brian Duggan - 2 - 7 April 2017 Waste Discharge Requirements General Order for InSitu Remediation R5-2015-0012 It appears that the proposed pilot study using 3DME as an injectant could be permitted under the General Order for InSitu Remediation. The Pilot Test Workplan includes a cross-section, groundwater quality data, monitoring well locations and construction detail, a workplan for installation of pilot test performance monitoring wells, and a proposed monitoring plan. Regenesis has provided Central Valley Water Board with an analysis of 3DME and CRS. While Central Valley Water Board staff accepts 3DME as an injectant, it is still considering the use of CRS, due to its high concentration of salts. Please provide the following additional information and documents to complete the General Order application: • A contingency plan that outlines water quality thresholds in compliance zone wells that, if exceeded, would indicate that the extent of the biologically active zone is much greater or behaving differently than anticipated, and what actions will be taken to address the occurrence. • A draft fact sheet and distribution list. The fact sheet needs to inform neighbors and interested parties about the contaminant distribution, the pilot test objectives and methods, and where the public may view site documents. • The site NCAIS industry standard codes. • An Initial Study Checklist. With the Checklist, Central Valley Water Board staff will determine if the California Environmental Quality Act document adopted for the General Order is sufficient for the proposed pilot test. • A Notice of Intent form. • A check for the General Order application fee of$4699 written to the State Water Resources Control Board and delivered to Amy Terrell at the Central Valley Water Board (11020 Sun Center Drive, Ste. 200, Rancho Cordova CA 95670). This fee will be assessed annually until the pilot test is determined to be completed, when groundwater geochemistry is approaching baseline conditions. When these elements are received, Central Valley Water Board staff will prepare a draft Monitoring and Reporting Program and a draft Notice of Applicability for your review and comment. When these documents are satisfactory, the fact sheet will be circulated for a 30-day comment period. Any comments received will be addressed before the final Notice of Applicability and Monitoring and Reporting Program are issued. Monitoring Well Installation and Destruction In the Pilot Test Workplan, CPS proposes to install five additional 2-inch diameter A-zone monitoring wells that will complement four existing A-zone monitoring wells and surround the former north pond injection area. At the south tank farm load pad, existing monitoring wells are located in downgradient and upgradient positions. The new wells are proposed to be installed with about 20-foot screens positioned from about 45 feet to 65 feet bgs. Three wells are proposed for destruction: E-1, installed in 2001 for hydraulic testing, and PM-1 and PM-2, installed in 2006 for a prior pilot test. These wells have not been used in the past decade, and are not anticipated to be useful in the future.