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Per the recommendation of the staff at San Joaquin County Public Heath Services Environmental Health Division, Clearwater contacted staff at the Central Valley Regional Water Quality Control Board (CVRWQCB) with regard to the requirements for a Permit for Waste Discharge. The CVRWQCB is responsible for issuing all permits related to the injections of chemicals into ' the subsurface within the Central Valley. The CVRWQCB staff responded that the agency does not have its own Regional Board-adopted general permit to inject nutrients and/or microbes into the subsurface ; therefore, a site-specific permit would be required . Such a site-specific permit would need to be adopted by the Regional Board at a public meeting. The process of approval and adoption by the CBRWQCB would take in excess of 6-months following the submittal of a complete site-specific permit application. Initiation of the permitting process requires the submittal of a Report of Waste Discharge (ROWD) with an application for waste discharge requirements (WDRs) to land (the WDR 'I application fee is approximately $3 ,684) . The ROWD presents the results of a bench scale test to demonstrate that 1 ) the addition of microbes would be cost effective in relation to the addition of nutrients to the indigenous species now present at the site, and 2) the injection of either nutrients it and/or microbes, specifically the species of bacteria injected, would not be harmful to human health, the environment, or water quality. A ROWD Workplan would be required and approved before bench testing could proceed. The CVRWQCB staff recommended that, preparatory to producing such a workplan, a file review be conducted of two projects located in Stockton that were successful in procuring all required permits for the injection of nutrients. Clearwater staff identified the two sites in question are 1 ) the Arco Station on Washington Street and 2) ST Services on Navy Drive. Clearwater performed the agency file review on December 29, 2006. On July 26, 2006, Ms. Lori Duncan, San Joaquin County Public Heath Services Environmental Health Division, approved the recommendation made in the Second Quarter 2006 Groundwater Monitoring and iSOC Remediation Activity Report to redevelop the groundwater-monitoring well network using a method deemed appropriate by Clearwater. The redevelopment of the groundwater-monitoring well and remediation well network was postponed until the first quarter of 2007 . On August 30, 2006, Mr. Floyd Barnes contacted Clearwater staff because he had inadvertently cut the underground iSOC plastic tubing (lines) . Mr. Barnes was cutting a trench on his property from his sump pump to the storm drain and damaged the lines for IW-2 through IW-6 iSOC . On August 31 , 2006, Clearwater inspected the site, repaired the damaged lines, reconnected the repaired lines, and relabeled the panel . On October 11 , 2006, Clearwater staff received a call from their technician in the field and sent SJCEHD a facsimile documenting activities occurring across the street from the project site and included maps and project discussion e-mails. The claimant, Mr. Barnes, reported that on or about October 8, 2006, a backhoe employed by D.A. Wood Construction for use in the construction of a housing development across the street from the project site hit and broke through a large water line. According to Mr. Barnes, the construction firm was working to shut off the water line, but in the meantime the resulting water was being pumped into trucks and taken off-site. Clearwater field staff notified the project manager of this activity during the October 10`h monthly iSOC O&M event. Clearwater has since learned that a large housing ZB 178 — Site Investigation History 4 Updated March 2010 Barnes Trucking Facility — 1817 South Fresno Avenue, Stockton, California