SITE INFORMATION AND CORRESPONDENCE

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WASTE DISCHARGE REQUIREMENTS ORDER NO.R5-2004-0160 4 CONTIGROUP COMPANIES,INCORPORATED FRENCH CAMP GRAIN ELEVATOR ENHANCED REMEDIATION PILOT STUDY SAN JOAQUIN COUNTY prior to the injection of GZVI. The list of analytes required for the baseline sampling is listed in the attached MRP No. R5-2004-0160. Regional Board staff must provide concurrence with the proposed baseline concentrations prior to injecting the GZVI. The Discharger will collect groundwater samples from MW-9B and MW-10B immediately following well development. Well development of MW-9B and MW-1 OB will occur no sooner than 24 hours after installation and no later than 48 hours after installation. MW-313,MW-4B,MW-913, and MW-10B will be sampled at. 2, 4, 8, 12, 16, 20, and 24 weeks after the completion of the GZVI injections in accordance with MRP No. R5-2004-0160, and then quarterly thereafter until concentrations return to baseline. 15. Bench-scale testing was not performed because this technology has been shown to be successful at reducing carbon tetrachloride and chloroform concentrations at several other sites, include the E1 du Pont de Nemours and Company site in Oakley, California. 16. Byproducts from the injection of GZVI may include reduced forms of iron, which depending on pH and electrical conductivity may include ferrous hydroxide or ferrous chloride. Breakdown products of carbon tetrachloride and chloroform from the injection may include methylene chloride, chloromethane, carbon dioxide,methane, and chloride ion. With the exception of chloride ion, the breakdown products of carbon tetrachloride are expected to be intermediate compounds. The Discharger will monitor for these byproducts in accordance with the attached MRP No. R5-2004-0160. 17. In the event that carbon tetrachloride, chloroform,methylene chloride,chloromethane,metals,total dissolved solids, chloride, carbon dioxide,methane,boron,ethylene glycol,byproducts, and/or breakdown products are detected in downgradient well MW-4B more than 20 percent above the approved baseline concentrations, the Discharger will collect a confirmation sample within 7 days of receiving the analytical results. If the exceedence is confirmed,the Discharger will install two extraction wells screened in the B water bearing zone downgradient of the three GZVI injection areas and upgradient of MW-4B within three months of the receiving the exceedence confirmation sample. The Discharger will receive Regional Board staff concurrence on extraction well schematics and placement prior to installation. Within two months of the installation of the two extraction wells, the Discharger will begin extracting from both extractions wells,treat the recovered water with granular activated carbon and/or air stripping and transport the extracted water to the Stockton Regional Wastewater Control Facility. The Discharger may also submit a Report of Waste Discharge to reinject the treated water if initial results show that groundwater extraction may be a long-term corrective measure. REGULATORY CONSIDERATIONS 18. The injection of chemicals into waters of the State is subject to regulation under the California Water Code. This Order authorizes the Discharger to inject GZVI into groundwater subject to specific discharge requirements. 19. The Water Quality Control Plan for the Sacramento River and San Joaquin River Basins, Fourth Edition (hereafter Basin Plan) designates beneficial uses, establishes water quality objectives