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WASTE DISCHARGE REQUIREMENTS ORDER NO.R5-2003-XXXX • 2 CONTIGROUP COMPANIES FRENCH CAMP GRAIN ELEVATOR ENHANCED BIOREMEDIATION PILOT STUDY SAN JOAQUIN COUNTY 6. The Discharger will inject four pounds of HRC®per linear foot of vertical depth in the water bearing zone. Regenesis, the manufacturer of HRC®,provides software to determine the dosing volume. Four pounds of HRC®per linear foot is the minimum dosage rate recommended by Regenesis. 7. The Discharger will collect baseline samples a minimum of two weeks prior to the injection of HRC® and routine monitoring of the new well and existing monitoring well MW-4B for volatile organic compounds, metals, and general chemistry parameters, as required in the attached MRP No. R5-2003-XXXX. The estimated groundwater flow velocity is 10 feet per year. The new well will be installed about eight feet downgradient of the pilot study treatment zone. The HRC® is estimated to radiate out about five feet. Based on this, the Discharger estimates that within four months the HRC®will reach the newly installed well. 8. Bench-scale testing was not performed because the most common mechanism of degradation of chlorinated compounds is reductive dechlorination where the chlorinated compounds serve as electron acceptors and carbon is the main electron donor. Injecting HRC®will stimulate growth of indigenous microorganisms by providing a carbon substrate, therefore'accelerating the reductive dechlorination process. The Discharger has determined that HRC®injections will reduce pollutant concentrations because monitoring data has shown that reductive dechlorination is occurring under anaerobic conditions and carbon tetrachloride is breaking down. 9. Byproducts from the injection of HRC® may include carbon dioxide, reduced forms of sulfate such as hydrogen sulfide, and breakdown products of carbon tetrachloride, such as chloroform and methylene chloride. These byproducts are expected to be intermediate compounds. The Discharger will monitor for these byproducts along with the constituents • listed in Finding 7 in accordance with the attached MRP No. R5-2003-XXXX. 1 10. In the event that HRC® reaches monitoring well MW-4B during the one-year pilot study, 1 the Discharger will implement a pump and treat system. The Discharger will install up to 10 extraction wells screened in the B water bearing zone. Recovered water would be treated using granular activated carbon and/or air stripping and then temporarily stored on site pending transport 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. 11. The injection to waters of the State is subject to regulation under the California Water Code. This Order authorizes the Discharger to inject HRC®groundwater subject to specific discharge requirements. 12. 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