SITE INFORMATION AND CORRESPONDENCE

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1' CLEANUP AND ABATEMhiNT ORDER NO. 5-00-704 2 FORMER CHEVRON STATION #9-5775 301 WEST KETTLEMAN LANE LODI, SAN JOAQUIN COUNTY hours. GR is scheduled to continue weekly extraction at EX -1 until an interim pump and treat system is installed. - 5. On 7 April 2000, GR submitted a workplan to the San Joaquin County Environmental Health Division to install six additional monitoring wells to further define the lateral and vertical extent of petroleum hydrocarbons and fuel oxygenates both on-site and offsite. One deep monitoring well will be installed next to MW -8 to serve as a sentinel well between the on-site contamination and the active City of Lodi -Municipal. Well 12 (City Well 12). 6. City Well 12 is about 500 feet southwest and downgradient of the form:: underground storage tanks. City Well 12 operates intermittently at approximately 800 gallons per minute. The well is constructed with a 108 -foot annular seal, cased to 490 feet bgs without a gravel pack, and the first perforated interval is at 210 feet bgs. The City of Lodi Water Department analyzes monthly samples from City Well 12 using EPA Method 524.2. MtBE has not betin detected in this well at a detection limit of 3 µg/1. 7. In October 1999, GR placed water level transducers in two on-site monitoring wells for a 3 -day period and recorded fluctuation changes corresponding to pumping of City Well 12. GR concluded that the shallow groundwater zone is in communication with the municipal well. 8. The California Department of Health Services Drinking Water Action L—evel for MtBE is 13 µg/1, and the Secondary Maximum Contaminant Level for taste and odor is 5 u21. 9. Section 13304(a) of the California Water Code provides that: "Any person who has discharged or discharges waste into the waters of this state in violanion ofany waste discharge requirement or other order or prohibition issued by a regional board or the state board, cor who has caused or permitted, causes or permits, or threatens to cause or perneit any waste to be discharged or deposited where it is, or probably will be, discharged into the waters of the state and creates, or threatens to create, a condition ofpollurion or nuisance, shall upon order of the regional board cleanup such waste or abate the effects of the waste, or, in the case of threatened pollution or nuisance, take other necessary remedial action, including, but not limited to, overseeing cleanup and abatement efforts. Upon failure of anyperson to comply with the cleanup and abatement order, the Attorney General, at the request of the board, shall petition: the superior court for that countyfor the issuance of an injunction reaquiring the person to comply with the order. In any such suit, the court shall have jurisdiction: to grant a prohibitory or manndatory injunction, either preliminary or permanent, as the fact may warrant. " 10. The Water Quality Control Plan for the Regional Water Quality Control Board, Central Valley Region, (4th Edition) (Basin Plan) establishes beneficial uses and water quality objectives to protect the beneficial uses. Water quality objectives for groundwater as specified in the Basin Plan include primary and secondary maximum contaminant levels. Was -z, including MTBE, has been discharged to waters of the state at concentrations that exceed wat= quality objectives. Exceedance of water quality objectives constitutes pollution. Therefor -- waste, including MTBE, has been discharged or deposited where it has created and continues to threaten to create a condition of pollution or nuisance.