SITE INFORMATION AND CORRESPONDENCE

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Mr. Bob Jackson -2 - 1 December 2010 Valley Water Board staff require any borings at the north and south ponds to be angled beneath the cap, not punched through the cap, unless CPS is willing to commit to excavating polluted material beneath the cap, or replacing the cap with comparable materials. Crop ProductionServicesmay also elect to remove the north and south pond soil borings from the work plan if it so chooses. Conditional Concurrence Central Valley Water Board conditionally concur with the Soil Investigation Work Plan provided the following condition is implemented: • No punctures shall be made into the engineered cap covering the north or the south pond unless Crop Production Services agrees to excavate polluted soil from the former pond, or replace the cap with comparable materials and provides a work plan for cap replacement. We look forward to seeing the report of results by 1 April 2011. Groundwater While Central Valley Water Board staff appreciate the additional investigation into on-site source areas, the data shows that the center of mass of groundwater pollution has moved off- site and groundwater remediation is needed off-site. By 1 April 2011, Crop Production Services needs to provide a tentative schedule for the next groundwater remediation actions. This schedule may be included in the Report of Results. If you have any questions, you may contact me by telephone at (916) 464-4680 or by email at ater ell@wat oards. a.gov. A Y TERRELL Private Sites Cleanup Unit cc: Mr. Michael Infurna, San Joaquin County Environmental Health Department, Stockton Mr. Kirk Williams, Crop Production Service, Loveland CO Mr. John Coll, ATC, Austin TX Mr. Todd Leonard, Rubik Environmental, Reno NV Mr. Bill Flores, ATC Associates, San Luis Obispo