SITE INFORMATION AND CORRESPONDENCE

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New West Petroleum #1003 • 2 - • 26 July 2007 Lodi, San Joaquin County 13 July 2007, CSI stated it could not get the exact locations and well construction details for the supply wells from SJCEHD to design the new wells in time to meet the 16 July 2007 CAO deadline for the Workplan. Therefore, CSI informed us that although the Workplan would not address new wells to provide lateral extent towards the north and northeast of the USTs, a subsequent workplan would include new monitoring wells to the north and northeast. Please ask CSI to contact me if the SJCEHD well information has not been received; or fax a Department of Water Resources release form to me for signature, so that you may access the information. You are directed to submit a letter supplement to the Workplan, including a revised Figure 1 with at least two new well locations indicated to the north and northeast of the USTs, and with technical justification for the depths of the new wells, or multiple depths at each new location, by 24 August 2007. The CAO requires installation of all new wells by 21 September 2007 and the submittal of a Preliminary Investigation and Evaluation Report by 15 November 2007. 2. The Workplan, in Section 4.7 Soil Vapor Sampling Analyses, states that "In addition (to the petroleum hydrocarbon constituents of concern), 02, CO2, and methane will be analyzed by EPA Method TO-15, ensuring that reporting limits are below the atmospheric concentrations of these gases." The Workplan does not describe how atmospheric concentrations will be determined: a) either by collecting additional air samples into summa canisters from the atmosphere, or b) the source of published atmospheric concentrations of these gases in the immediate area. I strongly suggest that CSI review the Interstate Technology and Regulatory Council Vapor Intrusion Pathway: A Practical Guideline (http://www.cIu-in.org/conf/itrc/vipathway/) Appendix D, Section D.10, which addresses ambient (background outdoor air) sampling. Please include any revisions to the soil vapor sampling section, including taking an ambient air sample(s) that also include the constituents of concern, with the letter supplement to the Workplan. 3. The Workplan does not include a figure depicting the cross-section.view of the new monitoring wells or soil vapor sampling points, which is a requirement for SJCEHD well permits. Please include cross-sectional figure(s) indicating the dimensions of the wells/sample points with the letter supplement to the Workplan. Site History: 4. The Site History report states that Mr. Gil Moore is the fee title owner. The CAO states in Finding 1 that "Based on San Joaquin County Grant Deed dated 19 December 1995, the Flag City, L.P. sold the property to Mr. J. Gilbert Moore and Ms. Eileen A. Moore." UST System Integrity: 5. The UST System Integrity report states that the ELD Test statement "...87 vapor bucket failed the water test..."was incorrect, in that: The statement did not indicate a failure to pass the ELD Test, The spill bucket is not intended to be a containment device, "only ...protects the vapor swivel adapter and vapor cap from backfill material',