SITE INFORMATION AND CORRESPONDENCE

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CLEANUP AND ABATEMENT ORDER N0.•007-0709 • -3- J GILBERT MOORE, EILEEN A. MOORE,AND NEW WEST PETROLEUM, INC. NEW WEST PETROLEUM#1003/FLAG CITY SHELL LODI, SAN JOAQUIN COUNTY release is from the site named in the Fund application. Subsequently Mr. Moore's application was approved, and UST Cleanup Fund payments have been processed and received by Mr. Moore. 9. On 16 September 2005, SJCEHD issued a directive letter requiring an additional investigation to characterize the vertical and lateral extent of the MtBE plume. CSA-31 Well 1 and Well 2 were placed on a monthly sampling schedule, and the Dischargers were directed to begin interim remediation as "...soon as possible" and submit the proposal for interim remediation "...immediately'. The additional investigation work plan was due 17 October 2005. 10.APEX submitted the work plan for an additional investigation on 17 October 2005, and SJCEHD approved it conditionally in a letter dated 18 October 2005. The SJCEHD required sampling of MW-4A and MW-4B weekly for one month with weekly reporting of each event, and the installation of a "ground water extraction system" prior to installing the additional monitoring wells, and added that "...installation and activation of the (interim remediation) ground water extraction system is of paramount importance." 11.APEX responded in a letter dated 1 November 2005 that a batch extraction of 28,800 gallons per day would be needed to comply with SJCEHD directive to begin interim remediation immediately, at a cost of $1,200,860 for six months. Subsequently, the daily batch extraction proposal was not approved by SJCEHD. In subsequent meetings with Mr. J. Gilbert Moore, APEX, SJCEHD, and Regional Board staff on 9 November 2005 and 22 March 2006, additional cost effective alternatives for the interim remediation treated groundwater disposal were suggested by the regulators, including discharge to land under a general permit or to the wastewater treatment plant. During the meetings, Mr. Michael Sgourakis of APEX stated that a discharge to the County Storm Water Sewer under an NPDES surface water permit was the only acceptable option to APEX. Discharge of the Site treated water to the CSA-31 wastewater treatment plant (WWTP) is not practical due to the limited capacity of the WWTP. The San Joaquin County Public Works Department estimates that the cost for MtBE wellhead treatment for CSA-31 Well 2 would be in excess of $1,500,000. 12.Also during the 22 March 2006 meeting, APEX proposed that the MtBE discharge was not from Site; that the source was the Flag City Chevron site to the south. The monitoring data or historic groundwater directions did not substantiate the evidence for a reversal of the groundwater plume from north to south. The data show that the highest concentrations of MtBE nearest the Site USTs were orders of magnitude above the highest historical Flag City Chevron MtBE groundwater concentrations. The SJCEHD and Regional Board staff verbally rejected the APEX hypothesis. 13.On 11 November 2005, APEX installed off-site monitoring wells MW-5A, MW-5B, MW-6B, and MW-6C. MtBE was not detected in the new monitoring wells from November until 30 March 2006, when MtBE was detected at 140 pg/L in groundwater at MW-6B. MW-6B is screened in the B depth at 40 to 50 feet bgs, 400 feet