SITE INFORMATION AND CORRESPONDENCE

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Flag City Chevron • - 6 - • 20 March 2012 6421 Capitol Ave., Lodi, San Joaquin County Consultants Recommendations: In the Closure Summary Report — August 2005, the Site consultant recommended the following: • "No further subsurface investigation at this time. Flag City Chevron has adequately assessed MTBE- impacted soil and groundwater associated with the Flag City Chevron UAR. • Recession of the Cleanup and Abatement Order(C&A) 5-00-700. Because the Banner Avenue MTBE plume encroached onto the Flag City Chevron property and has essentially interfered with the on-going cleanup efforts, the status of C&A 5-00-700 should be modified. AGE is of the opinion that all prior conditions of C&A order 5-00-700 order have been diligently met, and that the Flag City Chevron should not be held to the C&A order for the cleanup of the Banner Avenue MTBE plume. Furthermore, it is our understanding that the primary reason for the issuance of the C&A order was because of the MTBE impact to the domestic drinking water well formerly located at the Rocky's' Restaurant. Since the Rocky's domestic well has been abandoned and is no longer a threat for contamination impact, the C&A order is unnecessary. • Consideration of the facility for closure as a low risk groundwater site. From previous data, AGE has documented that MTBE concentrations in groundwater at the site have been at non-detectable or near non-detectable levels. Fate-and- transport model techniques have been used to demonstrate that concentrations of remaining MTBE in groundwater would not affect the CSA well, though there is the potential for limited impact to water above 50'bgs in well MW-10. Furthermore, the Banner Avenue MTBE plume that migrated onto the Flag City Chevron Property is no longer being drawn by the pump-treat groundwater extraction operations, and has most likely began dissipating with the natural gradient towards the east-southeast. • Abandon monitoring wells MW-1 through MW-20 in accordance with applicable regulations as part of site closure preparations: AGE will contact the consultants for New West Petroleum to discuss the possibility of transferring responsibility of certain monitoring wells (i.e. MW-8, MW-10, MW-19 and MW-20) that could still be utilized for their investigation." Public Comments to Date: In a letter dated 17 April 2006 Regional Board staff solicited public comments from all parcel owners and operators within 200 feet of the Site for 30 days for the proposed closure. Comments were received (Flag City Chevron responses in parentheses and italics) from the following respondents: 1) New West Petroleum • That the only source of the release was the Site alone (New West unsuccessfully contended that there was no evidence for an MtBE release at their site, which impacted Site),