SITE INFORMATION AND CORRESPONDENCE FILE 3

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i CAMBRIA Even though there were no discharge limitations set for fuel oxygenates, Shell' s goal was to manage the effluent from the GWE system so that no MTBE was discharged. This goal was achieved with few exceptions. On May 20, 2002, MUD staff informed us that they had lost our original discharge permit application and we needed to reapply for the permit. Based on the conditions of the original discharge permit, we submitted influent analytical data for TPHg, BTEX, and MTBE with the new discharge permit application on June 6, 2002. MUD issued a new discharge permit on June 28, 2002 which had discharge limits similar to the original permit, but MTBE was now regulated ! © at <0.5 parts per billion in our effluent. We continued to operate the GWE system under the new discharge permit conditions until we received MUD' s October 9, 2003 letter (received on October 14, 2003), which informed us that the permit conditions had again changed to where no detectable levels of fuel oxygenates would be allowed in our effluent. We shutdown the GWE system on October 14, 2003 because we did not have sufficient data to confirm that our effluent did not contain detectable levels of fuel oxygenates. Discharge Limit Discussion with the City of Stockton We discussed these new discharge limits with MUD staff and pointed out that they were requiring that the site' s effluent levels be cleaner than drinking water standards prior to being discharged into the sanitary sewer. We also provided MUD with information from other waste water treatment plants in California that showed that MUD' s discharge limits are more stringent than any other municipality we have worked with in the state of California. At one point during these discussions, MUD staff asked us to provide them with information about other municipalities discharge limits, to propose reasonable discharge limits for MUD staff consideration, and to also provide information to MUD about the capability of their waste water treatment plant to treat fuel oxygenates. We presented this information to MUD staff and were hopeful they would alter the discharge limits for our permit to allow low level discharge of fuel oxygenates, however the discharge limits were not changed. NPDES Permit Application After our attempts to discuss the discharge limits with MUD resulted in no change to our discharge permit, we then began the process of preparing an NPDES permit application. An NPDES discharge permit typically allows for low levels of gasoline constituents in the effluent 0783 2