SITE INFORMATION AND CORRESPONDENCE FILE 2

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• Page 2 November 7, 2003 02/03 The SJCEHD issued Palisades a Notice of Responsibility dated February 3, 2003, identifying Palisades as a responsible party(RP) based on increased concentrations of MTBE in March and May 2002. 03/03 Palisades filed a petition on March 25, 2003 with the State Water Resources Control Board (SWRCB), objecting to the designati SJCEHD as an RP. on of Palisades by the 04/03 Palisades' USTs failed a tracer test that confirmed the UST system was leaking. 05/03 The SJCEHD filed a second URR against Palisades due to the failed UST tracer test. 05/03 Groundwater samples collected from VEW3 contained TBA at a concentration of 23,400 ug/L. Currently, we are awaiting the SWRCB's decision concerning Palisades' petition to be removed as an RP. The point of contact for the Underground Storage Tank Program, State Water Resources Control Board, Division of Water Quality concerning this issue, Ms. Terry Brazell, can be reached at (916) 341-5645. After fuel additives were detected in the storm line along Plymouth Road near Country Club Boulevard, the City of Stockton retained Condor Earth Technologies, Inc. (Condor) to conduct a groundwater investigation to assess the source for detected fuel additives in the stom7 line. Condor assessed the potential impact that the 7-11, former ExxonMobil, and Shell service stations may have had on the stoml line, and concluded that "the Shell Oil site appears to be the source of contaminated groundwater that infiltrates the storm drain along Plymouth Road." Cambria Environmental Technology, Inc. (Cambria), on the behalf of Shell Oil Company, published a report titled Plymouth Road Storm Drain Summary Report, and concluded that "there is not enough data to definitively conclude that any of the service station sites are not contributing contaminated groundwater to the storm drain." During the meeting on October 31, 2003, Ms. Karen Petryna of Shell Oil Company indicated that no amount of information could support a conclusion that a service station is not contributing to fuel additives detected in the storm line. As we discussed in the meeting on October 31, 2003, groundwater elevations have risen over time. Based on risin4 groundwater conditions at the site, Exxon-Mobil installed wells MW9 and MW10 (screened from 5 to 20 feet below grade) immediately next to wells MW2 and MW3 (screened from 12 to 27 feet below grade) to ensure that the groundwater data collected from these wells were representative of subsurface conditions. Attached are graphs which present this rising goundwater condition over time. Also presented on these graphs are (1) the concentrations of petroleum hydrocarbons and fuel additives over time, (2) the elevation of the shallow sanitary sewer line near each well based on invert elevations and the assumed elevation of the bottom of the backfill (one foot below the base of the sanitary sewer line), and (3) the property transaction dates (ExxonMobil sold the property to New West Petroleum in 1995, and New West Petroleum sold the property to Palisades in 199-). Based on a review of these graphs, the shallow sanitary sewer line was historically not submerged. Of the constituents detected in samples collected from the stone lines and the storage tanks, the