SITE INFORMATION AND CORRESPONDENCE

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Phase I Environmental Site Assessment 1.0 SUMMARY At the time of the environmental assessment conducted by Carlton Engineering,Inc.(Carlton),the Northern California Power Agency Project property(the Site)was partially developed with paved surfaces,gas compressor and cooling towers,and the remainder of the Site was undeveloped. The Site is located west of the Interstate Highway 5 and the City of Lodi's White Slough Water Pollution Control Facility within the City limits of Lodi,in SanJoaquin County,California. Through record review,interviews with persons knowledgeable of the Site area,and historical aerial photograph observation,Carlton found that the Site was structurally undeveloped prior to the early 1990s and used for agricultural purposes before that time. Construction materials supporting the adjoining Water Pollution Control Facility's improvement projects have stored on the Site. Two automotive batteries were also observed amongst the construction materials on the Site. Gray silty material with waste materials characteristic of waste-water-pond sludge were observed in the northern portion of the Site property. The presence of these materials and other observed conditions on the Site is considered to fall within the category of"de minimis conditions". De minimis conditions are defined in ASTM E 1527-05 as"conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies". Carlton considers the likelihood of hazardous materials or petroleum products impacts to the soil or groundwater at the Site from onsite and offsite sources to be low. However,some possibility of impacted soil and groundwater existing in areas not chemically analyzed must be recognized. After review of reasonably ascertainable data,analysis of field observations,review of environmental records,and interviews with persons knowledgeable about the Site,Carlton found no evidence of existing or past recognized environmental conditions at the Site. Carlton has concluded that the likelihood of contamination at this Site is low;however several conditions regarding the potential for environmental concern at the Site were noted and are summarized here with recommendations for the Client's consideration. • Two automotive batteries were observed in the northern area of the Site and the batteries should be removed to an approved disposal or recycling facility. The drums of curing compound,and buckets of lubricating compound,along with the other construction materials should be removed from the Site. • Scattered surface deposits and push piles of gray silty material with waste materials characteristic of waste-water-pond sludge were observed in the northern portion of the Site property(likely remaining from the temporary stockpiling of sediment in the 1980s and 1990s). Typically,these types of materials have the potential to contain concentrations of heavy metals that could cause them to be classified as designated or hazardous wastes. We recommend consideration be given to conducting laboratory analysis of samples of the materials to assess if the silt contains elevated levels of any metals of potential concern(thereby causing the presence of the silt/sludge to be considered a recognized environmental condition),and if any special handling,disposal or placement requirements would apply to the materials during project development. Alternatively,the materials could be removed from the Site to an appropriate disposal facility,and confirmation samples of the underlying material could be collected and analyzed to verify adequate removal has taken place. • Considering that suspect oil staining was observed on the ground surface near the graveled drive path through the Site,we recommend that the extent of the affected area be observed during project development,by an environmental professional to determine if extensive oil staining is Lodi Energy Center Property ESA 1 Carlton Project No.6300-01-08 June 2008 CARLTON IM E n g i n e e r i n g I n c.