SITE INFORMATION AND CORRESPONDENCE

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Phase I Environmental Site Assessment 2.0 INTRODUCTION This report summarizes the Phase I Environmental Site Assessment(ESA)performed by Carlton for the Lodi Energy Center property identified in this report as the"Site". The Site is located west of Interstate Highway 5 and immediately west of the City of Lodi's White Slough Water Pollution Control Facility (WPCF),within the City limits of Lodi,in San Joaquin County,California. The Northern California Power Agency(NCPA)retained Carlton to perform the Phase I ESA for the Site based on the ASTM Standard E 1527-05"Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process." This Phase I ESA was completed in accordance with the scope of work approved by NCPA in their May 2008 Consulting Services Agreement with Carlton. 2.1 PURPOSE The objective of this ESA was to evaluate if there are or have been any recognized environmental conditions associated with the Site. The term"recognized environmental conditions"is defined in Section 1.1.1 of ASTM Practice E 1527-05 as"the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release,past release,or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground,groundwater,or surface water of the property." The term is not intended to include conditions where there are not material risks of harm to the public health or the environment and that generally would not be subject to enforcement if identified by the applicable regulatory agencies. Under the Comprehensive Environmental Response,Compensation and Liability Act of 1980(CERCLA), owners and operators of real estate where hazardous substances have come to be located may be held strictly liable for the costs of cleaning up contamination found on their property. No evidence linking the owner/operator with the placement of the hazardous substances on the property is required. Congress,in response to pressure from business and academic groups,established the innocent landowner defense in the 1986 amendments to CERCLA known as the Superfund Amendments and Reauthorization Act (SARA),which was further updated in the amendments of the 2002 Small Business Liability Relief and Brownfields Revitalization Act. To establish innocent landowner status,the landowner must have undertaken,at the time of acquisition,all appropriate inquiry into the previous ownership and uses of the property in a commercially prudent and reasonable manner. This document strives to meet the above requirements by using the ASTM E 1527-05 standard as guidance in conducting this"due diligence" assessment. 2.1.1 Scope of Work The scope of work for this assessment,according to Carlton's Authorization,is to provide information regarding the Site history,former uses,and contamination incidents and/or potential for incidents,if any, on the Site and in the surrounding area. Carlton's assessment of this Site included(1)examination of records pertaining to the Site and its vicinity;(2)review of historic aerial photographs and maps;(3)an environmental database search;(4)interviews with persons familiar with the Site;and(5)a reconnaissance of the Site and its vicinity. Information regarding the potential for hazardous materials contamination on or near the subject property was obtained from the following agencies. • U.S.Environmental Protection Agency lists including NPL,CERCLIS,RCRA notifiers or violators,ERNS,and enforcement record lists • California State Environmental Protection Agency(Cal EPA)including Department of Toxic Substances Control,State Water Resources Control Board,Integrated Waste Management Board,and Air Resources Board • California Department of Health Services Lodi Energy Center Property ESA 3 Carlton Project No.6300-01-08 June 2008 CARLTONM E n g i n e e r i n g I n c.