SITE INFORMATION AND CORRESPONDENCE

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Phase I Environmental Site Assessment None of the information reviewed or received from interviews with public agency personnel during this assessment revealed records of,or strong enough evidence for soil or water impacts from past or present Site uses to conclude that recognized environmental conditions exist or previously existed on the Site. Conditions with potential to be considered as recognized environmental conditions were observed on the Site. Surface deposits of gray silt characteristic of waste-water-pond sludge were observed in the northern portion of the Site property. Waste water treatment plant sludge can contain concentrations of heavy metals that could result in the materials being classified as designated or hazardous wastes. Laboratory analysis of the materials would be needed to determine if the silt contains high levels of any metals of potential concern. 8.2 CONCLUSIONS Carlton has performed this Phase I Environmental Site Assessment in conformance with the scope and limitations of ASTM Practice E 1527-05 for the property described in Section 2.0 of this assessment. The property is identified as a portion of San Joaquin County Assessor's Parcel Number 055-130-16,and as a portion of the property addressed as 12751 North Thornton Road,consisting of approximately 5.4 acres located west of Interstate Highway 5. Any exceptions to or deletions from this practice are described in Section 2.2 of this report. This assessment has revealed no evidence of recognized environmental conditions in connection with the Site. 8.3 RECOMMENDATIONS 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 suspected and if soil sampling and analysis is warranted to assess whether remediation may be required or not. • Carlton understands that the Client has no intent to use the shallow/perched zone groundwater at the Site for domestic/drinking water purposes. Considering the recent analysis results of groundwater samples from the onsite monitoring well WSM-2,it is recommended that if the shallow or deeper aquifer groundwater resources of the Site are to be utilized in the future,then groundwater quality analysis and evaluation is recommended prior to use of the groundwater. Lodi Energy Center Property ESA 14 Carlton Project No.6300-01-08 June 2008 CARLTON IM E n g i n e e r i n g I n c.