SITE INFORMATION AND CORRESPONDENCE

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s Walter Shockey c/o Lee Shockey 26 February 2009 850 Milgeo Avenue Page 2 of 3 Ripon, CA The EHD work plan approval of 24 June 2002 included as a comment/condition "Prepare a Corrective Action Plan including feasibility studies with comparisons". This should have been regarded as a directive if the approved work plan was implemented without further amendment of that comment/condition. Failure of a particular pilot study or remediation attempt does not satisfy or cancel the general directive to prepare a CAP or feasibility study for interim or final remediation. At your request, a meeting was held at the EHD office on 22 January 2007 to review your site status. The Request states that Margaret Lagorio attended that meeting which is in error. A copy of the sign in sheet for the meeting attendees is enclosed. During preparation for the 22 January 2007 meeting a primary objective of the EHD was to get at least interim remediation implemented on your site; enough was understood about your site to at least prepare an FS and CAP. Indeed, this appeared to also be an AGE objective based on the AGE-prepared Agenda (copy enclosed) item 11 (Discussion of Remediation Methods) and item III (Conceptual Agreement of Remedial Action). Because plume delineation is a requirement of the Central Valley Regional Water Quality Control Board (CVRWQCB) for concurrence with a closure recommendation from the EHD, the EHD had directed and concurred with AGE to perform additional groundwater assessment, even though remediation of off-site groundwater is generally not conducted. It was EHD's impression that during the meeting it was agreed to proceed with both additional groundwater assessment and preparation of an FS and CAP concurrently. The impression that progress toward groundwater remediation was part of the action plan agreement at the meeting is shown by item No. 9 of the EHD letter of 22 May 2007, (about which AGE correctly pointed out that the EHD erroneously gave the meeting date as March 2007, instead of the actual 22 January 2007). Item No. 9 stated: Interim corrective action in the former UST location was discussed at the March 2007 (corrected to 22 January 2007) meeting. The submitted WP does not address this nor does it have any recommendations to reduce soil and/or groundwater contaminant concentrations. Soil excavation and groundwater extraction should be considered and addressed, along with any other potentially applicable remediation methods in a feasibility study. A high priority for EHD is that you are working towards corrective action to mitigate the near free product concentrations in groundwater. This statement echoes the previous directives and was intended to point out one of the deficiencies of the 06 March 2007 work plan being commented on in the EHD letter; indeed the'following statement directed submittal of an addendum work plan, with the implication to address the identified deficiencies. The EHD is surprised to realize that there is such a high degree of confusion regarding what directives have been issued for your site. To eliminate any confusion by any party, you are hereby directed to prepare an FS and CAP for remediation of soil and groundwater impacted by the unauthorized release from the underground storage tank system formerly on your site. These documents are due to the EHD no later than 01 May 2009. The four documents AGE requested EHD to comment on included a recommendation for continued quarterly groundwater monitoring. The EHD has been reviewing the Comment and Directive Letter 0209