ARCHIVED REPORTS_LIMITED PHASE II ENVIRONMENTAL SITE ASSESSMENT AND SUMMARY OF PROJECT TO DATE

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November 16,2005 NOA Project Number: E05120B Photographs included in the file documented the discharge of water from the Site into the adjacent ditch at Grant Lane Road and crossing the intersection of Grant Line Road and Mountain House Parkway. One undated aerial photograph showed the site prior to the construction of the existing ponds. It appears that the entire area from the current pond location to the eastern property line was a natural depression being used as a shallow manure pond. The file also contained documents pertaining to the lack of roofs in the corral areas to protect cows from the elements and to inhibit nitrate leaching into the groundwater from the stockpiled manure within those areas. A Cleanup and Abatement Order (No. 98-721) filed against the Site and its operators by the Board on May 22, 1998 was also included in the file. According to the Order, the operators were ordered to "immediately abate any and all discharges of manured wastewater into surface waters of the State," as well as to submit various plans and technical documents to the Board for review. A selection of documents from the dairy file at the EHD are included in Appendix C of this report. 5.4 Calculation of Impacted Area Based on an undated,recent, aerial photograph from Google.com,which depicts the current configuration of the wastewater ponds on the subject property,NOA calculated the total area of the corral,manure spreading, and pond areas on the Site. The total area with the potential to be impacted by manure is approximately 43 acres. Of this area,approximately 9 acres consist of the current ponds,approximately 5 acres consist of the historic pond (current manure spreading area), and the remainder consists of corrals. The manure and manure-impacted soils are anticipated to be found at varying depths in the different regions of the 43 acres. 5.5 Review of Clayton Group Services Preliminary Pipeline Findings Clayton Group Services (Clayton) has been retained by Shell to perform an investigation along the length of the former crude oil pipelines in the area,including those which cross the Site. Results of the Clayton investigation on an adjacent property to the northwest resulted in that property being placed on the Board's SL-TC database of cleanup and remediation sites. On September 7,2005, Michael Hurd of Clayton provided NOA with a preliminary map depicting the locations of soil and groundwater borings advanced along the length of the former pipelines on the Site. Clayton had identified 14 contaminated locations along the length of the pipeline on the Site based on visual inspection and laboratory results. Mr. Hurd noted that Clayton had not received all of the analytical data as of that date, so it is possible that additional contaminated locations have since been identified. NOA has not reviewed any analytical data or final reports from Clayton for the Site. • 10