SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Technical and Equipment problems: Engineering concern: We are not able to define the degree or level of health risk i.e. our. Engineering reports a 95% success removing of containments. The killer question remains "how much is enough?" ISSUES: To this date we are not able to obtain site closure with a 5% residual Since present technology will not achieve total mass removal to the level of non-detect (ND) status remaining (5 %) we believe conditions remaining at the site will not adversely impact water quality, health. or other beneficial use. The engineering firm of Advanced Geo Environmental (AGE) has supported closure- stating additional effort to clean up site would not be cost effective, that no further action is justified or needed. The ATC Engineering firm has provided a request for closure on November 23, 2004 requesting closure, this report cost $11,000.00 and was denied by Environmental Health. In order to comply with regulatory directives mandated by EVH we have requested an additional work plan needed to remain in compliance. The draft work plan estimated cost exceeds $200,OOO.a time frame of (2) years. The most recent notice from State Water Resources Control Board (SWRCB) stating the UST fund cannot pay its bills and that a delay in payments on active claims will continue Advanced Geological Environmental has advised Chapin Bros that age will be unable to offer a "cost-float" for assessment and remediation charges incurred at our site during these budget-challenged times. Causing the cash flow out of pocket. In summary: Chapin Bros, Inc. has directed our consultant, Advanced Geo-Environmental Inc. (AGE) to prepare a work plan "that includes assessment and criteria by the State Water Resources Board FOR CLOSURE CONSIDERATION. Requesting the Environmental Health respond to our closure request with a technical presentation that shows why closure of our site is not justified.