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15135 Eight Mile Road -3- 1 October 2018 Stockton, San Joaquin County The Central Valley Water Board issued General Order No. 5-00-119 on 12 June 2008, which superseded General Order No. R5-2008-0085. General Order No. R5-2008-0085 granted 180 days of coverage from the date of adoption to enrollees under General Order No. 5-00-119. In November 2008, H&H paid the General Order annual renewal fee but failed to submit a Notice of Intent for coverage under General Order No. R5-2008-0085 by the end of this 180-day period. On 18 June 2009, Central Valley Water Board staff notified AGE that H&H was discharging treated groundwater without a permit and on 25 June 2009 H&H ceased extracting and discharging groundwater. On 20 August 2009, the Central Valley Executive Officer issued MRP R5-2009-0833 which replaced MRP No. R5-2004-0828. On 3 December 2009, Central Valley Water Board staff prepared a draft Cleanup and Abatement Order for comment; this order would have required enrollment under General Order No. R5-2008-0085 and continued operation of the GWETS; however, during the comment period H&H stated they did not wish to be required to continue to implement the same remedial technology and this CAO was not issued. In May 2010, AGE submitted a work plan for an in situ chemical oxidation (ISCO) pilot study at the Site. In August 2011, AGE requested that MRP No. R5-2009-0833 be suspended during the proposed ISCO pilot study, and on 14 September 2011, the Central Valley Water Board Assistant Executive Officer rescinded this order. However, the ISCO pilot study never took place. Beginning around November 2011, cleanup and investigation worked ceased at the Site under direction of then marina operator, David Johnson. On 21 October 2013,the Reclamation District subpoenaed business and environmental records related to the operation of the Site marina from David Johnson. During the third quarter of 2014, AGE began working on behalf of the Reclamation District and on 17 November 2014, AGE produced a Third Quarter 2014 groundwater monitoring report. In April 2015, AGE destroyed three monitoring wells in preparation for levee upgrade construction work at the Site. In order to assess Site conditions under the State Water Resources Control Board Low-Threat UST Case Closure Policy(LTCP), AGE collected an additional seven shallow confirmation soil samples in March 2016. AGE collected these samples from an area with historical petroleum hydrocarbon concentrations exceeding the San Francisco Bay Regional Water Quality Control Board (SFRWQCB) Environmental Screening Levels (ESLs)for direct contact with soil. The results of this soil sampling, as well as the applicable ESLs, are documented in Table 1 and discussed in the Risk Evaluation portion of this memo. CONSTITUENT DATA Soil —AGE conducted confirmation soil sampling in March 2016 to quantify concentrations of petroleum constituents remaining in shallow soil near the ASTs and former USTs; samples collected from the area in 2002 and 2003 exceeded SFRWQCB ESLs and the applicable LTCP criteria. Results of the March 2016 confirmation soil sampling and historical soil sampling conducted in this vicinity and applicable environmental screening levels are presented in Table 1. Di-isopropyl ether(DIPE), ethyl tert butyl ether(ETBE), 1,2-dichloroethane (1,2-DCA), and were not detected above reporting limits in soil samples obtained beneath the Site. MTBE was detected in multiple shallow soil samples across the Site with the maximum detection being below the commercial SFRWQCB ESL, as shown in Table 1. Tertiary-butyl alcohol (TBA), tertiary-amyl methyl