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McEllin Real Estate Investment - 2 5 June 2017 2154 S. El Dorado Street Stockton, San Joaquin County While AEG .did not analyze naphthalene in collected samples, benzene concentrations can be used as a conservative estimate for naphthalene, and as benzene was below reporting limits, it is unlikely that naphthalene exceeds the LTCP thresholds. AEG also analyzed soil samples collected from 10 and 15 feet bgs in B-10 and B-11 for volatile and semi-volatile organic compounds (VOCs and SVOCs), polychlorinated biphenyls (PCBs), and Title 22 metals. VOCs, SVOCs, and PCBs were below reporting limits in all four analyzed samples, and detected metals are low and likely within regional background levels. As such, no additional assessment of waste oil constituents is necessary. AEG detected total petroleum hydrocarbons as gasoline (TPHg) and benzene above reporting limits in the grab groundwater sample collected from B-10 at concentrations of 4,860 and 1,050 micrograms per liter (ug/L), respectively. However, recent groundwater data from monitoring well MW-1, screened from 90 to 95 feet bgs, suggest that the vertical extent of hydrocarbon impact to groundwater appears defined on-site. In the Site Assessment Monitoring Well Installation Work Plan Addendum - October 2016 dated 25 October 2016, in additional to the soil borings discussed above, AGE proposed the installation of off-site deep wells MW-11 and MW-12 and shallow well MW-13, as well as advancing off-site borings B-14 through B-17. In a letter dated 7 November 2017, Central Valley Water Board staff concurred with the proposal, but requested two additional borings east and southeast of B-16 and B-17. In email correspondence on 28 March 2017 with Mr. Tim Cuellar of AGE, Central Valley Water Board staff concurred with postponing installing the off-site borings until the groundwater quality data from wells MW-11 through MW-13 had been reviewed. Additionally, in an email dated 18 May 2017, Mr. Cuellar indicated that due to significant outstanding Cleanup Fund (CUF) reimbursement claims, you cannot afford to perform the well installations until reimbursement for previous work is received. Mr. Cuellar indicated that the reimbursements will likely arrive by July or August of 2017, after which time, AGE will proceed with the well installation. Once the wells are installed and sampled, the need for the additional downgradient borings will be assessed. By 30 August 2017, please provide a status update of the CUF reimbursement and the well installations. In summary, Central Valley Water Board staff request the following: By 30 August 2017, please provide a status update of the CUF reimbursement and the well installations. By 1 September 2017, please perform a second round of soil gas sampling, and submit a Second Soil Vapor Report, including comparison of collected data to LTCP VI criteria.