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from 1060 to 12,500 parts per million (ppm). Due to the high level of TPH concentration detected in the soil and since the origin of contamination is not known,further soil characterization was warranted. Therefore on May 13, 1991, SCS advanced four soil borings on the subject site and collected one composite soil sample from each boring at the 3 foot and 6 foot level. The samples were analyzed using the methods set forth in Title 22, California Code of Regulations to determine if the soil was hazardous. The results of the analysis indicated the soil was non-toxic and non- hazardous. Pursuant to this initial soil characterization, SCS has been retained to investigate the possible impact on groundwater and to develop a remediation method of soil treatment. It is SCS'intention to proceed with further work on a self-direction basis and under the oversight of the San Joaquin County Environmental Health Department (EHD). Since the quality of the groundwater in the vicinity of the subject site is in the jurisdiction of the RWQCB, SCS would like your confirmation to proceed under self-direction and under the guidance of the EHD. Copies of the work plan and all the reports will be forwarded upon completion to the RWQCB for your records. SCS would appreciate a written confirmation at your earliest convenience. SCS's June 10, 1991 letter did not include any sample locations maps or laboratory analytical report. The CVRWQCB prepared a June 26, 1991 internal Memorandum which stated concerning SCS Engineers proposal to landfarm petroleum contaminated soils. If SCS desires to landfarm the soils they must demonstrate that the petro soils will be a benefit to the existing soils. The June 26, 1991 memorandum did not appear to respond to SCS's June 10, 1991 letter. In the absence of maps and analytical reports, it is Partner's professional opinion that SCS's statements are anecdotal and cannot be used with regard to the environmental issues related to the Site. Subsequent to the submittal of Partner's September 28, 2015 draft Workplan to the DTSC, the DTSC reviewed the cumulative available data including a 1975 aerial photograph within Partner's Phase I ESA report. Based on DTSC's review, the DTSC surmised that, as the petroleum hydrocarbon release was associated with a septic tank, a leach field, and water wells, it was possible that the petroleum hydrocarbon release may have potentially occurred adjacent to any of three particular structures observed in the 1975 aerial photograph(included in Appendix E). These three inferred locations are depicted on Figure 2. In addition, following the submittal of Partner's September 28,2015 draft Workplan to the DTSC, the DTSC reviewed statements within Partner's Phase I ESA report related to the past use of the Site as agricultural and informed Partner(personal communication, circa February 17, 2016) that soil would have to be assessed for the potential residue of environmentally persistent agricultural pesticides in order to support a request for NFA.While historical aerial photographs do not indicate Sampling and Analysis Workplan Tracy Corners Shopping Center 3225 North Tracy Boulevard Tracy,California 95376 Partner Project Number SM14-129814 Docket Number HAS-VCA 14/15-108 August 15,2016 Page 8