SITE INFORMATION AND CORRESPONDENCE

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Chevron Compliance Page 2 In late May, Chevron submits a work plan for additional assessment and in late June four soil borings and a monitoring well are installed. In late September, Chevron submits a summary report and states that a corrective action plan to design and implement remedial actions would be submitted by 1/31/95. PHS/EHD responds in early November and directs Chevron to submit the corrective action plan by late December. In early December, Chevron responds that the corrective action plan would be submitted by December 30, 1994. Chevron also submits the third quarter 1994 report. 1995 In late January, Chevron requests an extension for the submittal of the corrective action plan until 5/15/95. In late September, Chevron submits the fourth quarter 1994 groundwater monitoring report, first quarter 1995, second quarter 1995 and the Geraghty and Miller work plan for Soil and Groundwater Remediation Services. In late November, PHS/EHD described to Chevron the problems with their compliance with regulatory directives, how the work plan failed to satisfy corrective action regulations, and that PHS/EHD did not agree with their proposed remediation goals. PHS/EHD stated that before goals less stringent than background were proposed, it must be demonstrated with physical data that the best available technology had been implemented and that any further remediation would not be technologically or economically effective for the benefit observed. A compliance schedule was also established and PHS/EHD indicated that should the schedule not be met that enforcement actions would be initiated. In early December, a meeting was held with Chevron and the following compliance schedule established: 12/23/95 Submit a drilling permit application, amended site map and a health and safety plan. 1/15/95 Submit a permit application to SJVUAPCD. 1/30/95 Submit a building permit application to the City of Stockton. 4/15/96 Start up interim remediation system 10/15/96 Submit a corrective action plan. In late December, Chevron submits the third quarter 1995 report. 1996 In early January, Chevron's consultant submits a drilling permit application to install air sparge and vapor extraction wells. In early July, PHS/EHD notifies Chevron that they are out of compliance. In late July, Chevron submits the fourth quarter 1995 monitoring report, first quarter 1996 monitoring report, a copy of the SJVUAPCD authority to construct permit, and the following amended compliance schedule: 8/9/96 Submit a building permit application to the City of Stockton and the second quarter 1996 monitoring report. 10/4/96 Begin drilling well/install system 11/29/96 Start-up interim remediation system 5/30/97 Submit a corrective action plan. In late August, Chevron's consultant faxes copies of the building permit application. In early October, PHS/EHD reviews the second quarter 1996 monitoring report and Chevron's phone message wanting to postpone remedial action. In early October, PHS/EHD forwards to Chevron a certified enforcement letter with the following directives: 10/21/96 Drilling must be initiated. 11/29/96 System constructed for operation. In late October, an administrative hearing is scheduled with Chevron, SJC District Attorney's Office, PHS/EHD and the Central Valley Regional Water Quality Control Board for 10/24/96.