SITE INFORMATION AND CORRESPONDENCE FILE 2

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Rodger Liston Darpetro Inc. 749 E. Charter Way, Stockton, California Page 6 of 7 was being sampled for that monitoring event. EHD noted that a decon station had not been set up, so field equipment could not be decontaminated , including the pump. Depth to water in all of the monitoring wells had not been gauged prior to initiating purging and sampling individual wells; each was gauged , purged and sampled before moving on to the next well . Ground water samples were collected using the same PVC bailer — without decontamination . These deficiencies were brought to the attention of CCG , but the report still contained ' boiler plated' field procedures as an appendix that indicated what would have been proper procedures had been performed for the monitoring event. Although the report states that the samples were collected with a contaminated bailer, it omits discussion of the other deficiencies and even states that the pump was decontaminated . This is absolutely incorrect and the 4th quarter 2003 monitoring report should be revised to reflect the actual procedures utilized to acquire the monitoring data. Please have the revised report submitted to this office by 10 May 2004. EHD was not notified prior to CGG conducting the January 2004 event. Notification to EHD of impending site work is a standard requirement for all sites in the LOP program, and in view of the unacceptable monitoring and sampling techniques employed during the October 2003 monitoring event, you must notify EHD at least 48 hours prior to any field activities that involve collection of samples, this specifically includes quarterly ground water monitoring events. Failure to provide sufficient notification to EHD before each sampling event will most likely result in this office rejecting the data acquired and advising the State Cleanup Fund to reject reimbursement of the monitoring event expenses . In addition , you may be required to repeat the monitoring event with EHD supervision . EHD also notes that despite a clear and explicit directive in our letter of 05 September 2003 to initiate and continue monitoring of 1 ,2-dichloroethane ( 1 ,2-DCA) and ethylene dibromide (EDB) in all sampled media until directed otherwise by EHD, the January 2004 samples were not analyzed for these analytes. You are hereby directed again to analyze all samples for 1 ,2-DCA and EDB and are notified that any future reports that omit these analyses will be rejected by this office as incomplete and the State Cleanup Fund will be advised to reject reimbursement of all costs for the monitoring event. During the January 2004 monitoring event, CGG monitored nearby wells and noted drawdown of the ground water table elevation during purging of adjacent wells , thereby demonstrating that the depth to water should be gauged in all wells prior to initiation of purging of any wells . Ground water flow direction data acquired utilizing the field techniques witnessed by EHD during the October 2003 event would be suspect. Finally, you have been directed on several occasions to complete the assessment of vertical and lateral extent of impacted soil and ground water resulting from your unauthorized release. This directive was most recently issued by letters dated 11 June 2001 and 05 September 2003 and were noted in EHD letters dated 17 April 2001 and 03 December 2002. This directive has not yet been complied with. Please submit the work plan to complete this phase of site investigation by 24 May 2004. To recapitulate, the directives issued you by this letter are: 1 . By 03 May 2004, have CGG provide EHD with references for site(s) having sinking plumes due to density increases associated with addition of dissolved