SITE INFORMATION AND CORRESPONDENCE FILE 2

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q Darpetro, Inc. Page 2 of 3 749 E . Charter Way 05 December 2008 Stockton, CA At the 13 March 2008 meeting with your current consultant, Apex Envirotech , Inc. (AEI ) agreed to provide to the EHD an estimate of the petroleum hydrocarbon mass in soil and in groundwater, the SCM , the SVE report , and to install monitoring well MW-15 on the East Charter Way sidewalk and possibly an additional monitoring well between BM-6 and the contaminant source area on the 701 E . Charter Way site to test the model suggested by your former consultant Lee and Pierce, Inc. To date , the following has been accomplished : your former consultant, Lee & Pierce, Inc. ( LPI ) submitted the report on the SVE test. None of the other directives have been complied with , none of the above noted reports or data AEI agreed to provide the EHD has been provided , the monitoring wells have not been installed . In the SVE report, LPI concluded that petroleum hydrocarbon vapor could be recovered at a rate between 5 and 7 pounds per day, but recommended utilization of SVE only as part of a groundwater remediation program . LPI did not verify the estimated 48 , 000 plus pounds of petroleum hydrocarbons estimated by a previous consultant to have been removed by SVE ; possibly because most of the data available are photo-ionization detector ( PID ) readings, which are not reliably quantitative. The SCM is needed to ensure that AEI and the EHD agree on possible data gaps, critical aspects of your plume and plume behavior, and can reasonably predict plume migration , stabilization or contraction , and plume response to remediation technologies. The consultant for the site at 814 E . Charter Way has provided an SCM that explains increasing total petroleum hydrocarbons quantified as gasoline (TPHg) in their northern monitoring wells MWA08 and MW-208 as originating from an off-site source — yours being one of the potential sources . Based on the information available , the EHD is inclined to accept their interpretation . Groundwater on your site is intensely impacted in the source area , the modeled plume covers a large area . As the suspected source area is close to the down- gradient property boundary, it is very probable that dissolved contaminants are actively migrating off-site . Groundwater remediation will be necessary to move your site toward closure; hence the numerous directives from the EHD to submit an interim remediation feasibility study to identify the technology likely to be most cost-effective for your site. As the SCM evaluation or revision and the interim remediation feasibility study for groundwater remediation have been previously directed without results , you are now directed to submit the documents within 14 days of date of this letter. Failure to submit the required documents may result in referral of your site to the Central Valley Regional Water Quality Control Board for enforcement action . You are also directed to submit a well permit application and appropriate fees to this Directive Letter 1208.doc