SITE INFORMATION AND CORRESPONDENCE

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L Mr. David Johnson • -3 - • 20 May 2011 Herman and Helen's Marina locations and are willing to discuss this at a meeting, recent groundwater data indicate that LPH is still on the water table beneath the Site and additional remediation is needed. H&H proposed performing the ORC pilot study in response to our decision to recommend to our management that we issue a cleanup and abatement order for this Site. An ORC Pilot Study Report was due on 3 January 2011; however, H&H has not yet conducted the study. H&H stated that stalled access negotiations with the U.S. Army Corps of Engineers Reclamation District 2029, have hindered performance of the pilot study, but has not asked for our assistance with gaining access. Since May 2010, concentrations of TPHg and TPHd increased sharply in MW-2 and MW-3 and TBA concentrations increased in MW-3 and EW-1. If the ORC pilot study is not completed, we will reconsider our decision not to recommend that we issue a cleanup and abatement order. 2. The concentrations of TPHg and TPHd observed in MW-2 during the fourth quarter indicate that LPH may be present in the vicinity of the MW-2. However, it does not appear that AGE is monitoring for LPH, which is a violation of the MRP. Future monitoring events shall include monitoring for LPH in wells that may contain it in compliance with the MRP. Alternatively, if the wells are being monitored for LPH, the procedures for monitoring LPH need to be documented in the monitoring reports. 3. The recent increases in groundwater elevation and contaminant concentrations indicate that more active remediation is required. 4. The elevated TPH and oxygenate concentrations observed during the fourth and first quarters indicate that discussions of site closure are currently premature. 5. Historical monitoring results for MW-9 show that it has been non-detect for contaminants of concern since September 2007. Therefore,we concur with H&H's request to abandon this monitoring well. Please submit a work plan proposing abandonment procedures. Failure to conduct monitoring in MW-8, MW-10 and MW-12 constitutes a violation of MRP No. R5- 2009-0833. Please address the accessibility issues at these monitoring wells so that scheduled monitoring can resume by the second quarter 2011. We will contact you shortly after you receive this letter to schedule the meeting you requested. If you have any questions regarding this letter, you may contact me at (916) 464-4811 or at betaylor@waterboards.ca.gov. BRIAN E. TAYLOR, P.G. Engineering Geologist cc: Ms. Adrienne Ellsaesser, San Joaquin Environmental Health Department, Stockton Mr. Arthur Deicke, Advanced GeoEnviron mental, Inc., Stockton