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JAN 2 8 2008 vas/os SHININGTREE — Mr. Jeff Welch Agency Compliance Manager Basic Resources Inc. P.O. Box 3191 Modesto, CA 95353-3191 Re: Munn&Perkins/Asphalt Concrete Plant /Wet Scrubber Effluent Character Dear Mr. Welch: We submit this report to amplify our earlier assertion that the wet scrubber effluent is essentially the same as the wet aggregate plant effluent. Both effluents are composed of water in contact with identical aggregates. No contact is made between the wet scrubber water and the asphalt portion of the AC process. Attached is Section 300 of the Compliance Manual for Asphalt Concrete Plant prepared by the California Air Resources Board. A complete description of the Batch type process is cited. Particular attention is drawn to Page 300-3, Figure 301.1. The figure shows how the portion of the Batch type process, which picks up aggregates to mix with water in the scrubber, is segregated from the portion of the process in which asphalt is introduced and mixed. This segregation is essential to the proper operation of the wet scrubber. If oil products could enter the wet scrubber, the oils would interfere with the proper operation of the wet scrubber. As further verification of this segregation, we have made extensive internal investigations of the wet scrubber three times in the last five years. These inspections include all day entry into the scrubber to view and make repairs within all scrubber compartments. Particular attention is paid to the presence of any foreign material in the scrubber compartments. To date no trace of petroleum products have been made. If such a material had been found in the scrubber, immediate remedial action would have been taken. Sincere REA Environmental Services 0 P.O. Box 1875 - Murphys, CA 95247 0 (209)728-2519 0 Fax (209)728-2533 0 Earth Sciences