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i. 2008 In their letter dated August 15 , 2007, the SJC/EHD concurred with the recommendations made for the completion of a work plan to investigate the impact of the off-site dewatering activities that were conducted during the third quarter 2006 as part of the site closure process. Clearwater submitted the Groundwater Investigation Work Plan on September 25, 2007, to the SJC/EHD. In their letter dated October 12, 2007, the SJC/EHD concurred with the recommendations for additional investigation presented in the aforementioned work plan with the condition that the soil borings extend to a depth of 25 feet below ground surface to intercept and collect groundwater samples from the sand unit noted as "commonly occurring across the site at that depth." During the regularly scheduled O&M event on March 14, 2008, Clearwater marked the proposed soil boring locations with white spray paint as required by Underground Services Alert. Clearwater prepared and submitted a soil boring permit application to the SJC/EHD on April 11 , 2008, and an encroachment permit application to the City of Stockton Department of Public Works on April 14, 2008. Because the proposed soil borings were located at the intersection of South Fresno Avenue and La Vita Drive, a main thoroughfare and traffic artery, the City of Stockton required the submittal of a comprehensive traffic plan with the encroachment permit request. Because of the extensive network of underground utilities located within the vicinity of the proposed soil borings, Clearwater sub-contracted the services of Jim Rezowalli (GP # 921 ) with J R Associates, an engineering geophysics firm located in San Jose, California, to look for geophysical indications of buried utilities in the vicinity of the proposed soil borings. In order to confirm that the actual locations for each proposed soil boring were clear of underground utilities, Clearwater requested that the survey event be completed in conjunction with the drilling event. On May 5, 2008, after overseeing the implementation of the traffic control plan by Traffic Management, Inc., of Sacramento, California, Clearwater personnel met with Mr. Rezowalli to begin the utility survey within the area marked for Underground Services Alert. The results of the utility survey indicated that each of the proposed soil borings was located within 2 feet of an active utility. Because the previously proposed soil boring locations had been deemed unsafe to drill, Clearwater relocated the proposed soil borings to areas that appeared to be clear of active utilities. However, these locations fell outside the perimeter marked for Underground Services Alert, and therefore the investigation event needed to be delayed until a new drill ticket could be obtained from Underground Services Alert. Because the locations for the soil borings had changed, Clearwater contacted the City of Stockton Department of Public Works to inquire whether a new encroachment permit would be required before the investigation could proceed. It was determined by the City of Stockton that an updated traffic plan would be required, but the existing encroachment permit could be modified and updated to incorporate the change in investigation locations . On May 30, 2008, Clearwater Project Manager Jessica Moreno and Field Manager Eric Austin met with Ms. Lori Duncan from the SJC/EHD, to review the newly proposed soil boring ZB178 — Site Investigation History 6 Updated March 2010 Barnes Trucking Facility — 1817 South Fresno Avenue, Stockton, California