SITE INFORMATION AND CORRESPONDENCE

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Canepa's Car Wash Page 2 6230 Pacific Avenue October 30, 2012 Stockton, California 95204 AGE has submitted a revised Additional Site Assessment Work Plan to delineate the lateral extent of petroleum hydrocarbon impacted groundwater. The EHD had scheduled the meeting with the goal of utilizing your funds more efficiently by mutually developing a plan to move your site to closure; but as there is stout resistance to having a meeting , the EHD will not schedule one at this time. The END directs that during the fourth quarter 2012 , MW-1 through MW-4 and SV-4 be monitored and sampled for chemical analyses for total petroleum hydrocarbons as gasoline (TPH-g) ; benzene, toluene, ethylbenzene and total xylenes (BTEX); methyl tertiary-butyl ether (MTBE) , tertiary-amyl methyl ether (TAME) , tertiary-butyl alcohol (TBA) and 1 ,2-dichloroethane (1 ,2-DCA) . Please notify the EHD of the scheduled sampling event so that an inspector can be present. The EHD is open to the proposal by AGE to reduce the frequency of monitoring and sampling the site monitoring wells from semi-annually to annually; however, before the EHD will approve any sampling reduction , technical justification must be provided for all wells proposed by AGE to be sampled annually and show that the data acquired will be adequate . As AGE stated in the email dated 16 October 2012 , there are limited funds available for site investigation , assessment, feasibility studies and development of an updated conceptual site model. Although the CUF has yet to act on the new claim for the second release, the EHD must require that adequate measures be taken to advance toward site closure in accordance with State of California law regardless of availability of monies from the CUF. Furthermore, funding from the CUF is currently scheduled to terminate on 01 January 2016. Responsible parties who have not completed corrective actions on their petroleum hydrocarbon contamination by that time may have to do so at their own expense. The EHD has changed its corrective action emphasis since 01 December 2008, when the EHD first directed the submittal of a work plan to conduct additional site assessment to delineate the groundwater plume vertically near the source area and laterally down-gradient from the source area, and a feasibility study for additional remediation . The EHD now considers monies better spent remediating the "secondary source ," defined by the State Water Resources Control Board "as petroleum—impacted soil and groundwater located at or immediately beneath the point of release from the primary source ." This is not to diminish the need to define the petroleum hydrocarbon plume and include the down-gradient impacted groundwater (both on- and off-site) in the feasibility study; but with limited funds available, it seems prudent that the focus should be on the secondary source of the initial release. If the petroleum hydrocarbon contamination in the secondary source can be reduced or eliminated by remediation, then further migration of the contaminate plume will probably be prevented . It has been the experience of the EHD that it is unlikely that any findings from the proposed off-site borings would significantly alter what would constitute effective remediation of the secondary source area. Additional borings may be useful in the suspected area of the purported second release to better focus remedial efforts more efficiently. For these reasons, the EHD directs that the feasibility study be submitted immediately. For the same reasons mentioned above, the EHD will not approve the revised Additional Site Assessment Work Plan, dated 21 September 2012 , at this time . If the off-site data are required to assess health risk to local residents, then monitoring wells should be proposed to acquire quantitative data . If it becomes necessary to conduct additional assessment off-site to achieve site closure, the EHD will direct such actions as needed .