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December 26, 2014 Subject: Work Plan for Additional Sampling Tracy Corners Shopping Center(Quality Cleaners) 3081 North Tracy Boulevard Tracy, California 95376 Partner Project Number P14-129814.3 Project History Partner Engineering and Science, Inc. (Partner) completed a Phase I Report on December 9, 2014 for the subject property. During Partner's on-site investigation, Partner noted the presence of a dry-cleaning tenant known as Quality Cleaners. According to an interview with the property manager, this site has operated as a dry-cleaning facility since 1992. Although the current closed-loop dry-cleaning machine (installed in 2007) uses a hydrocarbon-based solvent (DF- 2000 Aliphatic Hydrocarbon Fluid) for dry-cleaning purposes, the prior closed-loop dry-cleaning machine (operational from 1992 to 2007), used chlorinated solvents, particularly tetrachloroethene (PCE), during the dry-cleaning process. Chlorinated solvents (a.k.a. CVOCs) are highly mobile chemicals that can easily accumulate in soil. These solvents, even when properly stored and handled, can readily migrate into the subsurface as a result of small releases associated with onsite operations. Partner observed two 55-gallon steel drums (one containing new DF-2000 Aliphatic Hydrocarbon Fluid and one containing dry-cleaning process waste sludge) adjacent to the dry- cleaning machine. Steel secondary containment was noted around the dry-cleaning machine. In addition, no significant staining or cracking was observed in the area around the dry cleaning unit or around the hazardous waste storage area. According to the most recent waste manifest on site, Technichem, a licensed transporter of hazardous waste, collects the waste sludge. According to the property manager, a prior subsurface investigation performed in 1999 indicated that soil beneath the dry-cleaning tenant space had not been impacted by chlorinated solvents. However, based on the length of time between the prior subsurface investigation and the change from the PCE-based dry-cleaning machine to the hydrocarbon-based dry-cleaning machine (approximately eight years), the former use of chlorinated solvents represents a recognized environmental condition. Partner completed a Phase II Report on December 19, 2014 for the Quality Cleaners unit in the Tracy Corners Shopping Center to investigate the potential impact of PCE and related CVOCs in sub-slab soil gas as a consequence a potential release or releases from the dry cleaning facility. The scope of the Phase II Investigation included the installation of four sub-slab soil gas probe samples and analysis of four samples and one duplicate sample for PCE, trichloroethene (TCE), cis-1,2-dichloroethene (cis-1,2-DCE), trans-1,2-dichloroethene (trans-l,2-DCE), and vinyl chloride.