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Mr. Kevin Graves April 28, 2006 Page 6 Paragraph six, the third paragraph of page 2, of "The Work Plan is not approved" letter says to "Provide details on how the test will be conducted." See page A-11 of the Tr-Regional Board Staff Recommendations and several standard texts. Monitoring wells MW-3 and MW-4 are constructed as two inch diameter wells in a aquifer of unknown hydraulic properties (that's why we're performing the 'pump tests'). To a certain extent testing under such conditions is an iterative process requiring some experimenting, or fine tuning, prior to having a successful test. H2OGEOL has performed a few well and aquifer hydraulic evaluation pump tests in San Joaquin County, that were submitted to EHD over the years. Work plans that "Provide details on how the test(s) will be conducted" were not required from H2OGEOL for these pump tests. H2OGEOL declines to provide procedural guidance, viz., a procedures manual, to competitors through client work plan/proposal shopping. Read - trade secret. Paragraph six goes on to say "If needed, a constant rate pumping test should be designed and conducted to derive aquifer parameters that can be used to quantify plume capture if groundwater extraction is necessary for remediation." This is a redundancy when the work plan stated "Should a longer test be determined to be feasible, a constant rate test will be designed and performed in either or both of these wells." Once again, see Page A-11 of the Tr-Regional Board Staff Recommendations Paragraph seven, the fourth paragraph of page 2, of "The Work Plan is not approved" letter is a repetition of the requirements of the first paragraph on page two of the October 17, 2005 EHD letter. As can be seen from the fact that R. B. Construction, Inc. proceeded immediately with the fully justified Static Water Level Monitoring of Wells MW-1, MW-2, and MW-4, the reporting of which was submitted on December 30, 2005 that the owners. had every intention of fully cooperating with the requirements of the EHD. The First Quarter 2006 groundwater monitoring event at 26056/26080 North Thornton Road in Thornton had been scheduled during January 2006 and was to include all six monitoring wells in accordance with the October 17, 2005 EHD letter. However, rejection by under qualified EHD Staff of the November 29, 2005 work plan, resulted in all efforts being put on hold due to the psychological and business reaction to the "The Work Plan is not approved" letter. H 2 OGEOL A GROUNDWATER CONSULTANCY