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Mr.Mike Oliphant—CEMC Revised Soil and Groundwater Investigation Work Plan November 28,2011 Ahern Road-Vernalis Page 2 of 3 Access to the residential properties northeast of the Highway 33 ROW has either been denied or no practical drilling location on the property could be located. Therefore, SAIC recommends advancing two borings within the Highway 33 ROW to evaluate soil and groundwater conditions in the area of these properties. SAIC re-evaluated the need for several borings proposed within the UPRR ROW between the former Old Valley Pipeline and Tidewater Associated Oil Company pipelines. As affected soil and groundwater have been documented in previous borings within the UPRR ROW, SAIC considers that these additional borings would yield somewhat redundant data, and therefore proposes advancing one boring northwest of previous boring SB-43 (Figure 1) to further evaluate the extent of affected soil and groundwater within the UPRR ROW. Additional borings are not proposed along the UPRR ROW beyond the northwest property boundary of APN 255-180-05, as discussed below. The Site is located within un-incorporated San Joaquin County in the Tracy Planning Area as outlined in Volume 2 of the San Joaquin County General Plan.4 According to the Plan, expansion of the Vernalis community is "not planned or encouraged." Further, several of the parcels surrounding the Site are under Williamson Land Act contracts that are scheduled for renewal every 10 years. While some of the properties are designated as "Residential/Rural," the general plan statement and the presence of Williamson Land Act parcels in the area indicates that the designated land use of the properties on which SAIC initially proposed the investigation is unlikely to change in the short or medium term. The Site and adjacent parcels are shown on Figure 2. CEMC considers that as there is no evidence of development plans in the area of the Site investigation, a strong project driver does not exist to warrant moving forward with the investigation beyond the proposed borings in this work plan. CEMC will monitor the area for potential development, and in the event development plans are identified, CEMC will evaluate re-initiating site access discussions. PROPOSED SCOPE OF WORK SAIC proposes to advance three soil borings at the locations shown on Figure 1 to collect soil and groundwater samples. Field investigation procedures and methodologies were outlined in the work plan, and remain unchanged. For details on the investigative activities and investigation methodology, please refer to the work plan. Analysis of the constituents of potential concern will also remain the same. SCHEDULE Field work will commence on execution of the CFNR ROE agreement and necessary permitting. 4. San Joaquin County,2010. San Joaquin County General Plan. January.