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CENTRAL VALLEY EGIONAL WATER QUAL Y CONTROL BOARD RECORD OF COMMUNICATION Phone Call Other (specify) X Meeting PARTIES DATE: 26 March 2009 TIME: 0900-1007 Jim Barton, RB5S UST Enforcement Unit 2* ' Ms. Kerry Heckman, Connell Tire Antony Romero, Connell Tire Nick Bokidies, family friend and USA station owner. Robert Marty, AGE (consultant) William Little, AGE * Party Initiating Communication SUBJECT: Request to stop all work on River City Petroleum (RCP)/Connell due to financial crisis caused by SWRCB UST CUF delays of payment. FILE: RCP/Connell, 2211 N. Wilson Way, Stockton, San Joaquin County SUMMARY OF COMMUNICATION: See attached 1-9-09 draft letter for reason for meeting. Meeting commenced with introductions at 0900 hours. Approximately $1.3M CUF spent to date. I stated my agenda was to work with Ms. Heckman to focus on work necessary and required to keep the case moving towards closure. I shared a draft letter, which included a revised MRP table to reduce monitoring frequency and list of analyses, and to focus on known constituents detected in each well. I stressed that cost savings need to be addressed in all phases of the work, and gave my example for reductions in lab analyses (—$6000 annually, which is 66% less cost than current work required in the existing MRP). I stated that my table of reductions was subject to their review, and that I would consider further reductions based on a technical rationale from AGE. We also discussed savings in the current SVE treatment system (possible swapping of thermal oxidizer for carbon treatment units), the cost to abandon wells ($50,000) prior to closure, a working budget minus the well abandonment ($150,000 remaining in CUF account), using more cost effective methods for sampling wells, and delaying the pilot study. I suggested AGE look for additional cost savings. Mr. Romero asked if concentrations would rebound with the treatment system off, and I answered that we needed the monitoring data to determine if they would rebound, that we did not have an estimate of the contamination released or remaining to make a reasonable answer to his question. I requested the status of the remediation and was informed by AGE that the SVE/AS system has been off-line since November 2008; hence, RCP is now conducting a rebound test, which necessitates continuing the groundwater monitoring. I Asked when I could get a reasonable schedule for continuing the work, and Bob Marty said one week. We also discussed two worst case what-if scenarios if the Fund money is used up: A) RP pays. B) RP refuses to pay, then case may be placed in EAR account, with AGE let go in favor of the State contractor, RB takes over project from RP, and repayment of costs to State would be required (e.g. property liens). I said that enforcement action (CAO, Fines) would precede alternative B. Mr. Bokides requested an opinion whether a second release could be claimed, citing the 1,2-DCA may have come from an earlier generation of tanks that were removed without opening a case. I said that my opinion would be irrelevant since the SWRCB UST program would decide if the claim was valid, and added that I had not heard of a case where a 2nd release preceded the 1st release. Mr. Bokides said an interpretation of the regulations might allow a second release to be declared before the investigation/remediation of the 1st release is completed. CONCLUSIONS, ACTION TAKEN OR REQUIRED: Within one week of the meeting, AGE and Ms. Kerry are to agree on, and submit, a schedule for resumption of monitoring and a reasonable extension for remediation upgrades (SVE/AS wells in place, awaiting plumbing. The Pilot Test is on hold and may be cancelled if declining concentrations persist during rebound testing. REVIEWED BY: WRITTE BY: JLB 6