Contract analysis

I. Introduction and Purpose of Letter This firm represents Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company (Registration No. MC-318574), and successor-in-interest to Dunmore Terminal Services, Inc. ("DTS"), a dissolved Texas corporation (EIN 76-0384291). We write on behalf of DEH to make a formal demand for contribution and cost recovery from Rowan Creek Fuel Distributors, Inc. ("RCFD") (EIN 7

II. The Site — Description and History A. Site Description The Dunmore Wharton Terminal (the "Site") is a petroleum bulk-storage terminal facility commonly known by that name, located at 14200 FM 1301, Wharton, Wharton County, Texas 77488. The legal description of the Site is a 48.7-acre tract being Lots 3 and 4 of the H.T. & B.R.R. Survey, Abstract No. 241, Wharton County, Texas, as more particularly described in a

III. RCFD's Status as a Responsible Party RCFD is a responsible party liable for the response costs demanded herein under both federal and state law. Under CERCLA § 107(a)(2), 42 U.S.C. § 9607(a)(2), any person who at the time of disposal of any hazardous substance owned or operated any facility at which such hazardous substances were disposed of is liable for all costs of removal or remedial action incurred by any o

IV. Documented Releases from RCFD-Operated Facilities The environmental investigation conducted at the Site has identified multiple documented releases of petroleum products from tanks and infrastructure within the southern tank farm during the period of RCFD's operational control. These releases are the primary sources of the subsurface contamination requiring remediation. A. 1996 Release — Tank S-4 In 1996, approxi

V. Nature and Extent of Contamination A. Environmental Investigations Following the assumption of DTS's environmental obligations, DEH retained Pinehill Environmental Consulting LLC ("Pinehill"), a qualified Texas environmental consulting firm, to conduct comprehensive environmental investigations at the Site. Pinehill's work has been led by Dr. Lena Vasquez, P.E., P.G., who serves as the firm's Principal-in-Charge a

VI. Remediation Costs and Allocation A. Remediation Cost Estimate Pinehill prepared a detailed remediation cost estimate in April 2025, projecting total remediation costs of $9,740,000, with a confidence range of $7.81 million to $12.18 million depending on site conditions encountered during implementation. The cost estimate encompasses the following major components: The remediation plan includes soil excavation and

VII. Legal Bases for Recovery A. Federal Law — CERCLA § 107(a), 42 U.S.C. § 9607(a) RCFD is liable under CERCLA § 107(a)(2) as a former operator of a facility — the southern tank farm at the Site — at the time hazardous substances were disposed of or released. CERCLA imposes strict, joint and several liability on responsible parties for all costs of removal or remedial action, without regard to fault. Burlington N. &

VIII. Demand for Payment and Response Deadline DEH hereby demands that RCFD pay the sum of $4,647,000 within sixty (60) days of the date of this letter — that is, on or before July 11, 2025. Payment should be made by wire transfer to a trust account to be designated by Calderwood & Harkness LLP upon RCFD's confirmation of its intent to pay. Wire transfer instructions will be provided promptly upon receipt of written

IX. Reservation of Rights DEH expressly reserves all rights and remedies available to it under federal and state law, in equity, and at common law, including but not limited to: (a) The right to commence litigation against RCFD in the United States District Court for the Southern District of Texas, Houston Division, or in any other court of competent jurisdiction, including the District Court of Wharton County, Texas

X. Request for Document Preservation DEH requests that RCFD immediately institute a litigation hold and take all steps necessary to identify, preserve, and protect from destruction, alteration, or loss all documents, electronically stored information ("ESI"), and tangible items relating to the following categories: (a) RCFD's operations at the Dunmore Wharton Terminal site from 1991 to 2010, including all operational

XI. Conclusion DEH urges RCFD to address this matter promptly and cooperatively. Protracted litigation would impose significant costs on both parties, divert resources from the important task of environmental remediation, and delay the restoration of the Site to a condition protective of human health and the environment. DEH believes that a negotiated resolution is in the mutual interest of both parties and is prepar

1. Executive Summary — Phase II Environmental Site Assessment, Pinehill Environmental Consulting LLC (June 2024)

2. Remediation Cost Estimate Summary, Pinehill Environmental Consulting LLC (April 2025)

3. Site Location Map and Plume Delineation Figure Remediation Component | Estimated Cost Soil excavation and off-site disposal — Southern tank farm (RCFD-operated) | $3,420,000 Soil excavation and off-site disposal — Northern tank farm (DTS-operated) | $1,870,000 In-situ groundwater treatment (chemical oxidation and enhanced bioremediation) | $2,150,000 Long-term groundwater monitoring (8 years, 32 quarterly events a