Contract analysis

1. Identification of Applicant The applicant in this VCP matter is Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company, Registration No. MC-318574, with its principal headquarters at 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman, KY1-1002, Cayman Islands. DEH is the successor-in-interest to Dunmore Terminal Services, Inc. ("DTS"), a Texas corporation formerly in good

2. Site Description The Site that is the subject of this VCP application is described as follows: Common Name: Dunmore Wharton Terminal Physical Address: 14200 FM 1301, Wharton, Wharton County, Texas 77488 Tax Parcel Identification Number: WC-0241-0034 Legal Description: 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 that ce

3. Operational History The following is a summary of the operational history of the Dunmore Wharton Terminal, as documented in the enclosed Phase I Environmental Site Assessment and as supplemented by corporate records of the applicant: Dunmore Terminal Services, Inc. commenced petroleum bulk-storage terminal operations at the Site in 1974. The facility was designed and constructed as a petroleum products receiving,

4. Summary of Known Contamination and Release History 4.1 Documented Releases Based on TCEQ records, the Phase I and Phase II Environmental Site Assessments prepared by Pinehill Environmental Consulting LLC, and the corporate records of DTS and DEH, the following releases of petroleum products have been documented at the Site: (a) 1996 Release. Approximately 8,000 gallons of diesel fuel were released from Tank S-4, l

5. Environmental Assessments Performed In January 2024, DEH retained Pinehill Environmental Consulting LLC ("Pinehill"), a Texas limited liability company with offices at 9330 Kirby Drive, Suite 240, Houston, Texas 77054, to conduct comprehensive environmental investigations at the Site. Pinehill's Principal-in-Charge for this engagement is Dr. Lena Vasquez, P.E., P.G., a licensed Professional Engineer and Profession

6. Proposed Remedial Approach (Summary) DEH intends to pursue a comprehensive remediation strategy for the Site that addresses both soil and groundwater contamination and provides for long-term monitoring and institutional controls to ensure the protection of human health and the environment. The proposed remedial approach, as developed by Pinehill Environmental Consulting LLC in coordination with DEH and Calderwood

7. Financial Capability of Applicant DEH has the financial resources and capability to perform the proposed remediation in its entirety. The following information is provided in support of this representation: (a) DEH reported consolidated revenue of approximately $347 million for the fiscal year ended December 31, 2024, and maintains a consolidated net asset value of approximately $1.24 billion. DEH's financial posi

8. Site Access Arrangements As noted in Section 2 above, DEH is not the current fee owner of the Site. The current owner, Calera Properties Group LLC, acquired the property at a tax foreclosure sale in March 2019 and has had no involvement in the petroleum operations or releases that are the subject of this application. DEH and CPG are currently negotiating a Site Access & Cost-Sharing Agreement (the "Access Agreemen

9. Identification of Other Potentially Responsible Parties DEH notes that Rowan Creek Fuel Distributors, Inc. ("RCFD") co-operated the southern tank farm at the Site from 1991 through 2010 under the Joint Operating Agreement described in Section 3 above. During the period of RCFD's operations, at least four of the five documented releases at the Site—the 1996 release from Tank S-4, the 2001 release from Tank S-7, the

10. Enclosed Materials The following materials are enclosed with this application for TCEQ's review:

1. Completed TCEQ Voluntary Cleanup Program Application Form.

2. Application fee in the amount of $1,000.00 (check enclosed, payable to the Texas Commission on Environmental Quality).

3. Site location map, including USGS 7.5-minute topographic quadrangle map and recent aerial photograph with Site boundaries indicated.

4. Legal description of the Site (Lots 3 and 4 of the H.T. & B.R.R. Survey, Abstract No. 241, Wharton County, Texas; deed recorded at Volume 1892, Page 417, Official Public Records of Wharton County, Texas).

5. Summary of known contamination and release history (as detailed in Section 4 of this letter).

6. Phase I Environmental Site Assessment — Executive Summary (prepared by Pinehill Environmental Consulting LLC, commenced January 2024).

7. Phase II Environmental Site Assessment — Executive Summary (prepared by Pinehill Environmental Consulting LLC, completed June 2024).

8. Evidence of applicant's financial capability to perform remediation, including: (a) Corporate financial summary for Dunmore Energy Holdings Ltd.; and (b) Certificate of insurance for Bridgemont Insurance Company Pollution Legal Liability Policy No. ENV-BIC-2024-07821.

9. Proof of site-access arrangements with Calera Properties Group LLC (current fee owner), including draft Site Access & Cost-Sharing Agreement and letter of intent from CPG.

10. Copy of Plan of Dissolution and Assignment of Liabilities dated October 15, 2017 (documenting DEH's assumption of all environmental liabilities of Dunmore Terminal Services, Inc.).

11. Certificate of dissolution for Dunmore Terminal Services, Inc. issued by the Texas Secretary of State (effective December 31, 2017).

11. APAR Submission Timeline DEH hereby commits to submitting the Affected Property Assessment Report ("APAR") to TCEQ on or before October 31, 2025. The APAR will be prepared by Pinehill Environmental Consulting LLC under the direction of Dr. Lena Vasquez, P.E., P.G., and will present a comprehensive assessment of the nature and extent of contamination at the Site, an evaluation of risk to human health and ecologica