1016-00006 · Dunmore Energy Holdings · Insurance

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CALDERWOOD & HARKNESS LLP Attorneys at Law 1200 McKinney Street, Suite 4100 Houston, Texas 77010

Telephone: (713) 555-4200 Facsimile: (713) 555-4201 www.calderwoodharkness.com

Sandra Tung Partner — Environmental & Energy Practice Direct: (713) 555-4238 stung@calderwoodharkness.com

June 30, 2025

Matter No.: 1016-00006

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED, AND ELECTRONIC MAIL

Mr. Paul Neumann Senior Vice President — Environmental Lines Bridgemont Insurance Company 200 Galleria Parkway, Suite 1800 Atlanta, Georgia 30339

Re: Formal Notice of Pollution Condition — Pollution Legal Liability Policy No. ENV-BIC-2024-07821 Insured: Dunmore Energy Holdings Ltd. Scheduled Location: Dunmore Wharton Terminal, 14200 FM 1301, Wharton, Wharton County, Texas 77488

Dear Mr. Neumann:

I. Introduction and Purpose of Notice

This firm represents Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company (Registration No. MC-318574), with its principal office and headquarters located at 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman, KY1-1002, Cayman Islands. I am the Responsible Partner for this engagement and am writing on behalf of DEH in connection with the matters described herein.

The purpose of this letter is to provide formal written notice, pursuant to the terms and conditions of Pollution Legal Liability Policy No. ENV-BIC-2024-07821 (the "Policy"), issued by Bridgemont Insurance Company ("Bridgemont") to DEH, of pollution conditions discovered at the Dunmore Wharton Terminal site located at 14200 FM 1301, Wharton, Wharton County, Texas 77488 (the "Site"). The Policy has an effective date of March 1, 2024, and an expiration date of March 1, 2034, establishing a ten-year policy term. The Policy provides an aggregate limit of liability of Fifteen Million Dollars ($15,000,000), subject to a self-insured retention ("SIR") of Five Hundred Thousand Dollars ($500,000).

As set forth in detail below, environmental investigations conducted at the Site by DEH's retained environmental consulting firm have confirmed the existence of significant petroleum contamination in both soils and groundwater, including a dissolved-phase benzene plume that has migrated a substantial distance from the source areas. The Site is specifically identified as a scheduled known-condition location under the Policy, and the pollution conditions described herein fall squarely within the scope of the coverage afforded by the Policy.

DEH is providing this notice in order to comply with the notification requirements of the Policy and to preserve DEH's rights to coverage for cleanup costs, third-party claims, and related expenses arising from the pollution conditions at the Site. DEH expressly reserves all of its rights and remedies under the Policy, at law, and in equity with respect to the matters addressed herein and any related matters that may arise in the future.

II. Identification of the Insured and the Scheduled Location

The Insured. The named insured under the Policy is Dunmore Energy Holdings Ltd. DEH is the successor-in-interest to Dunmore Terminal Services, Inc. ("DTS"), a Texas corporation (Employer Identification Number: 76-0384291) that was dissolved effective December 31, 2017. All liabilities of DTS, including without limitation all environmental obligations and liabilities arising from DTS's ownership and operation of the Site, were assumed by DEH pursuant to a Plan of Dissolution and Assignment of Liabilities dated October 15, 2017 (the "Assignment"). A copy of the Assignment was provided to Bridgemont during the underwriting process and is referenced in the Policy's scheduled locations endorsement. DTS formerly maintained its registered office at 800 Travis Street, Suite 1440, Houston, Texas 77002, and was registered with the Texas Secretary of State until its dissolution.

The Scheduled Location. The Site is identified on the Policy's schedule of covered locations as follows:

Location Name: Dunmore Wharton Terminal Address: 14200 FM 1301, Wharton, Wharton County, Texas 77488 Legal Description: A 48.7-acre tract of land 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 certain Deed recorded at Volume 1892, Page 417, Official Public Records, Wharton County, Texas. Tax Parcel Identification Number: WC-0241-0034 Current Zoning Designation: Heavy Industrial (HI), unincorporated Wharton County, Texas

It is noted for the record that the Site is no longer owned by DEH or any of its affiliates. The current owner of the Site is Calera Properties Group LLC, a Texas limited liability company (Employer Identification Number: 84-3207156), which acquired the Site at a tax foreclosure sale conducted in March 2019 for a purchase price of $612,000. Calera Properties Group LLC is not a responsible party for the contamination at the Site and acquired the property without knowledge of the full extent of the environmental conditions described herein. DEH's environmental obligations with respect to the Site arise from DTS's historical ownership and operations, as assumed by DEH through the Assignment. The current property owner has been notified of the ongoing environmental investigation and has cooperated with DEH in granting site access for investigative activities.

III. Site Background and Operational History

DTS operated a petroleum bulk-storage terminal at the Site from 1974 through 2015, a period of approximately forty-one years. During that time, the Site served as a regional hub for the receipt, storage, and distribution of refined petroleum products, including gasoline, diesel fuel, and fuel oil.

The principal improvements at the Site consist of the following:

• Northern Tank Farm: Twelve (12) aboveground storage tanks ("ASTs"), designated Tanks N-1 through N-12, with a combined storage capacity of approximately 420,000 barrels. These tanks were owned and operated exclusively by DTS throughout the operational life of the terminal.

• Southern Tank Farm: Twelve (12) ASTs, designated Tanks S-1 through S-12, with a combined storage capacity of approximately 315,000 barrels. These tanks occupy approximately 18 acres in the southern portion of the Site.

• Truck Loading Rack: A decommissioned truck loading rack, consisting of four loading positions, located between the northern and southern tank farms. This facility was used for the transfer of petroleum products to tanker trucks for regional distribution.

• Pipeline Interconnects: Pipeline interconnects to the Colonial Pipeline right-of-way, which were used for the receipt and delivery of petroleum products via common-carrier pipeline. These interconnects were disconnected in 2016 following the cessation of terminal operations.

• Administrative Building: An abandoned administrative building, approximately 4,800 square feet, located near the main entrance to the Site off FM 1301.

From 1991 through 2010, Rowan Creek Fuel Distributors, Inc. ("RCFD"), a Texas corporation (Employer Identification Number: 74-2951683), co-operated the southern tank farm — specifically, Tanks S-1 through S-12 — under the terms of a Joint Operating Agreement ("JOA") with DTS. Under the JOA, RCFD was responsible for the day-to-day operation and maintenance of the southern tank farm, including product storage, transfer operations, and environmental compliance for that portion of the facility. RCFD's operational tenure at the Site is significant because a substantial portion of the documented releases at the Site occurred in the southern tank farm during the period of RCFD's co-operation.

DTS ceased all terminal operations at the Site in 2015. The pipeline interconnects to the Colonial Pipeline system were formally disconnected in 2016. As noted above, DTS was dissolved effective December 31, 2017, and all of its environmental liabilities were assigned to and assumed by DEH pursuant to the Assignment.

IV. Description of Pollution Conditions — Known Release History

The environmental record for the Site reflects at least five documented releases of petroleum products that occurred during the operational life of the terminal, as follows:

1. 1996 Release — Tank S-4 (Southern Tank Farm, RCFD-Operated). Approximately 8,000 gallons of diesel fuel were released from Tank S-4 in the southern tank farm. The release was reported to the Texas Commission on Environmental Quality (then the Texas Natural Resource Conservation Commission). A partial cleanup was performed at the time of the release; however, residual contamination in soils and groundwater was not fully addressed.

2. 2001 Release — Tank S-7 (Southern Tank Farm, RCFD-Operated). Approximately 3,200 gallons of gasoline were released from Tank S-7. This incident was reported to TCEQ and assigned Incident No. 142876. The release involved a failure of the tank bottom, resulting in product discharge to the underlying soils and subsequent migration to groundwater.

3. 2003 Release — Tank N-3 (Northern Tank Farm, DTS-Operated). Approximately 1,500 gallons of gasoline were released from Tank N-3 in the northern tank farm. This incident was reported to TCEQ and assigned Incident No. 158432. Initial response actions were conducted at the time, including limited excavation of visibly impacted soils in the immediate vicinity of the tank.

4. 2008 Release — Tank S-11 (Southern Tank Farm, RCFD-Operated). Approximately 5,600 gallons of diesel fuel were released from Tank S-11. This incident was reported to TCEQ and assigned Incident No. 197503. The release resulted from corrosion of the tank shell and was not detected for a period of several weeks, allowing a significant volume of product to migrate to subsurface soils and the shallow groundwater zone.

5. 2014 Release — Loading Rack Area (DTS-Operated). Approximately 600 gallons of diesel fuel were released from the loading rack area. This incident was reported to TCEQ and assigned Incident No. 251044. The release occurred during a product transfer operation and was contained relatively quickly; however, some product reached subsurface soils beneath the loading rack pad.

These five documented releases collectively account for the introduction of approximately 18,900 gallons of petroleum products to the subsurface at the Site. It is also possible that additional, undocumented releases occurred during the terminal's forty-one-year operating history, particularly during the earlier decades of operation when environmental monitoring and spill-detection systems were less rigorous than current standards require.

V. Description of Pollution Conditions — Current Contamination Profile

To fully characterize the nature and extent of contamination at the Site, DEH retained Pinehill Environmental Consulting LLC ("Pinehill") to conduct a comprehensive environmental investigation. The Pinehill engagement has been supervised by Dr. Lena Vasquez, P.E., P.G., who serves as Principal-in-Charge for the project. Pinehill commenced a Phase I Environmental Site Assessment in January 2024, which identified recognized environmental conditions associated with the historical releases described in Section IV above. Subsequently, Pinehill conducted a Phase II Environmental Site Assessment, which was completed in June 2024 and included the installation and sampling of soil borings, monitoring wells, and groundwater sampling points across the Site and in the downgradient plume area.

The Phase II investigation, together with supplemental investigation activities conducted through February 2025, has delineated the following contamination at the Site:

Contaminants of Concern (COCs). The primary contaminants of concern identified at the Site include: benzene, toluene, ethylbenzene, and xylenes (collectively, "BTEX"); total petroleum hydrocarbons ("TPH"); methyl tert-butyl ether ("MTBE"); and dissolved-phase lead. These COCs are consistent with the types of petroleum products historically stored and handled at the terminal, including gasoline and diesel fuel.

Soil Contamination. Elevated concentrations of petroleum hydrocarbons have been detected in subsurface soils at multiple locations across the Site, with the most significant impacts occurring in the following areas:

• Southern Tank Farm (Tank S-7 Area): TPH concentrations in soils in the vicinity of Tank S-7 have been measured at concentrations up to 14,200 milligrams per kilogram (mg/kg). This area represents the most heavily impacted soil zone at the Site and corresponds to the documented 2001 gasoline release from Tank S-7 (TCEQ Incident No. 142876).

• Northern Tank Farm (Tank N-3 Area): TPH concentrations in soils in the vicinity of Tank N-3 have been measured at concentrations up to 8,750 mg/kg. This area corresponds to the documented 2003 gasoline release from Tank N-3 (TCEQ Incident No. 158432).

• Benzene in Soil: The maximum concentration of benzene detected in soil samples across the Site is 42 mg/kg. This concentration substantially exceeds the TCEQ Tier 1 Protective Concentration Level ("PCL") for residential land use of 1.8 mg/kg, as well as the Tier 1 PCL for commercial/industrial land use of 5.3 mg/kg. The presence of benzene at these concentrations in soils confirms the existence of a significant source area requiring remediation.

Groundwater Contamination. Petroleum hydrocarbon contamination has migrated from the source areas in the soil to the shallow zone of the Chicot Aquifer, which is the principal aquifer in this region and is encountered at approximately 22 feet below ground surface ("bgs") at the Site. The groundwater investigation has revealed the following conditions:

• Dissolved Benzene Plume: A dissolved-phase benzene plume has been delineated extending approximately 2,400 feet downgradient (in a south-southwesterly direction) from the southern tank farm. The plume originates in the area of the Tank S-7 and Tank S-11 source zones and has migrated along the prevailing groundwater flow gradient.

• Maximum Dissolved Benzene Concentration: The maximum dissolved benzene concentration detected in groundwater monitoring wells is 3.8 milligrams per liter (mg/L). This concentration is approximately 760 times the federal Maximum Contaminant Level ("MCL") for benzene in drinking water, which is 0.005 mg/L (5 micrograms per liter). Concentrations at this level represent a significant threat to groundwater quality and to any downgradient receptors that may utilize the Chicot Aquifer as a source of drinking water.

• MTBE in Groundwater: MTBE has been detected in groundwater at concentrations up to 1.2 mg/L. MTBE is highly soluble and resistant to natural attenuation, and its presence at these concentrations is indicative of a gasoline source and contributes to the complexity and cost of the required groundwater remediation.

• Dissolved Lead in Groundwater: Dissolved lead has been detected in groundwater at concentrations up to 0.087 mg/L, which exceeds the federal MCL for lead of 0.015 mg/L by a factor of approximately 5.8. The presence of lead in groundwater is attributable to the historical use of leaded gasoline products at the terminal during the earlier decades of operation.

The contamination profile at the Site is consistent with a mature petroleum release from multiple source areas, with significant impacts to both the vadose zone and the saturated zone. The elevated concentrations of BTEX, TPH, MTBE, and lead in both soils and groundwater confirm the need for active remediation of the source areas and treatment of the dissolved-phase plume.

VI. Potential Third-Party Exposure — Nearest Receptor

DEH has identified the nearest residential receptor to the Site as the property located at 16405 FM 1301, Wharton, Texas 77488, which is owned and occupied by the Ingram family (the "Ingram Property"). The Ingram Property is situated approximately 3,100 feet south-southwest of the current leading edge of the dissolved benzene plume, as delineated by Pinehill's most recent monitoring well data. The Ingram Property is served by a private domestic water well that draws from the Chicot Aquifer.

In February 2025, at DEH's direction, Pinehill collected a groundwater sample from the residential water-supply well at the Ingram Property. Laboratory analysis of that sample did not detect any of the identified COCs at concentrations above their respective MCLs as of the date of sampling. This result indicates that, at the time of sampling, the leading edge of the dissolved benzene plume had not reached the Ingram Property's water supply.

However, DEH and its consultant remain concerned about the potential for future migration of the plume toward the Ingram Property and other downgradient receptors. Given the direction and estimated rate of plume migration, and the relatively limited distance between the current plume front and the Ingram Property, continued groundwater monitoring is warranted to ensure that COC concentrations do not reach the Ingram Property's water-supply well at levels that would pose a risk to human health. Should contamination reach the Ingram Property or other downgradient residential properties, third-party bodily injury and property damage claims would become a realistic possibility.

Accordingly, DEH's notice under the Policy is intended to encompass not only on-site and off-site cleanup costs but also potential third-party claims arising from off-site groundwater contamination migration, including but not limited to claims by downgradient property owners for property damage, diminution of property value, personal injury, or the cost of alternative water supply.

VII. Remediation Cost Estimate

Pinehill prepared and delivered to DEH a comprehensive Remediation Cost Estimate dated April 2025 (the "Cost Estimate"). The Cost Estimate was developed based on the data collected during the Phase I and Phase II Environmental Site Assessments and supplemental investigations, and reflects current market pricing for environmental remediation services in the Texas Gulf Coast region. The Cost Estimate presents a base-case estimate as well as low-range and high-range scenarios to account for the uncertainties inherent in estimating remediation costs at sites with mature petroleum plumes.

The total estimated remediation cost is $9.74 million at the base case, with a low-range estimate of $7.81 million and a high-range estimate of $12.18 million. The principal cost categories are summarized as follows:

DEH's Asserted Share of Remediation Costs. Based on the allocation of responsibility between DTS (as DEH's predecessor) and RCFD, DEH asserts that its share of the total remediation costs is $5.48 million. This allocation reflects DTS's responsibility for the northern tank farm releases, the 2014 loading rack release, and a proportional share of remediation activities in the southern tank farm based on the period and nature of DTS's and RCFD's respective operations.

Cost Recovery Against RCFD. DEH is actively pursuing cost recovery against RCFD for RCFD's allocated share of remediation costs in the amount of $4.26 million, plus $387,000 in investigative costs incurred by DEH to date, for a total claimed amount of $4.647 million. DEH has engaged this firm to evaluate and pursue cost recovery claims against RCFD under applicable state and federal environmental statutes and common law theories. However, the outcome and timing of any cost recovery from RCFD remain uncertain, and DEH cannot provide assurance that RCFD is financially capable of satisfying a judgment or settlement in that amount. Accordingly, the potential for cost recovery from RCFD does not diminish or defer DEH's claim for coverage under the Policy.

VIII. TCEQ Voluntary Cleanup Program Enrollment

DEH has elected to conduct the remediation of the Site under the oversight of the Texas Commission on Environmental Quality ("TCEQ") Voluntary Cleanup Program ("VCP"), as authorized by Chapter 361, Subchapter S of the Texas Health and Safety Code. The VCP provides a structured framework for the investigation and remediation of contaminated properties and, upon successful completion of the cleanup, the issuance of a Certificate of Completion that provides certain liability protections to the applicant and future property owners.

On June 25, 2025, DEH submitted an application to the TCEQ VCP, together with the required application fee of $1,000. The TCEQ has assigned VCP Tracking No. VCP-2517 to the Site. DEH anticipates receiving a formal acknowledgment letter from the TCEQ confirming acceptance of the application on or about August 2025.

The anticipated timeline for the VCP process is as follows:

• Affected Property Assessment Report ("APAR") Submission: DEH plans to submit the APAR to TCEQ by October 31, 2025. The APAR will present the results of the Phase I and Phase II ESAs and supplemental investigations, together with a risk assessment and proposed remediation approach.

• Voluntary Cleanup Work Plan Submission: Following TCEQ review and comment on the APAR, DEH anticipates submitting a Voluntary Cleanup Work Plan for TCEQ approval by approximately April 2026.

• Active Remediation Phase: Active remediation, including soil excavation and disposal and in-situ groundwater treatment, is estimated to commence in June 2026 and continue through approximately December 2028.

• Post-Remediation Monitoring Phase: Following the completion of active remediation, DEH anticipates a period of post-remediation groundwater monitoring to confirm the effectiveness of the remedial actions and to demonstrate attainment of cleanup standards. This monitoring phase is estimated to extend through approximately December 2032.

• Certificate of Completion: DEH's target date for obtaining a Certificate of Completion from the TCEQ is 2033, subject to the successful completion of all remedial actions and demonstration of compliance with applicable TCEQ standards.

TCEQ oversight fees for the VCP are billed at a rate of $225 per hour. Based on the anticipated scope and duration of TCEQ oversight activities, DEH estimates that total TCEQ oversight costs will be approximately $135,000 over the life of the project.

DEH's investigative costs incurred to date — from January 2024 through the present — total $387,000. These costs consist of fees invoiced by Pinehill for the Phase I Environmental Site Assessment, the Phase II Environmental Site Assessment, and supplemental investigation activities, including monitoring well installation, groundwater sampling, and laboratory analysis. These costs have been incurred in advance of enrollment in the VCP and in preparation for the remediation of the Site.

IX. Coverage Implicated Under the Policy

DEH submits that the pollution conditions described in this letter trigger coverage under the Policy. The Policy, as issued by Bridgemont to DEH, provides coverage for the following categories of loss, among others, that are directly relevant to the conditions at the Site:

• On-Site Cleanup Costs. The Policy covers cleanup costs incurred for the investigation and remediation of pollution conditions at scheduled locations, subject to the $500,000 SIR per pollution condition. The soil and groundwater contamination at the Site, as detailed in Sections IV and V above, constitutes a pollution condition at a scheduled known-condition location, and the estimated cleanup costs attributable to DEH's share substantially exceed the SIR.

• Off-Site Cleanup Costs. The Policy covers cleanup costs associated with pollution conditions that have migrated beyond the boundaries of a scheduled location. The dissolved benzene plume at the Site has migrated approximately 2,400 feet downgradient of the southern tank farm and beyond the property boundaries of the Site, necessitating off-site groundwater investigation and treatment.

• Third-Party Bodily Injury and Property Damage Claims. The Policy covers claims by third parties for bodily injury and property damage arising from pollution conditions at or emanating from a scheduled location. As described in Section VI above, the proximity of the Ingram Property and other downgradient receptors to the advancing benzene plume creates a realistic possibility of third-party claims for personal injury, property damage, diminution of property value, or costs of alternative water supply.

The Site is specifically listed as a scheduled known-condition location under the Policy, and the pollution conditions at the Site were disclosed to Bridgemont during the underwriting process as part of the environmental information provided in support of DEH's application for coverage. The Policy was issued with the understanding that the Site had a history of petroleum releases and that further investigation and remediation would be required.

DEH anticipates that remediation expenditures attributable to DEH's share — currently estimated at $5.48 million at the base case — will exceed the $500,000 SIR. Upon exhaustion of the SIR, DEH will look to Bridgemont for coverage of cleanup costs and other covered losses up to the $15,000,000 aggregate limit of the Policy. DEH will maintain detailed, auditable records of all remediation expenditures, including invoices, cost documentation, and evidence of payments, for purposes of SIR tracking and claims documentation. DEH will provide Bridgemont with periodic updates on the status of remediation activities and expenditures as the project progresses.

X. Reservation of Rights

DEH expressly reserves all of its rights, remedies, and claims under the Policy, at law, and in equity, including but not limited to:

• The right to claim reimbursement for all covered cleanup costs incurred above the SIR, up to the aggregate limit of the Policy;

• The right to claim coverage for any third-party bodily injury or property damage claims that may arise from the pollution conditions at or emanating from the Site;

• The right to assert coverage for defense costs related to any third-party claims, including costs of investigation, legal representation, and settlement or judgment;

• All rights regarding Bridgemont's subrogation interests, including with respect to any recovery that may be obtained from RCFD or other potentially responsible parties; and

• All other rights and remedies available to DEH under the Policy, whether arising under the express terms of the Policy, by operation of law, or otherwise.

Nothing in this letter, or in any prior or subsequent communication between DEH (or its counsel) and Bridgemont, shall be construed as a waiver, release, or relinquishment of any rights, defenses, or claims available to DEH under the Policy or applicable law. DEH's provision of this notice is not intended to, and does not, constitute an admission of liability to any third party, a concession as to the scope or extent of contamination, or a limitation on the amount or types of coverage that DEH may be entitled to claim under the Policy.

XI. Requested Actions

In light of the foregoing, DEH respectfully requests that Bridgemont take the following actions promptly upon receipt of this notice:

1. Acknowledge Receipt. Acknowledge receipt of this notice in writing, confirming the date of receipt and the identity of the Bridgemont representative responsible for the matter.

2. Assign a Claim Number. Assign a claim number to this matter and identify the claims adjuster or other contact person who will be responsible for handling DEH's claim under the Policy.

3. Confirm Policy Status. Confirm in writing that the Policy is currently in full force and effect, that all premiums have been paid and accepted, and that the Site remains a scheduled known-condition location under the Policy's schedule of covered locations.

4. Advise Regarding Additional Information. Advise DEH and its counsel of any additional information, documentation, or materials that Bridgemont may require in order to process this notice and evaluate DEH's claim under the Policy, so that DEH may respond promptly and cooperatively.

All future correspondence regarding this matter should be directed to:

Sandra Tung, Partner Calderwood & Harkness LLP 1200 McKinney Street, Suite 4100 Houston, Texas 77010 Telephone: (713) 555-4238

Email: stung@calderwoodharkness.com

Reference: Matter No. 1016-00006; Bridgemont Policy No. ENV-BIC-2024-07821

DEH and its counsel are prepared to cooperate fully with Bridgemont in connection with the investigation, evaluation, and adjustment of this claim, and look forward to a prompt and constructive response.

XII. Enclosures

The following documents are enclosed with this letter for Bridgemont's review and records:

1. Copy of Bridgemont Pollution Legal Liability Policy No. ENV-BIC-2024-07821 (declarations page and scheduled locations endorsement);

2. Executive Summary of Pinehill Environmental Consulting LLC Phase I Environmental Site Assessment (January 2024);

3. Executive Summary of Pinehill Environmental Consulting LLC Phase II Environmental Site Assessment (June 2024);

4. Pinehill Environmental Consulting LLC Remediation Cost Estimate (April 2025);

5. TCEQ Voluntary Cleanup Program Application (filed June 25, 2025), including proof of application fee payment;

6. Site location map and plat depicting the 48.7-acre Site, surrounding land uses, and the location of the nearest identified residential receptor (the Ingram Property); and

7. Summary table of known release history, including dates, volumes, source locations, and corresponding TCEQ Incident Numbers.

We appreciate your prompt attention to this matter. Please do not hesitate to contact me directly if you have any questions or require additional information in connection with this notice.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Sandra Tung Partner 1200 McKinney Street, Suite 4100 Houston, Texas 77010 Telephone: (713) 555-4238

Email: stung@calderwoodharkness.com

cc:

Gavin Rourke, Chairman & CEO, Dunmore Energy Holdings Ltd. Cynthia Ho, Calderwood & Harkness LLP Oliver Mackenzie, Calderwood & Harkness LLP

Remediation Activity	Estimated Cost
Soil excavation and off-site disposal — Southern tank farm	$3,420,000
Soil excavation and off-site disposal — Northern tank farm	$1,870,000
In-situ groundwater treatment (chemical oxidation and enhanced bioremediation)	$2,150,000
Long-term groundwater monitoring (est. 8 years; 32 quarterly events at $33,125/event)	$1,060,000
Institutional controls and deed restrictions	$180,000
Project management, reporting, and regulatory liaison	$1,060,000
Total Estimated Remediation Cost	$9,740,000

CALDERWOOD & HARKNESS LLP Attorneys at Law 1200 McKinney Street, Suite 4100 Houston, Texas 77010
Telephone: (713) 555-4200 Facsimile: (713) 555-4201 www.calderwoodharkness.com
Sandra Tung Partner — Environmental & Energy Practice Direct: (713) 555-4238 stung@calderwoodharkness.com
June 30, 2025
Matter No.: 1016-00006
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED, AND ELECTRONIC MAIL
Mr. Paul Neumann Senior Vice President — Environmental Lines Bridgemont Insurance Company 200 Galleria Parkway, Suite 1800 Atlanta, Georgia 30339
Re: Formal Notice of Pollution Condition — Pollution Legal Liability Policy No. ENV-BIC-2024-07821 Insured: Dunmore Energy Holdings Ltd. Scheduled Location: Dunmore Wharton Terminal, 14200 FM 1301, Wharton, Wharton County, Texas 77488
Dear Mr. Neumann:
I. Introduction and Purpose of Notice
This firm represents Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company (Registration No. MC-318574), with its principal office and headquarters located at 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman, KY1-1002, Cayman Islands. I am the Responsible Partner for this engagement and am writing on behalf of DEH in connection with the matters described herein.
The purpose of this letter is to provide formal written notice, pursuant to the terms and conditions of Pollution Legal Liability Policy No. ENV-BIC-2024-07821 (the "Policy"), issued by Bridgemont Insurance Company ("Bridgemont") to DEH, of pollution conditions discovered at the Dunmore Wharton Terminal site located at 14200 FM 1301, Wharton, Wharton County, Texas 77488 (the "Site"). The Policy has an effective date of March 1, 2024, and an expiration date of March 1, 2034, establishing a ten-year policy term. The Policy provides an aggregate limit of liability of Fifteen Million Dollars ($15,000,000), subject to a self-insured retention ("SIR") of Five Hundred Thousand Dollars ($500,000).
As set forth in detail below, environmental investigations conducted at the Site by DEH's retained environmental consulting firm have confirmed the existence of significant petroleum contamination in both soils and groundwater, including a dissolved-phase benzene plume that has migrated a substantial distance from the source areas. The Site is specifically identified as a scheduled known-condition location under the Policy, and the pollution conditions described herein fall squarely within the scope of the coverage afforded by the Policy.
DEH is providing this notice in order to comply with the notification requirements of the Policy and to preserve DEH's rights to coverage for cleanup costs, third-party claims, and related expenses arising from the pollution conditions at the Site. DEH expressly reserves all of its rights and remedies under the Policy, at law, and in equity with respect to the matters addressed herein and any related matters that may arise in the future.
II. Identification of the Insured and the Scheduled Location
The Insured. The named insured under the Policy is Dunmore Energy Holdings Ltd. DEH is the successor-in-interest to Dunmore Terminal Services, Inc. ("DTS"), a Texas corporation (Employer Identification Number: 76-0384291) that was dissolved effective December 31, 2017. All liabilities of DTS, including without limitation all environmental obligations and liabilities arising from DTS's ownership and operation of the Site, were assumed by DEH pursuant to a Plan of Dissolution and Assignment of Liabilities dated October 15, 2017 (the "Assignment"). A copy of the Assignment was provided to Bridgemont during the underwriting process and is referenced in the Policy's scheduled locations endorsement. DTS formerly maintained its registered office at 800 Travis Street, Suite 1440, Houston, Texas 77002, and was registered with the Texas Secretary of State until its dissolution.
The Scheduled Location. The Site is identified on the Policy's schedule of covered locations as follows:
Location Name: Dunmore Wharton Terminal Address: 14200 FM 1301, Wharton, Wharton County, Texas 77488 Legal Description: A 48.7-acre tract of land 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 certain Deed recorded at Volume 1892, Page 417, Official Public Records, Wharton County, Texas. Tax Parcel Identification Number: WC-0241-0034 Current Zoning Designation: Heavy Industrial (HI), unincorporated Wharton County, Texas
It is noted for the record that the Site is no longer owned by DEH or any of its affiliates. The current owner of the Site is Calera Properties Group LLC, a Texas limited liability company (Employer Identification Number: 84-3207156), which acquired the Site at a tax foreclosure sale conducted in March 2019 for a purchase price of $612,000. Calera Properties Group LLC is not a responsible party for the contamination at the Site and acquired the property without knowledge of the full extent of the environmental conditions described herein. DEH's environmental obligations with respect to the Site arise from DTS's historical ownership and operations, as assumed by DEH through the Assignment. The current property owner has been notified of the ongoing environmental investigation and has cooperated with DEH in granting site access for investigative activities.
III. Site Background and Operational History
DTS operated a petroleum bulk-storage terminal at the Site from 1974 through 2015, a period of approximately forty-one years. During that time, the Site served as a regional hub for the receipt, storage, and distribution of refined petroleum products, including gasoline, diesel fuel, and fuel oil.
The principal improvements at the Site consist of the following:
• Northern Tank Farm: Twelve (12) aboveground storage tanks ("ASTs"), designated Tanks N-1 through N-12, with a combined storage capacity of approximately 420,000 barrels. These tanks were owned and operated exclusively by DTS throughout the operational life of the terminal.
• Southern Tank Farm: Twelve (12) ASTs, designated Tanks S-1 through S-12, with a combined storage capacity of approximately 315,000 barrels. These tanks occupy approximately 18 acres in the southern portion of the Site.
• Truck Loading Rack: A decommissioned truck loading rack, consisting of four loading positions, located between the northern and southern tank farms. This facility was used for the transfer of petroleum products to tanker trucks for regional distribution.
• Pipeline Interconnects: Pipeline interconnects to the Colonial Pipeline right-of-way, which were used for the receipt and delivery of petroleum products via common-carrier pipeline. These interconnects were disconnected in 2016 following the cessation of terminal operations.
• Administrative Building: An abandoned administrative building, approximately 4,800 square feet, located near the main entrance to the Site off FM 1301.
From 1991 through 2010, Rowan Creek Fuel Distributors, Inc. ("RCFD"), a Texas corporation (Employer Identification Number: 74-2951683), co-operated the southern tank farm — specifically, Tanks S-1 through S-12 — under the terms of a Joint Operating Agreement ("JOA") with DTS. Under the JOA, RCFD was responsible for the day-to-day operation and maintenance of the southern tank farm, including product storage, transfer operations, and environmental compliance for that portion of the facility. RCFD's operational tenure at the Site is significant because a substantial portion of the documented releases at the Site occurred in the southern tank farm during the period of RCFD's co-operation.
DTS ceased all terminal operations at the Site in 2015. The pipeline interconnects to the Colonial Pipeline system were formally disconnected in 2016. As noted above, DTS was dissolved effective December 31, 2017, and all of its environmental liabilities were assigned to and assumed by DEH pursuant to the Assignment.
IV. Description of Pollution Conditions — Known Release History
The environmental record for the Site reflects at least five documented releases of petroleum products that occurred during the operational life of the terminal, as follows:
1. 1996 Release — Tank S-4 (Southern Tank Farm, RCFD-Operated). Approximately 8,000 gallons of diesel fuel were released from Tank S-4 in the southern tank farm. The release was reported to the Texas Commission on Environmental Quality (then the Texas Natural Resource Conservation Commission). A partial cleanup was performed at the time of the release; however, residual contamination in soils and groundwater was not fully addressed.
2. 2001 Release — Tank S-7 (Southern Tank Farm, RCFD-Operated). Approximately 3,200 gallons of gasoline were released from Tank S-7. This incident was reported to TCEQ and assigned Incident No. 142876. The release involved a failure of the tank bottom, resulting in product discharge to the underlying soils and subsequent migration to groundwater.
3. 2003 Release — Tank N-3 (Northern Tank Farm, DTS-Operated). Approximately 1,500 gallons of gasoline were released from Tank N-3 in the northern tank farm. This incident was reported to TCEQ and assigned Incident No. 158432. Initial response actions were conducted at the time, including limited excavation of visibly impacted soils in the immediate vicinity of the tank.
4. 2008 Release — Tank S-11 (Southern Tank Farm, RCFD-Operated). Approximately 5,600 gallons of diesel fuel were released from Tank S-11. This incident was reported to TCEQ and assigned Incident No. 197503. The release resulted from corrosion of the tank shell and was not detected for a period of several weeks, allowing a significant volume of product to migrate to subsurface soils and the shallow groundwater zone.
5. 2014 Release — Loading Rack Area (DTS-Operated). Approximately 600 gallons of diesel fuel were released from the loading rack area. This incident was reported to TCEQ and assigned Incident No. 251044. The release occurred during a product transfer operation and was contained relatively quickly; however, some product reached subsurface soils beneath the loading rack pad.
These five documented releases collectively account for the introduction of approximately 18,900 gallons of petroleum products to the subsurface at the Site. It is also possible that additional, undocumented releases occurred during the terminal's forty-one-year operating history, particularly during the earlier decades of operation when environmental monitoring and spill-detection systems were less rigorous than current standards require.
V. Description of Pollution Conditions — Current Contamination Profile
To fully characterize the nature and extent of contamination at the Site, DEH retained Pinehill Environmental Consulting LLC ("Pinehill") to conduct a comprehensive environmental investigation. The Pinehill engagement has been supervised by Dr. Lena Vasquez, P.E., P.G., who serves as Principal-in-Charge for the project. Pinehill commenced a Phase I Environmental Site Assessment in January 2024, which identified recognized environmental conditions associated with the historical releases described in Section IV above. Subsequently, Pinehill conducted a Phase II Environmental Site Assessment, which was completed in June 2024 and included the installation and sampling of soil borings, monitoring wells, and groundwater sampling points across the Site and in the downgradient plume area.
The Phase II investigation, together with supplemental investigation activities conducted through February 2025, has delineated the following contamination at the Site:
Contaminants of Concern (COCs). The primary contaminants of concern identified at the Site include: benzene, toluene, ethylbenzene, and xylenes (collectively, "BTEX"); total petroleum hydrocarbons ("TPH"); methyl tert-butyl ether ("MTBE"); and dissolved-phase lead. These COCs are consistent with the types of petroleum products historically stored and handled at the terminal, including gasoline and diesel fuel.
Soil Contamination. Elevated concentrations of petroleum hydrocarbons have been detected in subsurface soils at multiple locations across the Site, with the most significant impacts occurring in the following areas:
• Southern Tank Farm (Tank S-7 Area): TPH concentrations in soils in the vicinity of Tank S-7 have been measured at concentrations up to 14,200 milligrams per kilogram (mg/kg). This area represents the most heavily impacted soil zone at the Site and corresponds to the documented 2001 gasoline release from Tank S-7 (TCEQ Incident No. 142876).
• Northern Tank Farm (Tank N-3 Area): TPH concentrations in soils in the vicinity of Tank N-3 have been measured at concentrations up to 8,750 mg/kg. This area corresponds to the documented 2003 gasoline release from Tank N-3 (TCEQ Incident No. 158432).
• Benzene in Soil: The maximum concentration of benzene detected in soil samples across the Site is 42 mg/kg. This concentration substantially exceeds the TCEQ Tier 1 Protective Concentration Level ("PCL") for residential land use of 1.8 mg/kg, as well as the Tier 1 PCL for commercial/industrial land use of 5.3 mg/kg. The presence of benzene at these concentrations in soils confirms the existence of a significant source area requiring remediation.
Groundwater Contamination. Petroleum hydrocarbon contamination has migrated from the source areas in the soil to the shallow zone of the Chicot Aquifer, which is the principal aquifer in this region and is encountered at approximately 22 feet below ground surface ("bgs") at the Site. The groundwater investigation has revealed the following conditions:
• Dissolved Benzene Plume: A dissolved-phase benzene plume has been delineated extending approximately 2,400 feet downgradient (in a south-southwesterly direction) from the southern tank farm. The plume originates in the area of the Tank S-7 and Tank S-11 source zones and has migrated along the prevailing groundwater flow gradient.
• Maximum Dissolved Benzene Concentration: The maximum dissolved benzene concentration detected in groundwater monitoring wells is 3.8 milligrams per liter (mg/L). This concentration is approximately 760 times the federal Maximum Contaminant Level ("MCL") for benzene in drinking water, which is 0.005 mg/L (5 micrograms per liter). Concentrations at this level represent a significant threat to groundwater quality and to any downgradient receptors that may utilize the Chicot Aquifer as a source of drinking water.
• MTBE in Groundwater: MTBE has been detected in groundwater at concentrations up to 1.2 mg/L. MTBE is highly soluble and resistant to natural attenuation, and its presence at these concentrations is indicative of a gasoline source and contributes to the complexity and cost of the required groundwater remediation.
• Dissolved Lead in Groundwater: Dissolved lead has been detected in groundwater at concentrations up to 0.087 mg/L, which exceeds the federal MCL for lead of 0.015 mg/L by a factor of approximately 5.8. The presence of lead in groundwater is attributable to the historical use of leaded gasoline products at the terminal during the earlier decades of operation.
The contamination profile at the Site is consistent with a mature petroleum release from multiple source areas, with significant impacts to both the vadose zone and the saturated zone. The elevated concentrations of BTEX, TPH, MTBE, and lead in both soils and groundwater confirm the need for active remediation of the source areas and treatment of the dissolved-phase plume.
VI. Potential Third-Party Exposure — Nearest Receptor
DEH has identified the nearest residential receptor to the Site as the property located at 16405 FM 1301, Wharton, Texas 77488, which is owned and occupied by the Ingram family (the "Ingram Property"). The Ingram Property is situated approximately 3,100 feet south-southwest of the current leading edge of the dissolved benzene plume, as delineated by Pinehill's most recent monitoring well data. The Ingram Property is served by a private domestic water well that draws from the Chicot Aquifer.
In February 2025, at DEH's direction, Pinehill collected a groundwater sample from the residential water-supply well at the Ingram Property. Laboratory analysis of that sample did not detect any of the identified COCs at concentrations above their respective MCLs as of the date of sampling. This result indicates that, at the time of sampling, the leading edge of the dissolved benzene plume had not reached the Ingram Property's water supply.
However, DEH and its consultant remain concerned about the potential for future migration of the plume toward the Ingram Property and other downgradient receptors. Given the direction and estimated rate of plume migration, and the relatively limited distance between the current plume front and the Ingram Property, continued groundwater monitoring is warranted to ensure that COC concentrations do not reach the Ingram Property's water-supply well at levels that would pose a risk to human health. Should contamination reach the Ingram Property or other downgradient residential properties, third-party bodily injury and property damage claims would become a realistic possibility.
Accordingly, DEH's notice under the Policy is intended to encompass not only on-site and off-site cleanup costs but also potential third-party claims arising from off-site groundwater contamination migration, including but not limited to claims by downgradient property owners for property damage, diminution of property value, personal injury, or the cost of alternative water supply.
VII. Remediation Cost Estimate
Pinehill prepared and delivered to DEH a comprehensive Remediation Cost Estimate dated April 2025 (the "Cost Estimate"). The Cost Estimate was developed based on the data collected during the Phase I and Phase II Environmental Site Assessments and supplemental investigations, and reflects current market pricing for environmental remediation services in the Texas Gulf Coast region. The Cost Estimate presents a base-case estimate as well as low-range and high-range scenarios to account for the uncertainties inherent in estimating remediation costs at sites with mature petroleum plumes.
The total estimated remediation cost is $9.74 million at the base case, with a low-range estimate of $7.81 million and a high-range estimate of $12.18 million. The principal cost categories are summarized as follows:
DEH's Asserted Share of Remediation Costs. Based on the allocation of responsibility between DTS (as DEH's predecessor) and RCFD, DEH asserts that its share of the total remediation costs is $5.48 million. This allocation reflects DTS's responsibility for the northern tank farm releases, the 2014 loading rack release, and a proportional share of remediation activities in the southern tank farm based on the period and nature of DTS's and RCFD's respective operations.
Cost Recovery Against RCFD. DEH is actively pursuing cost recovery against RCFD for RCFD's allocated share of remediation costs in the amount of $4.26 million, plus $387,000 in investigative costs incurred by DEH to date, for a total claimed amount of $4.647 million. DEH has engaged this firm to evaluate and pursue cost recovery claims against RCFD under applicable state and federal environmental statutes and common law theories. However, the outcome and timing of any cost recovery from RCFD remain uncertain, and DEH cannot provide assurance that RCFD is financially capable of satisfying a judgment or settlement in that amount. Accordingly, the potential for cost recovery from RCFD does not diminish or defer DEH's claim for coverage under the Policy.
VIII. TCEQ Voluntary Cleanup Program Enrollment
DEH has elected to conduct the remediation of the Site under the oversight of the Texas Commission on Environmental Quality ("TCEQ") Voluntary Cleanup Program ("VCP"), as authorized by Chapter 361, Subchapter S of the Texas Health and Safety Code. The VCP provides a structured framework for the investigation and remediation of contaminated properties and, upon successful completion of the cleanup, the issuance of a Certificate of Completion that provides certain liability protections to the applicant and future property owners.
On June 25, 2025, DEH submitted an application to the TCEQ VCP, together with the required application fee of $1,000. The TCEQ has assigned VCP Tracking No. VCP-2517 to the Site. DEH anticipates receiving a formal acknowledgment letter from the TCEQ confirming acceptance of the application on or about August 2025.
The anticipated timeline for the VCP process is as follows:
• Affected Property Assessment Report ("APAR") Submission: DEH plans to submit the APAR to TCEQ by October 31, 2025. The APAR will present the results of the Phase I and Phase II ESAs and supplemental investigations, together with a risk assessment and proposed remediation approach.
• Voluntary Cleanup Work Plan Submission: Following TCEQ review and comment on the APAR, DEH anticipates submitting a Voluntary Cleanup Work Plan for TCEQ approval by approximately April 2026.
• Active Remediation Phase: Active remediation, including soil excavation and disposal and in-situ groundwater treatment, is estimated to commence in June 2026 and continue through approximately December 2028.
• Post-Remediation Monitoring Phase: Following the completion of active remediation, DEH anticipates a period of post-remediation groundwater monitoring to confirm the effectiveness of the remedial actions and to demonstrate attainment of cleanup standards. This monitoring phase is estimated to extend through approximately December 2032.
• Certificate of Completion: DEH's target date for obtaining a Certificate of Completion from the TCEQ is 2033, subject to the successful completion of all remedial actions and demonstration of compliance with applicable TCEQ standards.
TCEQ oversight fees for the VCP are billed at a rate of $225 per hour. Based on the anticipated scope and duration of TCEQ oversight activities, DEH estimates that total TCEQ oversight costs will be approximately $135,000 over the life of the project.
DEH's investigative costs incurred to date — from January 2024 through the present — total $387,000. These costs consist of fees invoiced by Pinehill for the Phase I Environmental Site Assessment, the Phase II Environmental Site Assessment, and supplemental investigation activities, including monitoring well installation, groundwater sampling, and laboratory analysis. These costs have been incurred in advance of enrollment in the VCP and in preparation for the remediation of the Site.
IX. Coverage Implicated Under the Policy
DEH submits that the pollution conditions described in this letter trigger coverage under the Policy. The Policy, as issued by Bridgemont to DEH, provides coverage for the following categories of loss, among others, that are directly relevant to the conditions at the Site:
• On-Site Cleanup Costs. The Policy covers cleanup costs incurred for the investigation and remediation of pollution conditions at scheduled locations, subject to the $500,000 SIR per pollution condition. The soil and groundwater contamination at the Site, as detailed in Sections IV and V above, constitutes a pollution condition at a scheduled known-condition location, and the estimated cleanup costs attributable to DEH's share substantially exceed the SIR.
• Off-Site Cleanup Costs. The Policy covers cleanup costs associated with pollution conditions that have migrated beyond the boundaries of a scheduled location. The dissolved benzene plume at the Site has migrated approximately 2,400 feet downgradient of the southern tank farm and beyond the property boundaries of the Site, necessitating off-site groundwater investigation and treatment.
• Third-Party Bodily Injury and Property Damage Claims. The Policy covers claims by third parties for bodily injury and property damage arising from pollution conditions at or emanating from a scheduled location. As described in Section VI above, the proximity of the Ingram Property and other downgradient receptors to the advancing benzene plume creates a realistic possibility of third-party claims for personal injury, property damage, diminution of property value, or costs of alternative water supply.
The Site is specifically listed as a scheduled known-condition location under the Policy, and the pollution conditions at the Site were disclosed to Bridgemont during the underwriting process as part of the environmental information provided in support of DEH's application for coverage. The Policy was issued with the understanding that the Site had a history of petroleum releases and that further investigation and remediation would be required.
DEH anticipates that remediation expenditures attributable to DEH's share — currently estimated at $5.48 million at the base case — will exceed the $500,000 SIR. Upon exhaustion of the SIR, DEH will look to Bridgemont for coverage of cleanup costs and other covered losses up to the $15,000,000 aggregate limit of the Policy. DEH will maintain detailed, auditable records of all remediation expenditures, including invoices, cost documentation, and evidence of payments, for purposes of SIR tracking and claims documentation. DEH will provide Bridgemont with periodic updates on the status of remediation activities and expenditures as the project progresses.
X. Reservation of Rights
DEH expressly reserves all of its rights, remedies, and claims under the Policy, at law, and in equity, including but not limited to:
• The right to claim reimbursement for all covered cleanup costs incurred above the SIR, up to the aggregate limit of the Policy;
• The right to claim coverage for any third-party bodily injury or property damage claims that may arise from the pollution conditions at or emanating from the Site;
• The right to assert coverage for defense costs related to any third-party claims, including costs of investigation, legal representation, and settlement or judgment;
• All rights regarding Bridgemont's subrogation interests, including with respect to any recovery that may be obtained from RCFD or other potentially responsible parties; and
• All other rights and remedies available to DEH under the Policy, whether arising under the express terms of the Policy, by operation of law, or otherwise.
Nothing in this letter, or in any prior or subsequent communication between DEH (or its counsel) and Bridgemont, shall be construed as a waiver, release, or relinquishment of any rights, defenses, or claims available to DEH under the Policy or applicable law. DEH's provision of this notice is not intended to, and does not, constitute an admission of liability to any third party, a concession as to the scope or extent of contamination, or a limitation on the amount or types of coverage that DEH may be entitled to claim under the Policy.
XI. Requested Actions
In light of the foregoing, DEH respectfully requests that Bridgemont take the following actions promptly upon receipt of this notice:
1. Acknowledge Receipt. Acknowledge receipt of this notice in writing, confirming the date of receipt and the identity of the Bridgemont representative responsible for the matter.
2. Assign a Claim Number. Assign a claim number to this matter and identify the claims adjuster or other contact person who will be responsible for handling DEH's claim under the Policy.
3. Confirm Policy Status. Confirm in writing that the Policy is currently in full force and effect, that all premiums have been paid and accepted, and that the Site remains a scheduled known-condition location under the Policy's schedule of covered locations.
4. Advise Regarding Additional Information. Advise DEH and its counsel of any additional information, documentation, or materials that Bridgemont may require in order to process this notice and evaluate DEH's claim under the Policy, so that DEH may respond promptly and cooperatively.
All future correspondence regarding this matter should be directed to:
Sandra Tung, Partner Calderwood & Harkness LLP 1200 McKinney Street, Suite 4100 Houston, Texas 77010 Telephone: (713) 555-4238
Email: stung@calderwoodharkness.com
Reference: Matter No. 1016-00006; Bridgemont Policy No. ENV-BIC-2024-07821
DEH and its counsel are prepared to cooperate fully with Bridgemont in connection with the investigation, evaluation, and adjustment of this claim, and look forward to a prompt and constructive response.
XII. Enclosures
The following documents are enclosed with this letter for Bridgemont's review and records:
1. Copy of Bridgemont Pollution Legal Liability Policy No. ENV-BIC-2024-07821 (declarations page and scheduled locations endorsement);
2. Executive Summary of Pinehill Environmental Consulting LLC Phase I Environmental Site Assessment (January 2024);
3. Executive Summary of Pinehill Environmental Consulting LLC Phase II Environmental Site Assessment (June 2024);
4. Pinehill Environmental Consulting LLC Remediation Cost Estimate (April 2025);
5. TCEQ Voluntary Cleanup Program Application (filed June 25, 2025), including proof of application fee payment;
6. Site location map and plat depicting the 48.7-acre Site, surrounding land uses, and the location of the nearest identified residential receptor (the Ingram Property); and
7. Summary table of known release history, including dates, volumes, source locations, and corresponding TCEQ Incident Numbers.
We appreciate your prompt attention to this matter. Please do not hesitate to contact me directly if you have any questions or require additional information in connection with this notice.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Sandra Tung Partner 1200 McKinney Street, Suite 4100 Houston, Texas 77010 Telephone: (713) 555-4238
Email: stung@calderwoodharkness.com
cc:
Gavin Rourke, Chairman & CEO, Dunmore Energy Holdings Ltd. Cynthia Ho, Calderwood & Harkness LLP Oliver Mackenzie, Calderwood & Harkness LLP
Remediation Activity | Estimated Cost
Soil excavation and off-site disposal — Southern tank farm | $3,420,000
Soil excavation and off-site disposal — Northern tank farm | $1,870,000
In-situ groundwater treatment (chemical oxidation and enhanced bioremediation) | $2,150,000
Long-term groundwater monitoring (est. 8 years; 32 quarterly events at $33,125/event) | $1,060,000
Institutional controls and deed restrictions | $180,000
Project management, reporting, and regulatory liaison | $1,060,000
Total Estimated Remediation Cost | $9,740,000

CALDERWOOD & HARKNESS LLP Attorneys at Law 1200 McKinney Street, Suite 4100 Houston, Texas 77010

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