SITE INFORMATION AND CORRESPONDENCE

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Honorable K. Peter Saiers April 12, 1994 Page 2 The FHLBB took over ASLA in September 1988, and the FSLIC was appointed receiver. In December 1988, the FSLIC as receiver for ASLA assigned substantially all of the assets and Iiabilities of ASLA to the newly formed American Savings, a federal savings and loan association (the "Bridge Bank"), of which the FSLIC was receiver. The FSLIC as receiver for the Bridge Bank then assigned various assets and liabilities, including the Property (and any associated liabilities) to New West Federal Savings and Loan Association ("New West"). Effective on or about June 30, 1993, New West transferred the Property to Irvine Service Company. A tank tightness test was performed by ASLA in April 1988 which revealed failure of at least one of the four underground storage tanks at the Property. Following additional testing and work with regulatory officials, the tanks were removed in June 1990. A. Source of Release Historical documents indicate that the underground storage tanks were installed in 1961, making the tanks almost 30 years old at the time of removal. The April 1988 tank tightness test provided evidence of tank failure. Subsequently, subsurface investigations were performed with the purpose of verifying that contamination was present and to define the extent of the contamination. According to findings by Woodward & Clyde in the initial site assessments and corrective action plan, almost 900 cubic yards of soil were impacted by the product release. In addition, subsurface investigation revealed contamination of the soils and groundwater at 85 feet below ground surface. The doth and extent of the contamination identified during the investigations and subsequent remediation is highly indicative of a long term historical product release. Following tank removal in June 1990, FGL Environmental performed soil testing which revealed the presence of lead. Lead was an important anti-knock ingredient in gasoline until the advent of automobile pollution control devices requiring unleaded gasoline, which was about 1972. The leaking tank was identified as a 10,000 gallon unleaded gasoline tank. It appears as though at some point between 1961, its initial service date, and 1988 (the point at which it failed the tank tightness test) this tank was converted from leaded gasoline to unleaded gasoline. Since unleaded gasoline was not in distribution until 1972, we can reasonably conclude that from 1961 until at least 1972, this tank contained leaded gasoline. This would account for the presence of elevated lead levels in the subsurface soils and would provide further evidence that the contamination resulted from a historical product release. 32960.1