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ACi t.P4EHr0 <br /> CVRV/ OC© <br /> rI-6 wV 20 PH 3: 25 <br /> Friday,November 17, 2006 <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 11020 Sun Center Drive <br /> Suite#200 <br /> Rancho Cordova, Ca. 95670-6114 <br /> Attention: Brian Newman,P.E. <br /> Underground Storage Tank Program Manager <br /> Dear Brian, <br /> Apex Environmental and I,owner of Flag C ty Shell,are responding to the draft cleanup <br /> and abatement order no. R5-2006-XXXX aE d draft monitoring and reporting program,at <br /> 6437 West Banner Street,Lodi,located in S Joaquin County. <br /> I would like to preface this letter with some background that perhaps is new to you, <br /> Brian. I started New West Stations,Inc.in 1994 with my first gasoline station that I <br /> bought in Livermore,Ca. I started New W Petroleum in 1986,a wholesale <br /> distribution company, located in Sacrament at 183110 h Street, Sacramento. I am a <br /> Board member of NACS (National Associal.on of Convenience Stores),member of <br /> CIOMA(California Independent Marketers s.), Sigma(Society of Independent <br /> Gasoline Marketers Ass.),and a member of MA(Petroleum Marketers Ass.)in good <br /> standing. For those in this industry and part iering businesses,governmental agencies, <br /> etc.,I have one thing in common with every dy and everything I do, and that is an <br /> impeccable reputation of doing what is right,and being fair. It appears to me,that the <br /> draft before me is hostile and accusatory. <br /> I currently own and operate 36 gasoline stat ons in Califomia. I have never had a <br /> malfunction of equipment,release of gasolb Legasp ' or diesel,truck spill,drive off,or any issue <br /> T that was not taken care of within 8 hours. I very sensitive to the problems of our <br /> N% industry,and have a full understanding of try,and my heirs,liability and responsibilities <br /> to the environment. It is with great sadness that I read this draft accusing me"that I have <br /> failed to demonstrate the release has been s pped". There are also many accusations that <br /> are simply untrue in the draft. We,Apex arid 1, are confused and do not understand since <br /> we have done everything right and quickly. <br /> I built this site from scratch and put the finest equipment money could buy both <br /> underground and above ground in 1997. have tested the lines and tanks regularly <br /> �b FW WEST pfflouUg <br /> 1831 16TH STREET• SACRAMENTO, A 95814. (916) 443-0890 Phone• (916) 443-1170 F� <br />