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since inception. In January, of 2006,we tested the tanks, supply lines, and vapor lines <br /> with a tracer test which showed the entire fueling facility tight at a cost of$26,000. <br /> Every year we test the tanks and lines and tbIey have always passed the tests. We have <br /> not had an unauthorized release to date other than normal break aways at the dispenser <br /> from customer usage or driver errors at deli ry. We have strict policies in place and <br /> self contain any customer or driver spill and dispose of the"kitty litter"in special drums <br /> that Ramos environmental hauls away. Wesent proof in writing with the detailed facts to <br /> CRWQCB of all repairs since inception and proof of the tracer test in January or <br /> February of 2006. We cannot prove, nor can anyone else prove that we had an <br /> unauthorized release through the tanks or lines, or from our monitoring system as we <br /> know it under normal circumstances from 1�97 to today. <br /> However,that being said,I believe that it is�ntirely possible,and according to the facts <br /> from the monitoring wells,contamination occurred through our spill buckets,which <br /> failed several annual tests(that were repaired that same day), and it is entirely possible <br /> that the Gilbarco Vapor Vac system and the vents could have released gasoline fumes <br /> containing MTBE prior to the change of the law in 2003,of which everything was <br /> mandated to new, current equipment that pr vents the vapors from escaping into the air, <br /> unlike its predecessor. The spill buckets were replaced(please see attached dates), and <br /> that would explain why only MTBE had surfaced or subsurfaced,and not the rest of the <br /> hydrocarbons from gasoline,and because thi spill bucket has been completely replaced <br /> some time ago would explain why only MT 3E remains. And last,it has been noted in <br /> the draft that our vapor recovery buckets fai ed a test. According to Walton Engineering <br /> it is impossible for liquid gasoline to get into this area,and as for vapors,this area is so <br /> minute that it is classified as a nondetect area and it is not even suppose to be tested nor <br /> is it required to be tested by law because of his fact. It is impossible,according to <br /> Walton,that any vapor release at this junct> would be detected, and if a line or the <br /> system failed,we would all know. The gas line system would shut down. <br /> In November of 2005, I was called to a mee"g with the San Joaquin County folks,and <br /> Jim Barton of the CRWQCB. I thought wed were entering that meeting to figure out what <br /> and where the contamination was coining from at my station, and to discuss other <br /> potential possibilities since I was very familiar with Flag City,even prior to me owning <br /> this site. For example,I was friends with Bokidas family who owned and operated <br /> the old Texaco site, and another family member owned and operated the Chevron site. I <br /> was familiar with truck and trailer spills at the Chevron in the 80's and the contamination <br /> and spills at the Chevron and the Texaco be ause I worked for the carrier in those days. <br /> Apex asked Jim Barton and the two folks working for the county about the Chevron site <br /> and Jim Barton told us they were receiving closure. He said they have exhausted the$1.5 <br /> million in the FUND, and that the senior Bc kidas has cancer. We expressed concern that <br /> their contamination was larger than the results show. <br /> ow 11M PMOLEUbt <br /> 1831 16TH STREET• SACRAMENTO,�:A 95814. (916) 443-0890 Phone• (916) 443-1170 Fax <br />