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0 <br /> t Closure Appeal, <br /> Flag City Chevron,6421 Capitol Avenue,Lodi,California <br /> Page 5 of 5 <br /> This site should not be considered for closure at this time. There are too many inconsistencies in <br /> the Closure Summary Report prepared by AGE dated August 31, 2005 between the actual data <br /> shown in the tables and on the figures and the data used in the fate and transport model. These <br /> inconsistencies in the report ignore the fate and transport of TPHg and benzene and grossly <br /> underestimate the remaining residual mass in both soil and groundwater at the site. Groundwater <br /> data from the Gilbert and Eileen Moore's Flag City Shell site wells located down gradient from <br /> the Subject Property also warrant not closing the Subject Property until an additional <br /> investigation can be performed. <br /> Sincerely, <br /> APEX ENVIROTECH, INC. ` rwO <br /> Michael S. Sgourakis, P.G. 9 <br /> Senior Geologist 01, CF, <br /> CPG No. 7194 <br /> cc Robert Busby, CVRWQCB <br /> Gil Moore, New West Petroleum <br /> Michael hifurna, STCEHD <br />