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I during that- gime utilized and continues to utilize the Exxon <br /> 2 property as a gas/service station, which. included and continues <br /> 3 to include the; ownership and operation of fuel and possibly waste <br /> 4 oil undorgroun± storage tank systems The Exxon property <br /> 5 currently :is being: operated as an "Exxon"' SA /service station. <br /> 6 231 The. Exxon property is situated north Of the T09011 <br /> 7 Property, directly and immediately across West Lodi Avenue from: <br /> 8 the Togo e s ;Property. <br /> 2+ . In or about April. 1991, City retained an environmental. <br /> 10 consultant to investigate the. environmental. condition of the <br /> 11 Togo,s Property, which included soil ancgroundwaiter sampling. <br /> 12 Additional investigatioosand periodic sampling of both soil and <br /> :13 groundwater at the Togo"s Property have been conducted since <br /> 14 April 1391. The results of such investigations: have revealed_ and <br /> 15 continue to reveal significant concentrations of petroleum <br /> 16 hydrocarbons and associated hazardous constituents in the soil at <br /> 17 the Togo's Property and significant concentrations of petroleum <br /> 18 hydrocarbons and associated constituents, volatile organic <br /> 19 compounds, including dichloroethane {"DCA"} , and methyl-tertiary- <br /> 20 butyl-ether MTBE"') , <br /> A. gasoline additive, in the: groundwater <br /> 21 beneath the Togols Property. <br /> 22 25. F.- 0. is informed and believes, and .based thereon <br /> 23 alleges;, that Defendants,, and each of them, except :Defendant <br /> 24 84KIDES, utilized the. Togots Property, including the fuel and <br /> 25 waste oil undergrou.nd storage tank systems, in such a manner as <br /> 26 to release hydrocarbon contaminants and associated hazArddus: <br /> 7 constituents, volatilel organic compounds, including DCA, and. <br /> 28. possibly MTBE: intol the. sail and +groundwater :at the Togo11;s <br />