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4 ' <br /> Mr. Walt Pettit <br /> November 23, 1994 <br /> Page 2 <br /> For the same reasons that Roek Brothers was placed in the <br /> secondary responsibility position, so to should Union Safe <br /> Deposit Bank. <br /> Furthermore, I would respectfully request that you <br /> instruct the County to designate both Harold and Dena <br /> Knowles and Pepsi-Cola San Joaquin Bottling Company <br /> primarily responsible for the assessment and cleanup of <br /> the site. The technical evaluation prepared by Gil <br /> Torres, Senior Engineering Geologist, for the State Board <br /> concluded that "on the basis of the Knowles family' s 30 <br /> year gas station ownership/operation at 102 South Wilson <br /> Way and the subsequent removal of four underground storage <br /> tanks by Pepsi Cola Bottling Company (prior to the <br /> purchase of the property by Roek Brothers) , both should be <br /> named as primary responsible parties for the unauthorized <br /> release-impacted groundwater beneath and possible <br /> downgradient from the subject site . " As such, it is <br /> proper to instruct the County to designate Knowles and <br /> Pepsi-Cola primarily responsible parties for the <br /> assessment and cleanup. <br /> I would like to thank you in advance for assisting in <br /> clearing up the designation of primary and secondary <br /> responsible parties . Should you have any questions or <br /> concerns, please feel free to contact me . <br /> Very tly y r , <br /> KARNA E. HARRIGFELD <br /> Attorney-at-Law <br /> KEH:cjm <br /> Enclosure <br /> CC : Ted Cobb, Chief Counsel, State Water Resource Control <br /> Board <br /> Lori Casias, Program Manager, Underground Storage <br /> Tank Program <br /> Ms . Donna Heran, REHS, Program Manager, San Joaquin <br /> County Public Health Services <br /> Mr. Chris M. Amantea <br /> Mr. Patrick Riddle <br /> Mr. Donald Roek <br /> Mr. John Donlon <br /> 22802-1 <br />