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Ms. Laurie Casias <br /> September 3, 1993 <br /> Page 4 <br /> 2 . on December 7, 1988, two tanks were removed from 101 <br /> South Wilson Way and the unauthorized release report documented <br /> contamination (Exhibit A) . The tank inspection report for both <br /> tanks state that the conditions of the tanks were "poor" and <br /> contained "holes" with significant "corrosion" (Exhibit B) . Soil <br /> samples taken from beneath the two tanks established the <br /> following results: <br /> Chemical(ug/ka) Tank 1 Tank 2 <br /> TPH-g 2 ,200,000 1,600,000 <br /> Benzene 22, 000 0 <br /> Toluene 100, 000 0 <br /> Xylene 60,000 520,000 <br /> Ethyl Benzene 60, 000 68,000 <br /> Ug/kg=micrograms per kilogram <br /> TPH-g=Total Petroleum Hydrocarbons as gasoline <br /> (Exhibit C) . <br /> Not only are these documented releases substantial, they continue <br /> to remain uninvestigated and unremediated. <br /> 3. The current owners of 101 South Wilson Way were required <br /> on February 3, 1989, to conduct further site assessment of the <br /> documented contamination (Exhibit A) . While the property remains <br /> an open site, to date the property owners have not undertaken a <br /> single required act or cost for site assessment or remediation, <br /> while the Petitioner has been actively (and voluntarily) pursuing <br /> corrective action at their Site. <br /> 4 . The pursuit of Petitioner and the non-inclusion of the <br /> Adjacent Landowners is inequitable and unjustified. This is <br /> particularly true in light of the fact that information compiled <br /> from investigations undertaken by Petitioner's at the Site have <br /> not confirmed that the documented groundwater contamination under <br /> the Site resulted from an on-site source. Rather, the data <br /> indicates that contaminated groundwater is migrating on-site from <br /> up-gradient sources. In specific: <br /> a. BTX&E and TPH levels in the groundwater (<10 <br /> ug/kg) directly below the soil contamination <br /> in the northwest corner are much lower than <br /> would be expected from a source area; one <br /> would expect that residual fuel in the soils <br /> would, through sorption/desorption processes <br /> have continued to contribute to higher <br /> groundwater contamination levels; <br /> F1\TRN\17093\D\ROEE3.REE <br /> 75376-17093/=/09/03/93/4 <br />