SITE INFORMATION AND CORRESPONDENCE_FILE 1

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• 10 Ms. Linda Turkatte, R.E.H. S. June 16, 1993 Page 2 Services, Environmental Health Division ("PHS/EHD") , on the following requests hereby made on behalf of Roek Brothers: 1. PHS/EHD name adjacent landowners as additional responsible parties for groundwater contamination. 2 . PHS/EHD authorize implementation of a workplan for investigating and confirming relationship between soil and groundwater contamination at the Site. 3 . Confirm that Roek Brothers is secondarily liable for site contamination. We believe that the law, as well as numerous decisions of the State Water Resources Control Board ("Board") provide ample support for these demands, as set forth below. We are requesting a written response to our demands at this time so that, if necessary, we may appeal the County's conclusions to the State Board in accordance with Section 7 of the Memorandum of Understanding between the County and the Board, and Health and Safety Code Section 25927 . 1 (h) . B. Naming of Additional Responsible Parties. We understand that the following parties have been identified as responsible parties: • Roek Brothers because of its status as the current owner of the Site; • Pepsi Cola San Joaquin Bottling Company because it was the property/tank owner when the tanks were removed; • Union Safe Deposit Bank because it was in the chain of title after the tanks were removed; and • Harold and Dena Knowles because they were the last operator of the tanks immediately prior to their discontinued use. We request that the past and present owners and opera- tors of 101 South Wilson Way ("Adjacent Landowners") be named as additional responsible parties. The factual basis for this request is that there have been documented releases from under- ground storage tanks at 101 South Wilson Way which is located directly upgradient from the Site. F:\TRN\77093\C\ROEK.JMZ 75376/JMZ/O6/16/93/2