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r -CRyderRECIEVED Logistics &Transportation Solutions Worldwide NOV 3 2008 October 27, 2008 ENVIR0AIi0EN i HEALTH PERNIMSERVICES Mr. Ray vonFlue San Joaquin Environmental Health Department 600 Main Street Stockton, California 95202 RE: Scope -of -Work Ryder Stockton LC -1041 3633 Duck Creek Drive Stockton, CA Dear Mr. VonFlue, We are diligently working to comply with the suggested scope of work for the Ryder Stockton facility as requested in your email dated October 21, 2008. The following information provides a brief summary of oil tank interstice investigation and testing and the suggested scope of work. On December 19, 2007 Tanknology performed 989 testing on the secondary components of the petroleum underground storage tank system and reported the motor oil tank interstice as a failure. Other issues were also noted with the test boots and the used oil sump. Tanknology re- tested the oil tank interstice on January 4, 2008 and reported the interstice as failing. On February 5, 2008 Tanknology and Stockton Service Station Equipment (SSSECO) returned to the site to retest the secondary components that had failed on December 19 and to investigate the failed interstice on the motor oil tank. The used oil tank interstice again failed the SB 989 testing. The secondary containment piping on the fluids product lines were not retested due to the tester's lack of understanding of the test boot configuration. On October 7 -10, 2008 CRGS and Bonsall Petroleum performed Enhanced Leak Detection Tracer testing on the complete petroleum underground storage tank system as required by the State Water Resource Control Board. All components of the fuel system were reported as passing the ELD testing as was reported to you on October 21, 2008. During the Oct 7-10 testing period, Bonsall performed elective 989 testing on the oil tank interstice and reported passing results (see attached Bonsall 989 report). Based on this data coupled with the fact that the interstitial sensor is reporting a "Normal" status with no reported alarms, Ryder is in the process of scheduling another 989 test to be performed by Bonsall Petroleum. Bonsall will test the oil tank interstice and other secondary components that previously failed or were not tested. Ryder`s position is that the results of the testing performed by Tanknology and SSSECO was possibly erroneous, as we have not been able to identify a leak nor has there been a reported liquid alarm for the oil tank interstice and Bonsall's testing on October 7, 2008 passed. Following the performance of 989 testing on the oil tank and if the test is successful, then Ryder will request no further action. 1630 South Church Street, # 301, Murfreesboro, TN 37130-5554 Tel 615 890 6229 Fax 615 890 5105 www.ryder.com