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WLsvlsu v LSV <br /> 12 2 2006 <br /> ENVIRONMEN I HEALTH <br /> PERMIT/SERVICES <br /> A P <br /> EX 11244 Pyrites Way•Gold River,CA 95670 <br /> E N V I R 0 T E C H I N C . Phone 916.851.0174• Fox 916.851.0177• Toll Free 1.800.242.5249 <br /> May 16, 2006 <br /> James L. Barton, P.G. <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 11020 Sun Center Drive, #200 <br /> Rancho Cordova, CA 95670-6114 <br /> Attn: James L. Barton, P.G. <br /> Dear Mr. Barton: <br /> Apex Envirotech, Inc. (Apex) has been authorized by Gilbert and Eileen Moore to object to the <br /> closure of the LUST Case No. 390782 for the unauthorized release of petroleum hydrocarbons at <br /> 6421 Capitol Avenue, Lodi California (Subject Property). On April 17, 2006, you sent a letter to <br /> Gilbert and Eileen Moore stating that the Central Valley Regional Water Quality Control Board <br /> is considering closure of Subject Property. Apex has reviewed site data, Cleanup and Abatement <br /> Order No. 5-00-700, and the Closure Summary Report prepared by Advanced <br /> GeoEnviromnental, Inc (AGE) dated August 31, 2005 and has the following objections: <br /> 1) The total petroleum hydrocarbons as gasoline (TPHg) and benzene were not successfully <br /> remediated, still remain at the site, and were not considered in the fate and transport <br /> model. <br /> On May 7, 1993, the San Joaquin County Environmental Health identified soil contamination at <br /> the site during the installation of a tank venting system. Almost two years passed until the <br /> underground storage tanks (USTs) were replaced on March 31, 1995. TPHg and benzene were <br /> detected in groundwater in the UST basin as high as 18,000 and 230 micrograms per liter (ug/L) <br /> or 'parts per billion, respectively. TPHg and benzene were detected in soil samples as high as <br /> 1,500 and 81 milligrams per kilogram (mg/kg) or parts per million, respectively. Soil and <br /> groundwater samples were not analyzed for methyl-tertiary-butyl-ether (MTBE) during the tank <br /> removal event. <br /> In April; 2000, TPHg and benzene were detected in a grab groundwater sample collected from <br /> location P-30-W located in the dispenser area of the Subject Property at concentrations of 11,000 <br /> ug/L and 300 ug/L, respectively. <br /> t <br />