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15 August 2000 AGE-NC Project No. 96-0232 Page 2 of 3 Both CPTT and Tanknology recommended a standard pressure test as the best alternative for evaluating the integrity of the primary product lines and a helium test to evaluate the integrity of the secondary product line. • On 03 August 2000,AGE met with Mr.Richard Bokides and Mr.Navtej Dhingsai to discuss the above mentioned CRWQCB-CVR and PHS-EHD directive letters. It was decided that the CRWQCB-CVR and PHS-EHD directives would be satisfied by performing the above mentioned tracer test on the product lines and by collecting soil samples directly beneath the fuel dispensers. • On 07 August 2000,AGE contacted Mr.Michael Kith of the PHS-EHD by telephone to see if the PHS-EHD had issued the directive letter for "helium tracer testing" as stated above. Mr. Kith stated he was not aware if the directive letter had been mailed out; he further stated that AGE should write a letter request to the PHS-EHD for the proposed product line testing so that he could confer with his supervisor, Ms. Kasey Foley. • On 07 August 2000, AGE recommended by letter to the PHS-EHD (Appendix A) that a standard pressure test be performed on each primary product line to satisfy annual tank testing requirements and a helium tracer test performed only on the secondary product lines to satisfy the PHS-EHD and CRWQCB-CVR directives. hr the letter, AGE stated that the "helium tracer test" was scheduled with CPTT for testing to commence on Thursday, 10 August 2000 at 7:00 A.M. • On 10 August 2000, CPTT removed the side panels of each fuel dispenser for observation and soil sample collection; CPTT initiated "helium tracer testing" on each product line. During the tracer test, Mr. Kith notified AGE that a"helium tracer test"was not a State of California-certified precision test and would not satisfy the PHS-EHD directive; a State of California-certified"Tracer Tight Precision Test"would be necessary to satisfy the PHS- EHD directive. Furthermore, approximately 4 to 5 feet of pea-gravel backfill material was encountered beneath each fuel dispenser and AGE was unable to collect soil samples through the pea-gravel. Therefore, AGE discontinued the"helium tracer test" and all fuel dispenser soil sampling efforts. • On 14 August 2000, AGE was notified by Mr. Doug Wilson by telephone that a State of California-certified"Enhanced Tracer Tight Precision Test"with leak detection capabilities of 0.005 gallons per hour was required to satisfy the PHS-EHD. Furthermore,AGE has been informed that only one precision testing company in the United States was State of California-certified to perform the above mentioned testing (Tracer Research Corporation, Tucson, Arizona). • On 14 August 2000, AGE contacted Mr. Ian Harris of the Tracer Research Corporation to schedule an"Enhanced Tracer Tight Precision Test". Mr. Harris indicated he did not have Advanced CeoEnvironmental,Inc.