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February 13 , 1996 <br /> San Joaquin County Public Health Service <br /> Mr. Steve Sasson, R.E.H. S . <br /> P . O . Box 388 <br /> Stockton, CA 95201 -0388 <br /> RE: Gasco Service Station, Site 1060 and K & S Gas and Grocery <br /> Dear Mr. Sasson, <br /> Regarding the above sites and corresponding letters concerning the suggestion of <br /> possible contamination originating from our underground storage tanks based on <br /> the data from one off-site B9 well, we challenge any suggestion that our site is at fault. <br /> We agree with your suggestion to Darpetro group to install another well west of our <br /> location to help define and characterize the western edge of their plume. We chose <br /> to disagree with you on the responsibility as to the origin of the alleged leakage and <br /> submit the following practices and measures taken by us which could have easily <br /> alerted us or the inspectors from the Environmental Health Department that there was <br /> any occurrence of leakage from our facilities. <br /> 1 . Kept daily inventory reconciliation records where all data fell within the allowable <br /> limits. <br /> 2. Carried out yearly tightness tests on underground storage tanks and lines for <br /> delivery and recovery systems with passing results. <br /> 3 . No water was found in our tanks at anytime. <br /> 4. In 1995, we passed the ST 27 and ST 30 tightness and blockage tests required by <br /> the Air Pollution Control District, <br /> 5 . In 1993 , inspectors from the Environmental Health Department detected no apparent <br /> contamination in the subsoil during excavation for the installation of a new tank. <br /> 6 . Our system of delivery is by mechanical suction pumps which tend to stop in the <br /> presence of the slightest leak in lines. <br /> We contend that the reasons listed above are more than enough to not buy into any <br /> contamination theory from our facilities and therefore we should not be called upon <br /> to characterize the up gradient portion of the Darpetro site plume. <br /> Although we feel that we were singled out unfairly to shift the burden of proof to, we <br /> still wish to cooperate with all parties involved in tracing, fingerprinting, dating, or any <br /> other means of identifying the alleged release measured at well B9 . <br /> Our plans for upgrading our facilities is due in 1998 . At that time and under the <br /> r <br /> I <br />