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