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Advanced GeoEnvironmental, Inc, 07 August 2000 AGE -NC Project No. 96-0232 Mr. Michael Kith San Joaquin County Public Health Services - Environmental Health Division 304 East Weber Avenue, Third Floor Stockton, CA 95202 Subject: Gasoline And Diesel Product Line Testing FLAG CITY CHEVRON - 6421 Capitol Avenue, Lodi, CA 95242 Dear Mr. Kith: On behalf of Mr. Richard Bokides, property owner of Flag City Chevron located at 6421 Capitol Avenue (site), Lodi, California (See Figure 1), Advanced GeoEnvironmental, Inc. (AGE) is hereby requesting to schedule a standardized pressure test on each primary fuel dispensing product line and a helium tracer test on each secondary fuel dispensing product line with the San Joaquin County Public Health Services - Environmental Health Division (PHS-EHD). On 31 July 2000, Mr. Doug Wilson of the PHS-EHD informed AGE in a telephone conversation that the PHS-EHD was preparing a letter directive to the Flag City Chevron facility to conduct a "helium tracer test" on all fuel dispensing product lines. Furthermore, Mr. Wilson iterated that the Flag City Chevron facility needed to install secondary containment pans beneath each fuel dispenser to satisfy the existing State of California underground storage tank (UST) laws. In telephone conversations with Champions Precision Tank Testing (CPTT) and Tanknology, both State of California certified to perform tank and product line integrity tests, AGE was informed that helium testing performed on dual walled product line system would only identify a leak at the point of breach in the secondary product line containment system and not the primary product lines; furthermore, there would be no way to identify where the breach was in the primary product line from a helium tracer test. 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. Therefore, AGE recommends that a standard pressure test be performed on each primary product line to satisfy annual tank testing requirements; a helium tracer test should be performed only on the secondary product lines to satisfy the above mentioned PHS-EHD directive. AGE believes that the proposed standard pressure test will locate whether or not there are breaches in the primary product line and a helium tracer test will be tested on the secondary product lines to identify areas of fuel leakage. All fuel leakage detected from the above mentioned primary and secondary product line tests would require immediate damage repairs to the associated product line(s) in accordance with San Joaquin County guidelines. 4005 North Wilson Way. Stockton. California 95205 Telephone (209) 467-1006 FAX (209) 467-1119