SITE INFORMATION AND CORRESPONDENCE_2

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Ron Rowe Registered Environmental Specialist February 2, 2000 Page 10 Our understanding of natural weathering processes further supports the conclusion that post- 1979 product was released from the former underground storage tanks. When one considers the high solubility and mobility of TBA and its tendency to biodegrade, (factors that over time, would serve to significantly attenuate TBA in comparison to TPHg) one must conclude that the leaked product originally contained more than 1 percent TBA. Thus, the available information strongly suggests that the gasoline product that leaked from the former underground storage tanks was refined sometime after the USEPA authorized blending of percentage concentrations of TBA in gasoline in 1979. 3. Evidence Employed in Naming Parmaceast as a Responsible Party During the fall of 1994, correspondence between Del Monte and the County urged the County to name Parmaceast as a responsible party. In a letter dated October 26, 1994,the County explained to Del Monte that it would not name Parmaceast unless Parmaceast owned or operated the underground storage tanks prior to the discontinuance of their use. In November 1994, Del Monte responded that it had obtained information about the prior owner of the site and believed that the prior owner also owned and/or operated the underground storage tanks. In a subsequent letter dated December 16, 1994, Del Monte provided the following information to the County. Parmaceast's response to this data is provided in italics: 1) Grant deed from the City of Stockton Redevelopment Agency to Parmaceast. Del Monte explained that the Property was vacant at the time of sale and "Parmaceast immediately began to redevelop the Property." Parmaceast was the owner of the Property from 1963-1976; however, it leased the Property to a corporate lessee, and that lessee subleased the gas station property to Urich. Parmaceast did not build out or operate the gas station at any time. Mere ownership of Property does not make Parmaceast an owner of the USTs. 2) Application for a use permit submitted to the City by Warren Simmons on behalf of Parmaceast to build s service station on the Property. As noted in footnote 21 above, the only significance of this document is that a property owner is required to be a party to a conditional use permit. It does not mean that the Property owner it will be the operator of the gas station business, or the owner of the business's equipment. 3) "Parmaceast, the owner and developer of the site, was composed of two general partners: . . . Mr. Simmons and Fampar, Inc. are responsible parties as the owners of the site when the station was operated and when the releases occurred." 761778.3