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Michael Infurna Diane Hinson October 18, 1995 Page 4 the To b History of Operations at the ARCO site (former Ekon Station) additi and tl Autotromc leased the ARCO site in 1971 We have been unformed by indica counsel for Autotronic that in 1971 Autotronic developed the site as a gasoline contai station which included the installation of a UST system Autotronic operated a retail fuel facility at the site under the name "Fill 'Em Fast" until 1986 under In 1986, the Autotronrc's lease was assigned to Mel Bokides (PSA Petroleum, Inc Mel Bokides Petroleum operated an Exxon Station at the site disci: until some time in late 1994, at which time it is our understanding the site was the R shut down The site has been re-opened and presently is being operated by additi Bokides as ARCO retail fuel facility group site b c SaWling Results indicate that operators at both Too and and b ARCO sites are responsible for contamination Parte feet t The PAR makes clear that the soil beneath the Togo's site is . gasol h, contaminated with petroleum hydrocarbons associated with the historical detect operations of the gasoline service station and attendant UST systems See MTB PAR, page 17-20) In addition to earlier investigations, which revealed soil after contamination in the vicinity of the second generation UST system, further investigation by Geocon has revealed hydrocarbon contamination underneath the Togo's structure, where the first generation UST was located ad ) previ, Geocon has concluded that, given the pattern of lateral migration of coni hydrocarbons in the soil at the Property, the soil contamination at the Property expre is attributable to leakage of both the first and second generation UST systems Clear See PAR, page 22) prop( prior Thus, based on the above, all of the past oil company operators at the this r Togo's site are collectively responsible for the soil contamination at the site FDIC Further, if the County believes that ground water contamination beneath the Togo's site is attributable in part to an on-site source and/or requires additional investigation of ground water, all of the past oil company operators at the Togo's sntey should be responsible for conducting additional groundwater investigation and remediation, if necessary The FDIC believes it is ? reasonable and appropriate for these past operators to be ordered by the Togo County to take over the investigation and cleanup activities at the Togo's site towa DOWNEY BRAND SEYMOUR & ROHWER