SITE INFORMATION AND CORRESPONDENCE

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16 January 2004 AGE-NC Project No. 02-0964 Page 3 of 4 AGE and the Sutter Office Center hereby appeal the S.WRCB Staff Decision which found their USTCF claim to be ineligible for placement on the priority list, as stated in items 3,4 and 5 of the Technical Review Unit,memo dated 08 December 2003.First,the EHD and California Regional Water Quality Control Board are not aware of any "regional ground water problem" in central Stockton,which may be the source of the hydrocarbon plume of impacted ground water at the Sutter Office Centerproperty.Please provide substantial evidence that this"regional ground waterproblem" in central Stockton exits. AGE and the Sutter Office Center hereby appeal the SWRCB Staff Decision which found their USTCF claim to be ineligible for placement on the priority list and request your review of the Staff Decision, as stated in items 3 and 4 of the Technical Review Unit memo. Currently,AGE has specific knowledge of UST releases in central Stockton and elsewhere across California,which are over fifty years in age,that are substantial in concentration and pose a significant risk to ground water quality (presents of benzene). Please provide an explanation of the Technical Review Unit's justification to the demonstrate how and at what rate ground water contamination degraded at the Sutter Office Center(possible a ground water fate and transport model). Otherwise, AGE and the Sutter Office Center hereby appeal the S WRCB Staff Decision which found their USTCF claim to be ineligible for placement on the priority list,due to increasing contamination documented at greater depths.AGE,the EHD and Board can readily document this vertical migration phenomenon,at site within 2,000 to 2,500 feet of the Sutter Office Center property,in central Stockton.Additionally,the vertical increase of contamination, as demonstrated by extensive site assessments,has been typical and not extraordinary of the course for most older UST releases. Please be aware that the lateral, upgradient extent of the Sutter Office Center plume has been fully defined.Therefore,the Technical Review Unit's justification is contrary to most extensive site assessment conducted in the Central Valley of California and Southern California and further, and further contradictory to the site assessment evidence. AGE and the Sutter Office Center hereby appeal the SWRCB Staff Decision which found their USTCF claim to be ineligible for placement on the priority list and request your review of the Staff Decision, as stated in item 5 of the Technical Review Unit memo. The greatest concentration of ground water and general shallow soil contamination at the site,is located directly north and near the southern edge of the small,northeastern, former dispenser island operated from the 1930's until the abandonment in 1960. The greatest vertical contamination concentration is generally, directly under the same former dispenser island. AGE and Sutter Office Center submitted a site plan which depicted both locations of each entire UST system for each generation of operation, as based on photograph of the site as collected by outside photographers, recorded with The Bank of Stockton and recorded with the SJC Assessors Office. At best the plume of impacted ground may be commingled with an equal apportionment to both potential releases. However, due to the initiation of UST integrity test and monitoring not until after thel980's, no know testing data.or monitoring data for the in-place or removed UST sets has been readily documented with the EHD, (historical records were not readily available for either address of 434 or 448 East Miner Avenue)likely due to the lack of any regulations regarding discharged waste from UST prior to the mid-1980's. Advanced GeoEnviromntntal,Inc.