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I f An SJCEHD Inspection Report on file at the SJCEHD dated January 14, 1987 <br /> 2 indicates that the UST was being removed. Thus, nine months prior to the actual removal an <br /> 3 inspection was done and it was known that the UST was being removed. <br /> 4 g. A letter dated March 27, 1987 from Janet Keir, Secretary of Keir Crane,Inc. to <br /> 5 the SJCEHD on file at the SJCEHD indicates that the"previous"contents were unknown. <br /> 6 h. The Case Closure Summary signed by Donna Heran on May 22, 1997 <br /> 7 indicates that there was no "free product" in the UST upon removal on October 14, 1987. <br /> 8 i. Based on the above, it is most likely that any discharge from the UST occurred <br /> 9 previous to the Keir's ownership of the property, during the period the property was owned by <br /> 10 Turnpike Associates. <br /> 11 j. The record at the SJCEHD evidences that the SJCEHD named Turnpike <br /> 12 Associates as a responsible party fact previously when the site required investigation, and that <br /> 13 Turnpike Associates participated in meetings, etc. regarding investigation of the site. The facts <br /> 14 have not changed since that time and there is no basis to have removed Turnpike Associates as a <br /> 15 responsible party. <br /> 16 5. Petitioner is aggrieved by SJCEHD's failure to act in that she is being held <br /> 17 responsible for assessing and cleaning up the site at 1601 Turnpike when her actions did not <br /> 18 contribute to the contamination, while the parties who are most likely to have caused the <br /> 19 contamination are not being held responsible. <br /> 20 6. The action by SJCEHD the Petitioner requests is that it name Turnpike <br /> 21 Associates and the general partners of Turnpike Associates as additional responsible parties, <br /> 22 specifically, Bill Snyder, Mervyn Totman, and Ralph Smith. <br /> 23 7. Points and Authorities <br /> 24 a. Turnpike Associates and the General Partners of Turnpike Associates <br /> Should Be Named as "Responsible Parties." <br /> 25 <br /> It is appropriate and responsible to name all parties for which there is reasonable <br /> 26 <br /> evidence of responsibility, even in cases of disputed responsibility. In the Matter of the Petition <br /> 27 <br /> of Stinnes-Western Chemical Corporation, Order No. WQ 86-16 (1986 WL 25523 <br /> 28 <br /> DAMRELL,NELSON Cal.St.Wat.Res.Bd.), at p. 6. Furthermore, public policy considerations provide that to the extent <br /> SCFIRIMP,PALLIOS <br /> PACFIER&SILVA <br /> A Professional 3 <br /> Corporation <br />