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Mr.Nuel Henderson <br /> Re: 102 S. Wilson Way—Petition for Closure Page 8 <br /> was released from that order in May 2004. It is not clear from the record whether <br /> Chevron undertook any remediation activities during that period. <br /> On the other hand, since the Knowles Family Trust was issued an initial letter order,we <br /> have undertaken monitoring and remediation activities from 1995 until the present <br /> time—totaling more than 14 years. The Knowles Family Trust has acted in good faith, <br /> and those efforts have had a demonstrable effect on the quality of the groundwater, <br /> especially considering that peak contamination levels are not reflected in the initial <br /> testing data. (The fact that peak contamination levels were recorded after monitoring <br /> began provides still further evidence that the contaminants originated from another <br /> source.) <br /> Statement of Request <br /> There is inadequate evidence to support the County's conclusion that the contaminants <br /> identified in the initial investigation of 102 S. Wilson Way resulted from an unauthorized <br /> release on the site prior to 1977 when the tanks were removed. However, there is <br /> substantial evidence to suggest contaminant migration from a nearby site which has had a <br /> filling station under continuous operation since that time. Furthermore,the positive <br /> outcomes resulting from the remediation efforts undertaken by the Knowles Family Trust <br /> to date surpass any level of responsibility that could have been reasonably assigned to the <br /> Knowles Family Trust for any release that may have occurred prior to the tanks being <br /> removed. <br /> Because of these reasons, and consistent with the actions taken by the SWRCB with <br /> respect to a similarly situated underground storage tank operator, a"No Further Action" <br /> letter with respect to the site located at 102 S. Wilson Way is appropriate at this time. I <br /> request that such a letter be issued forthwith. <br /> I appreciate your consideration of this official request and look forward to your written <br /> response. <br /> Sincerely, <br /> Carl W. Knowles, Successor Trustee <br /> Knowles Family Trust Agreement <br /> cc: Gregory P. Stahl, Ground Zero Analysis <br />