Contaminated Fueling Stations Issues

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Former Berkeley Chervon Service (Gateway) Station #9-0171
L AWood, April 5, 1995

Last Thursday I spoke to you about the remediation process at 1101 San Pablo ave., Berkeley. Subsequent to our conversation I also reviewed the site file and have spoken directly to Mark Miller of Chervon. I write this letter to express my concern over the current and future toxic clean-up at this location.

As you are aware, in mid 1993 the Zoning Adjustments Board issued an Use Permit (#A2081) for the 1101 San Pablo site which incorporated a Negative Declaration. I was quite surprised to see that this could happen given the high levels of contamination occurring both on-site and off-site.

The California Environmental Quality Act (CEQA) findings on the site contamination and remediation stated: Pursuant to Section 2108.6 of the Public Resources Code, a reporting program has been adopted and incorporated into the conditions of project approval, in order to report on completion of mitigation measures which are intended to avoid significant effects on the environment.

At present, there are no assurances that anymore on-site or off-site remediation will take place though the CEQA report clearly reflects the need for a follow-up on the approved site work plan. It appears that the City of Berkeley is allowing another contaminated property to enter into a "pseudo-closure" The city has failed to enforce Chervon's obligation to the remediation work plan for 1101 San Pablo (especially for off-site efforts) while allowing for development of the site.

The site work plan calls for an implementation of the remediation concurrent with the site development. The new property owner, C&H Development Company was to plan for and construct a building for a combined GW/SVE system. This remediation system was to be installed on the roof. The current owner is perhaps exempt from the CEQA findings but the use permit does not exempt Chervon from its obligation to off-site remediation.

Chervon is actively involved in the planning or the implementation of the final phase of the clean-up as the site begins development. The First Quarter report of 1995 indicates the existence of considerable off-site contamination. Benzene levels, detected at monitoring well A-4, are over 7000 ppb. Accompanying this site report was a communication from Mr. Miller dated March 9, 1995. In this letter he states that Chervon is "studying the potential benefits, if any, of continuing to operate a remedial system in the future once development of the site is complete".

In my own discussion with Chervon, Mr. Miller indicated that Chervon had done enough or spent enough since 1981 to affect a clean-up of the site. In addition he was under the impression that no current technologies are available to get the site any cleaner. I did suggest that most bio remediation methods (such as was employed at this site) generally require more time and only work when afforded' full implementation. And that this has not been the case at the old Chevron fueling station.

The groundwater remediation system used at the site was in operation barely four years and experienced some down time. The installation of the groundwater system was purposely linked to the development of the property to insure the successful completion of the remediation.

On March 1, 1994 the City of Berkeley gave a Notice of Violation to Chervon, stating that it appears that Chervon was in violation of Section 2652 of detailed site activities title 23 of the California Code of Regulations. In a response to the notice of violation Chervon stated that the current groundwater system would remain in place until the combined GW/SVE system was installed. This has not been the case. The groundwater remedial system was recently removed along with a dozen or more on-site monitoring wells. On-site development should run concurrent with both on-site and off-site remediatiori efforts. It would seem that Chervon,lnc. and the site have once again fallen out of compliance.

The Chervon overall site remediation plan has shown a failure to recognize the mixed residential use of the surrounding area. This has been particularly evident in Phase II when such a large volume of contaminated soils were spread across the site and its toxic vapor allowed to vent into the community. Again, the apparent reluctance of Chervon to pursue further remediation is suggestive of this same failure. It is incumbent upon Chervon to begin immediate steps to incorporate the remediation plan into the development project.

In the last month residents have complained of the smell of gasoline coming from near or around the storm drain closely associated to the site. In responding to complaints, Chervon inspected the site, and indicated that they found no problem. This site investigation was not accompanied by any sufficient testing. The city of Berkeley should make an independent investigation of this matter because of its possible connection to the site contamination and remediation process. Perhaps they can make a more definitive statement concerning the source of the smells.

Several years ago Chervon began to sell the idea of a *special" on roof remediation system which would be integrated into the site development. It has become clear that this discussion was only engineered for the purpose of site development and not directed at their obligation for both on-site and off-site contamination. The current site development project is only compatible with the community if the remediation is designed and implemented within the use permit process. The city of Berkeley has an regulatory obligation to this end.

Problems with toxic cleanup method aired
Will Harper, Berkeley Voice, September 14, 1995

Problems with toxic cleanup method aired: City officials, gas station neighbors frown on aeration

When Leslie Marks bought her west Berkeley home in 1992, she never suspected the closed gas station next door posed a danger to her. The person who sold her the house neglected to tell her there had been underground gas leaks at the site, she said.

Earlier this summer a toxic cleanup of the site at 2700 San Pablo Ave. started after the go-ahead was given by various local, regional and state agencies.

The remediation a plan used a controversial and relatively inexpensive cleanup method known as aeration in which polluted soil is unearthed and essentially aired out over a period of time.

Marks said the fumes have caused her an ongoing sore throat, nausea, burning eyes and severe headaches. The fumes have also made her house is uninhabitable, she said. Marks, an artist, now either stays in her studio down the street or with friends.

I'm furious," she said while standing across the street from the site and her home. "I've got a house I've got to continue to pay for and I can't use it."

Marks said she was notified that the cleanup was going to take place, but she was not told what method was going to be used. A city toxics official acknowledged an odor definitely emanated from the site, although that did not mean the site posed a health hazard. A sign posted by the city said measured air emissions did not reveal the presence of benzene -- a known cancer-causing agent often associated with contaminated gas sites. The posted sign said the air being emitted from the site posed no health risk to the surrounding community.

Still, environmentalists question the wisdom of using aeration to clean up sites in urban areas near homes and businesses. It's a method better suited for rural or industrial areas, environmentalist say.

According to the city toxics program there are 40-50 underground storage tank sites in Berkeley, many of which may be contaminated. If the owners of those sites all wanted to clean up their property using aeration there's little the city could do now to stop them.

The Community Environmental Advisory Commission last month unanimously passed a resolution strengthening the city's policy on the use of aeration. The commission's recommendation goes to the City Council for final approval some time in the next month.

Nabil Al-Hadithy, staff secretary to the commission, said the commission wants to establish a city policy that would declare aeration an unacceptable method of toxic cleanup or remediation. The commission's recommendation would also require property owners to protect soil stockpiles from water and wind and remove those stockpiles from the polluted site within 30 days.

Currently, Al-Hadithy said, the city's policy is to advise property owners not to aerate on site, But the city doesn't have the legal authority to prevent owners from aerating if they insist on doing so. That's because the Bay Area Air Quality Management District, the regional body that regulates local air standards, permits aeration and doesn't allow cities to ban it. What the air district does allow the city to do, Al-Hadithy said, is strengthen restrictions. "Consequently, we have to be creative and restrict aeration without banning it," he said.

"I'm longing for something stronger, but it's the best we could do under the circumstances," said Jami Caseber, the vice-chair of the commission. The appeal of aeration is that it is a relatively cheap remediation method.

A city policy at simply restricts aeration still can deter its use, Al-Hadithy said. Property owners will know from the beginning that the city doesn't want them to aerate. If owners insist on using aeration they must seek the permission of three regional and state boards.

In the case of 2700 San Pablo, Al-Hadithy said, a city policy opposed to aeration may have prevented its use on the site. Such a policy may have been more persuasive to the to State Water Resources Control Board -- which controls the purse-strings to the state's underground storage tank cleanup program paid for by gas taxes -- than an individual city toxics inspector advising against it, Al-Hadithy said.

There are some air quality management districts in the state that don't permit the aeration of polluted soils, Al-Hadithy said. The Bay Area air district only restricts aeration if a property is very large or extremely contaminated. Relatively small properties like gas stations generally qualify to aerate on site, Al-Hadithy said. I'd be happy if other cities in the Bay Area follow our lead, not only because it's good policy but also because it's bad policy to take pollution from one medium (soil) and transfer it to another on.

Caseber said he'd like the city to lobby the regional air board to ban aeration. Al-Hadithy said the city already takes pro-active measures to protect the community from adverse health impacts by requiring preliminary health risk assessments and air monitoring of polluted sites. If aeration of petroleum hydrocarbons, like those found at gas stations, wore to adversely affect the health of nearby residents, the city can shut down a site. In most cases, however, Al-Hadithy said such aeration does not have any measurable health impact.

Still, there are less measurable "nuisances" effects which go along with aeration such as the smell of gas having a psychological or sensitizing impact on surrounding residents. Such effects can't be measured by a toxicologist, Al-Hadithy said, but are valid nevertheless.

Local environmentalist and neighborhood activist L A Wood said while the city's efforts to further restrict aeration was a step in the right direction, still more can be done. Wood suggested the city could offer incentives to use safer alternative remediation methods, such as bio-venting, that don't send volatile compounds into the air. Wood added that the city should require more complete public notification so nearby residents know what's happening when a toxic site is being cleaned. For example, Wood said, residents near the site at 2700 San Pablo received only a vague notice that didn't warn of any potential health effects.

"Public notification of remediation activities is delivered like a pizza flyer, stuffed in residents' doorways. A more formal notification process should be a requirement for every toxic site in Berkeley," Wood said. "All those people involved in remediation have a right to know the types of contaminants, work schedules, the actual health effects these contaminates have. People should be warned so they can avoid areas that are being remediated or aerated," he said.

Al-Hadithy said if preliminary health risk assessment required by the city showed a potential health hazard then the city would not allow aeration to take place on the site.

Polluted properties for sale during alleged data-fixing
Will Harper, Berkeley Voice, July 25, 1996

Two polluted Berkeley properties around the time a former company employee allegedly falsified lab data on soil and groundwater contamination, a county inspector's report says. The altered data made it look like former service station sites at 1285 Eastshore Highway and 1101 University Avenue, both contaminated by underground gas leaks, were cleaner than they really were when they were sold four years ago.

County investigators say Nancy Vukelich, a former Chevron remediation project manager, altered lab results in order to persuade local regulators to expedite "closure" of the sites -- a decision that no further cleanup is required.

"The false information allowed for the sale and redevelopment of two properties in the City of Berkeley and the near sell of (a third property) in San Lorenzo," Deputy District Attorney John Samuedson said in an 11-page report.

The University Avenue property, on the north east corner of San Pablo Avenue, now supports a new minim retail mall that includes Blockbuster Video. C & H Development Co. of Lafayette says it bought the land from Chevron for approximately $300,000 in 1992 and county property records indicate the company has since pumped in more than $1 million toward developing the site.

Basil Cristopolous, co-owner of C &H, said the more favorable data didn't raise the initial purchase price of the property. He said C & H knew the property required more cleanup and noted that Chevron was still responsible for remediating the site to comply with local and state environmental laws. "From our perspective, it really doesn't affect us," Cristopolous said. "The Nancy Vukelich thing is too bad (But) it wasn't clean when we bought it, and Chevron is still remediating it." Chevron installed a so-called vapor extraction system on the site to remove remaining underground pollutants. Cristopolous added that there also is an "impenetrable" vapor barrier protecting employees and customers.

The other Berkeley property at 1285 Eastshore Highway was sold to Joseph and Helen Garello of Napa in May 1992 for around $263,000, county property records indicate.

Vukelich faces 44 misdemeanor counts of falsifying lab reports prepared by outside environmental consultants over a three-year period from 1991-94, Those altered reports were submitted to city, county and state regulators. At this point investigators say that Vukelich, who left Chevron in March 1994, acted alone.

"Anything may happen," said Larry Blazer, a deputy district attorney in the consumer and environmental protection division. "(Vukelich) hasn't told us the extent of this. But we haven't seen anything suggesting that anyone else was involved"

Blazer said the financial motive for the company seemed limited because when polluted properties are purchased, buyers usually ask to be indemnified and Chevron would still be liable. County property records show C&H has such a deal on 1101 University Ave. and Blazer said the buyer of a San Lorenzo site handled by Vukelich was also indemnified.

City toxic waste regulators won't say how much more contaminated the sites are now, but will say the levels don't exceed current legal environmental standards. Chevron officials insist that the sites managed by Vukelich are safe despite there being a higher level of gas, benzene and other pollutants than previously believed. Chevron spokeswoman Bonnie Chaikand said she couldn't discuss the specifics of the case. Chaikand did say the company doesn't tolerate changing data for any reason.

"As soon as the discrepancies were noticed we immediately went through the proper notifications and brought it to the attention of the proper (government) agencies," Chaikand said. "I feel that speaks for itself,"

Chevron officials were questioned by county investigators last fall after the company disclosed there were discrepancies between consultants' data and reports Vukelich sent to regulators.

Mark Miller, the site remediation project manager who took over for Vukelich after she resigned, told a supervisor that he thought the reports were altered using cut and paste method.

The supervisor, John Randall, told investigators he didn't know why Vukelich would change the lab reports. He did say, according to a county investigator, that Chevron had a program where employees can get a pay raise, awards, gift certificates or up to $1,000 cash for good performance.

L A Wood, a local environmental watchdog who has closely followed the University Avenue site's cleanup, was skeptical whether such performance perks were enough to motivate Vukelich to break the law. Wood said Chevron had a clear financial motive to unload distressed properties. He said Chevron pushed city officials hard to allow the company to continue to clean up the property after it had been developed, instead of waiting until all the pollutants had been removed. "I can't imagine an employee doing this by themselves. There doesn't seem to be any benefit for her," Wood said.

Vukelich, who was arrested in Arizona earlier this month, agreed to be extradited to California last week, authorities said. The law gives California officials 30 days to bring Vukelich over state lines, an Arizona extradition official said. Neither Vukelich's Bay Area or Arizona attorneys returned phone calls from The Voice.

TuneUp Masters Faces City Council
Devona Walker, Berkeley Daily Planet, April 7, 2002

The public hearing concerning TuneUp Masters and the possible revocation of the garage's business license due to an ongoing nine-year dispute with neighbors who say the business is just not in tune with Berkeley had two distinctly different sides last night.

At the beginning of the public hearing the lawyer for TuneUp Masters started off with a "spirited" argument against the city for not respecting the laws of due process. He also alleged that demands placed on TuneUp Masters by the city have put it at a competitive disadvantage and threatened livelihoods.

"Berkeley is a wonderful place," said Robert Zweben, legal counsel for TuneUp Masters. "But this process has been the most bizarre I've ever been through."

Zweben alleged that the city's process has unfairly targeted the business due to a grudge held by Councilmember Dona Spring and the constant "nagging" of a few citizens; mentioning Michael Popso a neighbor of TuneUp Masters by name.

At one point Zweben even stated that the city's intention for the last several months has been to frame his client.

"Due to the nagging of Mr. Popso you decided we're not going to warn anyone. We're not going to issue any citations, we're going to build a case," Zweben said. "You want them to respond to these that happened over a year ago, that's just insane. It's not fair. It's not right. It's not constitutional and it's un-American."

At one point Zweben even told the city that they did not have the jurisdiction to revoke the business license.

At the March 21 city council meeting prior to the holding of a public hearing regarding the possible revocation of the business license Councilmember Dona Spring lashed out at the business stating that they city should just close them down.

All councilmembers are legally required to enter into public hearings without bias, consequently Spring's comments may have placed the city into a legally vulnerable situation. The out for the city, however, was for Spring to recuse herself from all arguments surrounding TuneUp Masters.

Walline of TuneUp Masters said yesterday that the company would consider suing the city if need he, hut that decision would be based upon what was being said at the public hearing.

Prior to last night's public hearing the City Council met behind closed doors to discuss the issue. When asked whether or not the meeting was held to discuss any legal vulnerability for the city, Councilmember Kriss Worthington said he was not allowed to comment.

"But I will say that even if all eight of us were to vote that you should recuse yourself, the responsibility to do so still lies on the individual," Worthington said. "We, the rest of council, have no authority."

Asst. City Attorney Zach Cowan would also not comment on the closed session discussions. Spring, however, through her silence seemed to say the most. She declined to comment on discussions regarding the business revocation, apparently untying the city's hands and freeing it from the perception that due process may have been violated.

Her silence set a different tone for the second half of the meeting.

Councilmember Linda Maio began by resurfacing several past offenses of TuneUp Masters and stating that she believed the business basically disregarded the rules until the owners realized the city was serious about closing them down.

"And now you say we've made staffing changes and we've let that person go. But things only happen in the 11th hour Mao said. She also stated that the company should have disciplined employees who were failing to comply with restrictions placed on the business by the city independently of the city having to send out someone to monitor and report their violations.

"You should have someone on-site making sure your employees are doing what they are supposed to do," she added in reference to allegations from neighbors that the business is still operating after hours, that tainted water has been dumped down storm drains and that the business is generally a public nuisance.

Berkeley resident L A Wood earlier in the evening seemed to address a similar issue.

"The problem is that this is an out-of-town business with absentee management and they are not the kind of business that cares about Berkeley," Wood said.

But not everyone had bad things to say about the business. Despite this nine-year battle, several community members supported the business and stated they were indeed good neighbors.

One citizen even hinted that the city just wanted the business out so that affordable housing could he built on the site.

No action was taken and the public hearing will be continued until next week.

Alternative methods of remediation that are non-invasive
From City of Berkeley to L A Wood, January 26, 1994

This is in response to your letter dated January 3, 1994 to the City Council and a recap of the meeting held on Friday, January 21, 1994 with Denise Barndt and Nabil Al-Hadity of the Emergency and Toxics Management program.

Based on the discussion at that meeting, staff would like to expand on the two issues that concerned you most:

1. Alternative methods of remediation that are non-invasive.

As you correctly pointed out, it is apparent that the primary method of remediation for contaminated soils seems to be excavation and disposal or recycling of contaminated or polluted soils. Alternative methods are available, such as bioremediation, bioventing, vapor/water extraction and a combination of the above. It should be pointed out that some vapor extraction methods are capital intensive technologies and bioremediation may prolong the remediation time. As discussed, there are technical reasons that limit the application of bioremediation and vapor extraction, but it does appear that the methods can be used more frequently.

The Toxics Management Program staff do not specify the methodology for remediation, the City is charged with reviewing the choices made by the responsible party (tank owners or operators) and their technical/ environmental consultants. It is only on occasion that we reject the method suggested because our experiences prove the method unworkable. The City has always been interested in promoting pilot schemes for bioremediation and we will continue to do so.

It was also suggested that the Community Environmental Advisory Commission may be interested in asking certain questions of environmental consulting /engineering businesses that would encourage them to focus on non-invasive methods of remediation. The staff will supply you with a list of companies that are active in environmental remediation in the East Bay and we suggest the following list of questions:

1. What do you consider to be non-invasive and environmentally acceptable remediation methods?
2. On how many sites are you the lead contractor in such remediation methods?
3. What is this as a percentage of overall sites you administer?
4. What percentage of sites using non-invasive methods have received closure in California and outside California?
5. What are the drawbacks of the non-invasive methods?
6. What are the advantages of the non-invasive methods?
7. What is the main reason why non-invasive technology is not more popular?
8. What can be done to promote applicable non-invasive technology to your prospective clients?

2. Contractor incompetence during tank removal and site remediation.

The staff is again in agreement that there are occasions where risks are taken and jobs are left incomplete. The staff has been pro-active on requiring written site safety plans for any excavated site involving hazardous materials. Jobs have been stopped due to the inadequacy of site safety. However, incomplete or inadequate work is more difficult to control.

The recently reestablished State Tank Funds program (SB 2004) has given the City a greater control of reimbursement of State funds for clean-up programs. If incompetence is witnessed, the City is able to recommend to the State that the job did not meet our standards and that the responsible party should not receive any compensation. The City is also insisting on the presence of State certified geologists and engineers and we will insist in the future that such a professional be present on site if we are not satisfied with the professionalism of the contractor.

Should you require further assistance, please call Denise Barndt at 644-6644 or Nabil AlHadithy at 644-7719.
Weldon' Rucker Acting City Manager

cc: Tamlyn Schafer-Bright, Chairperson, Community Environmental Advisory Commission Denise Barndt, Assistant to the City Manager, Emergency and Toxics Management Program Nabil Al-Hadithy, Hazardous Materials Specialists, Toxics Management Program.

City halts building on toxic site
Neighbors worry about possible health threat
Will Harper, Berkeley Voice, April 27, 1995

A toxic-cleanup system at the site of a former gas station in west Berkeley was removed more than two months ago in violation of a previous city-approved agreement, the Voice has learned.

The city briefly halted construction this week on the Gateway project on the northeast corner of University and San Pablo avenues while Chevron, the former property owner, devised an engineering plan to protect future occupants of the building from underground pollutants.

At the request of Chevron and the developer, the city is allowing construction to continue without an underground water treatment or remediation system. The remediation system and toxic monitoring wells were in the way of the construction, a Chevron official said. Chevron's laboratory tests show the groundwater below the surface of the site is contaminated with the cancer-causing agent benzene, which is found in gasoline. City and Chevron officials say the contamination at the site doesn't pose a health threat to nearby residents and businesses, although an underground toxic plume is being carried off-site by groundwater.

We don't feel it's a significant risk (to suspend remediation during construction) because continued groundwater monitoring has demonstrated the plume is stable," said Mark Miller, the site assessment and remediation engineer for Chevron. Miller said that during construction, the company would continue to remove gas weekly from an off-site underground well near the west end of the property.

In an August 1993 agreement with the city Chevron promised the existing groundwater treatment system would continue to operate until a new, more elaborate groundwater and soil vapor extraction system was installed. It said remediation would continue during construction.

Now, an on-site treatment and monitoring system won't be operational until building is completed, city officials said. Construction of the Gateway project began in February and is expected to end in late September, according to the contractor. Nabil Al-Hadithy, a hazardous materials specialist with the city's toxics management program, said the migration of the plume is "exceedingly slow" and that the plume should not have moved very far by the time construction is completed.

The plume is traveling in a west-northwest direction toward the Wells Fargo Bank across the street. Al-Hadithy said clay and asphalt above the pollutants would help contain them below ground. A Feb. 27, 1995, Chevron report says samples collected from  monitoring wells at the site detected up to 7,600 parts per billion of benzene in the groundwater.

Until 1994, the Maximum legal level of benzene in water was one part per billion- in other words, drinking water standards. But under political pressure, the Regional Water Quality ControlBoard changed that standard where there is no proven use for groundwater, as in this case, Al-Hadithy said. Now, he said, local agencies assess health risks on a case-by-case basis.

What's to worry?: Cityside, Sticks & Stones
EXPRESS August 18, 1995

Sticks & Stones is quite looking forward to the free public program being offered by (UC Extension on October 5 at its Contra Costa Regional Center. 2272 Camino Ramon in San Ramon, titled "What's to Worry About? Toxins in Your Environment."

"Toxins and chemicals all around us-which of them are cause for alarm?" None better to set our minds at ease than Zachary Wong, "toxicologist and a Senior Analyst with Chevron Corporation," who will discuss "real concerns and common misconceptions about environmental poisons."

Perhaps Mr. Wong will address himself to the subject of benzene, a plume of which is migrating from the former Chevron service station (soon to be the hideous new "Gateway" project) on the northeast corner of University and San Pablo in the direction of Strawberry Creek. In February; Chevron reported groundwater concentrations of benzene beneath the site at up to 7,600 parts per billion-or 7,600 times the maximum legal standard for drinking water. Chevron toxicologists, however, convinced the Regional Water Quality Control Board that since no one is drinking the groundwater in the neighborhood, what's to worry'

'There are no residences threatened with impact from the apparently stable plume," concluded the water board, "with the nearest building being a bank." Next door to the Wells Fargo Bank, of course, are the Villa Apartments-whose residents would probably profit by attending Mr. Wong's lecture.

Subject: ARTICLE RE SMELL OF GAS AT STATION SITE
Weldon Rucker, City Manager, May 17, 1995


This site, the former Chevron station at 1101 University Avenue, has been in active remediation since June 1981. To date, 108,201 gallons of water have been pumped out and 2850 cubic yards of soils have been excavated. Significant pollution still exists in the north east portion of San Pablo and University Avenues and on the adjacent corner of the site.

An original agreement between City and Chevron was made to continue clean up (remediation) while construction was on-going. This agreement created a difficulty with the developer and construction crew who claimed that they could not work around wells and pipes. Chevron requested and received permission to remove remediation system and wells from site. All other requirements of the agreement were still active such as designing the new building to house the remediation system. The City determined that the delay of the pumping operation during construction was not going to affect the pollution to any measurable extent.

A Berkeley citizen complained about the removal of remediation system from the site as not meeting the original agreement. The file was reviewed by Toxics staff in view of such changes. It should be understood that the pollution is in the groundwater (over five feet below the ground surface) in concentrations of less than 10 parts per million while the air emissions on a busy city street can be as high as 2 parts per million from vehicular traffic.

In a meeting with responsible parties and property owner, the City Toxics Division and the Regional Water Quality Control Board determined that the pollution on the site was not affecting the residents around the site as the vast majority of the pollution was under the asphalt street, sidewalk and on-site. The City put in new and more restrictive requirements for protecting the health of the future occupants of this site. A building wide barrier and collection system was approved as an additional safeguard. The City required that the previously approved vapor extraction system must undergo testing to prove its effectiveness with an understanding that additional extraction wells may be required if it is found to be inadequate.

The City is also requesting additional sampling to ensure that no residents in the area are being exposed from the groundwater pollution. The responsible party has proven to be very responsive to all requests made so far.

cc: Nabil Al-Hadithy, Hazardous Materials Specialist 11


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