SITE INFORMATION AND CORRESPONDENCE

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PUBLIC HEAL'T'H SERVICES aa¢�FA SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION Karen Furst, M.D., M.P.H., Health Officer 304 East Weber Avenue,Third Floor • Stockton, CA 95202 'cj oka 209/468-3420 KAREN PETRYNA EQUIVA SERVICES LLC DEC 2 0 2001 P 0 BOX 7869 BURBANK CA 91510-7869 RE: Shell 3011 W. Benjamin Holt Drive Stockton, CA San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has reviewed your letter dated November 30, 2001, and provides the following response. California Code of Regulations (CCR) Section 2652 requires that owners or operators of sites where an unauthorized release from an underground storage tank has occurred submit reports at least every three months to the agency providing oversight of the corrective action until the investigation and cleanup are complete. The reports are to include an update on implemented actions, proposed actions, and a time schedule for implementing proposed actions. CCR Section 2722 (e) states that"in the interest of minimizing environmental contamination and promoting prompt cleanup, the responsible party may begin implementation of the proposed actions after the workplan has been submitted and before it has received agency concurrence. Implementation of the workplan may begin sixty (60) calendar days after submittal, unless the responsible party is otherwise directed in writing by the regulatory agency'. Before beginning the work the regulatory agency must be notified of the intent to initiate the work and the responsible party must comply with any conditions of the regulatory agency. These sections of the law clearly indicate that the responsible parties are to move forward with their investigations and provide time schedules that show there is a plan for completing site investigation and remediation. Also the law gives the responsible party the authority to proceed with proposals after 60 days if the regulatory agency does not comment. PHS/EHD staff routinely review and comment on reports and approve work plans. There are times when PHS/EHD staff shortages have caused a lapse in providing comments on reports or approval of plans. It is the responsible partys duty to notify our agency that they want to proceed with work and/or request comments. Equiva did proceed with initiation of the Corrective Action Plan (CAP) dated February 13, 1998, for 2575 Country Club, Stockton, without PHS/EHD comment as they are permitted to do by the law. It was prudent that Equiva proceed with this plan since there were drinking water wells in the area that may have become impacted if they didn't proceed. The text of that CAP states that the plan is interim and PHS/EHD may still require a final CAP. A Division of San Joaquin County Health Cam Services