SITE INFORMATION AND CORRESPONDENCE

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• EQ SIVA SERVICES LLC November 30, 2001 VIA EMAIL AND RI✓GULM U.S. MAIL Ms. Margaret Lagorio San Joaquin County Public Health Services Environmental Health Division 304 E. Weber Avenue, Third Floor Stockton, California 95202 Re: Shell-branded Service Station 3011 West Benjamin Holt Drive Stockton,California Dear Ms. Lagorio: I received your November 8, 2001 email(copy attached)regarding the above-referenced site and the pending Problem Assessment Report(PAR). I have reviewed your email with my consultant (Cambria Environmental Technology, Inc.)and have the following comments. The Tri-Regional Guidelines state that investigation reports are to be submitted to the Local Implementing Agency(LIA)for review,comment, and approval. Most of the regulators with whom we work do provide review, comment, and approval of reports we issue. We submit investigation reports and the LLA reviews them and writes letters back acknowledging their receipt. These letters also typically include comments regarding the regulator's review of the report and recommendations or requirements for additional assessment or other work at the site. We have found this to be standard practice among regulators across the State. However,we learned during our June 19,2001 meeting with San Joaquin County Public Health Services Environmental Health Division (PHS/EHD)that Mike Infurna does not necessarily operate in this manner. During the meeting Mike indicated he expects the consultant to continue investigating sites without his input and provide a PAR when they think they have finished their assessment. Mike's method of managing sites differs from the way most other regulators in the State manage sites, including other PHS/EHD regulators. This method is also not consistent with the Tri-Regional Guidelines. But since learning how Mike expects us to proceed we have progressed expediently with investigation activities at the subject site without his input. The recent events and dates associated with those activities are mentioned in your email (paragraph 4). And the documented timeline demonstrates our willingness to continue assessment at the subject site in an expeditious manner. As it currently stands, however,additional assessment is still needed at this site;the field work for which is scheduled for December 10-14,2001. Therefore, adequate assessment may not be completed prior to the December 7,2001 due date Mike has uncharacteristically and inappropriately specified for the PAR.