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NOVO OIL <br /> t tMJ&NV 1221 East Main Street Chattanooga, TN 37408-1696 <br /> (615)756-5770 <br /> RgCr6aT= <br /> 40 <br /> August 21, 1985 SEP 4 '19H5 <br /> CERTIFIED MAIL ENVIROMENTAL HEALTH <br /> RETURN RECEIPT REQUESTED PERMIT/W"CES <br /> Mr. William S. Johnson <br /> Assistant Executive Officer <br /> Central Valley Region <br /> Dcgic all nater Q:::lity Control Board <br /> 3201 S Street <br /> Sacramento, CA 95816-7090 <br /> RE: Site Assessment Plans For Douglas Oil Company Stations - <br /> Lodi; Stockton; Jackson, California <br /> Dear Mr. Johnson: <br /> In response to your letter of August 14, 1985, Douglas/Kayo Oil Company <br /> respects your position regarding the California Water Code and the Health and <br /> Safety Code. In addition, we agree with the spirit and the intent with which <br /> your letter was written. The meeting held in Stockton, California on Thursday, <br /> August 15, 1985, addressed many of the requests listed in your August 14 <br /> letter. A list of those attending the meeting is enclosed for your information. <br /> Douglas/Kayo's policy and position regarding environmental affairs states in <br /> part, ". . .to comply with all environmental laws and regulations related to <br /> environmental quality," and ". ..to maintain contingency plans to cleanup <br /> discharges of gasoline or other materials caused by the Company." Furthermore, <br /> the purpose of the initial investigation was to ensure environmentally sound <br /> stations would be transferred to the new owner. Our Company has been prepared <br /> to respond to the conditions found at each site and it is in that spirit that <br /> we intend to expedite the resolutions to the problems found. <br /> Each of your six requests are discussed below and our responses to those <br /> requests are also given. <br /> 1. Douglas-/Kayo believes the intent of the Regional Board is to have <br /> the groundwater conditions monitored on a specific schedule at each <br /> site and have the free product bailed from those monitoring wells <br /> where it has accumulated. Monitoring all on-site monitoring wells <br /> is technically unsound in that, several of the first wells installed <br /> do not encounter groundwater. A thorough assessment cannot be made <br /> of the subsurface condition at those monitoring well sites. <br />