SITE INFORMATION AND CORRESPONDENCE

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PUBLIC HEALTH SERVICES SAN JOAQUIN COUNTY ?- ENVIRONMENTAL HEALTH DIVISION Ernest M. Fujimoto, M. D., M.P.H., Acting Health Officer 304 E. Weber Ave., Third Floor • P. O. Box 388 • Stockton, CA 95 1-0 8 209/468-3420 OCT 11 1996 T F MAHER SENIOR MANAGER SHELL OIL PRODUCTS COMPANY PO BOX 2099 HOUSTON TX 77252 RE: SHELL STATION (former) SITE CODE: PR#505602 1265-1267 Country Club Blvd. Stockton, CA 95204 San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) has reviewed your correspondence dated September 9, 1996 and has the following comments. Historical records indicate that SHELL service station operations started in 1949 at 1265 Country Club Boulevard. In 1956, City of Stockton records indicate that four underground tanks (UGT) existed at this single parcel and that Shell Oil Company was operating the facility. On July 8. 1970 a permit was issued to Shell Oil company to install a single 8,000 gallon UGT. In March 1974, a permit was issued to remove the 8,000 gallon UGT. Central Bank began leasing the site in 1976 and built the current building that remains on site today. It is currently the position of PHS-EHD that SHELL operated the four existing UGTs from 1949 thru 1970, then added the 8,000 gallon UGT, and continued to operate the service station until 1976. If you have any information that states otherwise, please submit it to me immediately. Please submit a site plan that shows the layout of the station, including the UGT locations, the piping, and the dispenser islands. PHS-EHD is unclear on some previous events that occurred at the site. Who installed the "existing" four UGTs referenced in the Phase I report? Were these UGTs installed by someone other than SHELL? Was the permit issued by Stockton City Fire Department in March, 1974 for the removal of only the 8,000 gallon UGT or was it also used as the permit to remove the other"existing" four UGTs? As the last and only known operator of the underground tanks (UGT) located on this site. your company qualifies as the primary responsible party for the required investigation directed by PHS-EHD in correspondence dated July 25, 1996. Until you provide information that SHELL was not the last operator of the UGTs before discontinuation of their use, SHELL will remain responsible for the required investigation. PHS-EHD advised that an investigation should be conducted to determine the extent of soil and groundwater contamination and that a diligent effort should be made to verify the UGT removals so that the conclusions you reached that off-site sources were impacting your site could be supported. Until the status of these UGTs (including piping) are verified, PHS-EHD cannot eliminate the possibility that they are still present and contributing to the elevated levels of petroleum still present at the site. Soil and groundwater grab samples from B-1 and B-2 indicate that petroleum constituents are present. Total Petroleum Hydrocarbons as Gasoline (TPH-G) in the soil at B-2 are at 1,900 mg/kg at 31 feet below ground surface (bgs) and at 1,700 mg/kg in B-1 at 16 feet bgs. Both of these borings were located at either side (east and west) of three of the four UGTs known to exist on site. A Division of San Joaquin County Health Care Services