SITE INFORMATION AND CORRESPONDENCE FILE 3

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Mike Infurna [EH] From : Margaret Lagorio [EH] Sent : Thursday, April 15, 2004 8: 14 AM j To : Mike Infurna [EH] Subject: FW: Shell, 2575 Country Club Blvd , Stockton FYI - - - - - Original Message - -- -- From : Brian Newman [mailto : NewmanB@rb5s . swrcb . ca . gov] Sent : Thursday , April 15 , 2004 7 : 55 AM To : Jim Barton ; Margaret Lagorio [ EH ] Subject : RE : Shell , 2575 Country Club Blvd , Stockton The issue is if the discharge is to a facility/ system that is. already under permit . In this case the discharge from the City sewer is regulated by a permit so the dischargers to the city system ( i . e . Shell ) are already covered ( at least as far as we are concerned ) and it then falls into the City ' s pre -treatment program . Here , the City set pre- treatment requirements that Shell won ' t / can ' t meet . That is an issue between Shell and the City . Only if Shell can establish an otherwise unregulated discharge would they get their own permit . In this case it seems all the logical receptors for the waste water are already under permit , ergo Shell must meet pre-treatment requirements . However , just because they have discharge limits that they won ' t / can ' t meet does not excuse them from remediating the site . Using Shell ' s logic they would stop remediation if they don ' t like the limits in any permit . I think they should just be told to upgrade their system , but , like everything else we do that ' s going to take extra time and effort . more fun with dischargers Brian >>> Jim Barton 04 / 15 / 04 06 : 10AM >>> Margaret , we received the two reports on the same dates , but did not receive the City ' s letter to Shell . Since the discharge is to City of Stockton and not to a ditch or other surface water body , Brian informed me that we will not issue an NPDES permit . I will follow up with our NPDES section to see if Shell has submitted a Report of Waste Discharge for a permit . Thanks for your inquiry . Jim >>> "Margaret Lagorio [ EH ] " <MLagorio@sjcehd . com> 04 / 14 /04 04 : 27PM >>> It appears that we were copied on a letter to City of Stockton in December 2003 , that stated because they could not meet newly initiated non detect discharge requirements they shut down their groundwater extraction system on October 14 , 2003 . In the Fourth Quarter 2003 report we got in March 2004 and the First Quarter 2004 report we received April 12 , 2004 , they discuss making design changes in the Remediation section and then discuss application for an NPDES permit in the Anticipated Activities section . What makes Shell think they can do this ? They know it will take time for us to force them into turning the system back on . The only place to discharge to besides the sewer is the storm drain system which is also the responsibility of the City of Stockton , although the county does have some storm drains in the area . We will respond to. them . Check out the quarterly reports if you have time . - - - - -Original Message ---- - From : Brian Newman [ mailto : NeW anB@rb5s . swrcb . ca . gov ] Sent : Wednesday , April 14 , 2004 1 : 31 PM To : Jim Barton Cc : Margaret Lagorio [ EH ] Subject : Re : Shell , 2575 Country Club Blvd , Stockton 1