SITE INFORMATION AND CORRESPONDENCE FILE 3

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CAMBRIA holding, and approximately 5,000 gallons of water was generated by cleaning a section of the City of Stockton storm sewer pipe. The water was held in two above-ground storage tanks pending analysis and disposal. Shell ' s Residuals Management Team determined that the water could not be accepted by Shell' s Martinez Refinery, and the City of Stockton decided that the water could not be returned to the storm sewer or sanitary sewer without treatment, nor could it be treated and discharged under the existing wastewater discharge permit. Therefore, Cambria applied for a Special Discharge Permit from the City of Stockton Municipal Utilities District (MUD), to treat the water using the existing GWE system and discharge it to the sanitary sewer. As directed by the City of Stockton, we could not apply for this permit until it was certain that no © additional wastewater would be generated in response to the spill incident. Cambria submitted the special discharge permit application on September 27, 2004. In the meantime, Cambria installed a second float switch in the GWE system transfer tank, and submitted a GWE System Modification Report, dated August 24, 2004. This redundant shutdown mechanism was proposed in Cambria' s 5-Day Incident Report, and the GWE System Modification Report was required by the City of Stockton prior to resuming operation of the GWE system Permission to resume normal operation of the modified GWE system was obtained from Richard Stiffler of the City of Stockton on August 30, 2004. Groundwater extraction from well RW-lA was not resumed at this time, however, because to do so would have posed a serious threat to permit compliance when it came time to process water generated during the spill response. Treating the water from RW-lA for a short period of time would have loaded up the initial carbon vessel with hydrocarbon constituents. Processing the water generated during spill response, which did not contain significant hydrocarbon concentrations, would have likely released the previously adsorbed hydrocarbons into the GWE system midfluent and effluent streams by the process of desorption. Therefore, the system was left off pending proper treatment and disposal of the spill response water, in the interest of maintaining permit compliance. Cambria received the approved Special Discharge Permit from the City of Stockton MUD on October 15, 2004. The spill response water was processed in compliance with the Special Discharge Permit between October 26 and November 1 , 2004, as described in Cambria' s Special Discharge Permit Report, dated November 10, 2004. � Tank Pull and Overexcavation Activities I I Underground storage tank (UST) removal activities were already underway at the site when treatment and disposal of the spill response water was completed. The GWE system was left off 0783 2