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RECEIVED <br /> C A M B RIA <br /> JUL 092004 <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES July 7, 2004 <br /> Mr. Mike Infurna <br /> San Joaquin County Environmental Health Department <br /> 304 East Weber Avenue, Third Floor <br /> Stockton, California 95202 <br /> Re: Groundwater Extraction System Status Response Letter <br /> Shell-branded Service Station <br /> 2575 Country Club Boulevard <br /> Stockton, California <br /> © SAP Code <br /> Incident No., 9899 98996184 <br /> SJCPHS Site 1071 <br /> Dear Mr. Infurna: <br /> Cambria Environmental Technology, Inc. (Cambria) prepared this letter on behalf of Equilon <br /> Enterprises LLC dba Shell Oil Products US (Shell) in response to the April 19, 2004 letter from <br /> the San Joaquin County Environmental Health Department (SJCEHD) regarding shutdown of the <br /> groundwater extraction (GWE) system at the referenced site. <br /> Oxygenate Discharge to Sanitary Sewer <br /> The SJCEHD April 19, 2004 letter discusses a claim by the City of Stockton Municipal Utilities <br /> District (MUD) that we did not inform MUD staff that discharge from our GWE system might <br /> contain fuel oxygenates. This claim is incorrect. Our first discharge permit application included <br /> laboratory analytical data for an influent sample that was analyzed for fuel oxygenates. A <br /> detailed history of the various discharge permits issued by MUD is presented below. <br /> Shell initially applied for a discharge permit from the MUD on October 13, 2000. Prior to <br /> applying for this permit Cambria had contacted MUD to determine the constituents of concern <br /> (COC) for a discharge permit from a service station GWE system. We were informed that the <br /> list of the COC included total petroleum hydrocarbons (TPH), benzene, toluene, ethylbenzene, <br /> and xylenes (BTEX) along with some other non fuel related analyses (metals, pH, etc.). At that <br /> time, MUD was not concerned with methyl tertiary butyl ether (MTBE) or the other fuel <br /> oxygenates. The discharge permit application we submitted included groundwater analytical <br /> results for an influent sample collected from our extraction well. The laboratory analysis for this <br /> Cambria <br /> Environmental sample included total petroleum hydrocarbons as gasoline (TPHg), BTEX, and fuel oxygenates <br /> Technology, Inc. (MTBE, diisopropyl ether, tertiary amyl methyl ether, ethyl tertiary butyl ether, tertiary butyl <br /> alcohol [TBA]). MUD issued a discharge permit for our GWE system on October 23, 2000. <br /> 270 Perkins Street <br /> P.O. Box 259 <br /> Sonoma, CA 95476 <br /> Tel (707) 935-4850 <br /> Fax (707) 935-6649 <br />