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C A M B R 1 A October 12, 2004 Mr Brett Stevens Central Valley Regional Water Quality Control Board 11020 Sun Center Drive##200 Rancho Cordova, California 95670 Re Spill Notification Report Clarification Former Shell Service Station 2575 Country Club Boulevard Stockton, California SAP Code 136144 Incident No 98996184 Dear Mr Stevens Cambria Environmental Technology, Inc (Cambria) prepared this letter on behalf of Equilon Enterprises LLC dba Shell Oil Products US (Shell) in response to the Spill Notification Report— Final tiled by OMI;Thames Water Stockton, Inc (OMI) on August 30, 2004 (Appendix A) We have prepared this document to clarify details presented in OMI's report, expand on some of the details of the spill incident, and present our findings and conclusions In general, the OMI's report describes the spill incident accurately with regard to time,place, and events Specific details of their report that require clarification are discussed below We do not intend to imply that any of the information contained in OMI's report is purposefully erroneous, it dust may be that it is based on preliminary or incomplete information (some of which may have been initially supplied to them by Cambria) The information we present below is based on the findings of our investigation of the spill incident Location The paragraph OMI wrote for this section includes a sentence that states the spilled water " flowed in the storm lane one block north on Plymouth Rd to Oxford Way " This is likely supposition on the part of OMI as it is not clear how much water was spilled and how far it traveled in the storm drain system We learned during the subsequent clean up activities that the storm drain system is designed with very little slope This design essentially encourages storage of water inside the storm drain pipes, and results in very little flow, especially during the dry Cambria season (when the spill occurred) Soon after the spill occurred the storm drain on Plymouth Environmental Road was inspected from the surface and no flow was observed inside the pipes We do not Technology,me believe it is accurate to report that the spilled water flowed through the storm drain as far north Oelkins Street as Oxford Way without evidence that this occurred P 0 Box 259 Sonoma CA 95476 Tel(707)935-4850 fax(707)9356649