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JAN 2 7 1999 <br /> STARSKY & KIRK LLP <br /> ATTORNEYS AT LAW <br /> SUITE 264 <br /> 601 UNIVERSITY AVENUE <br /> SACRAMENTO, CALIFORNIA 95825-6720 <br /> TELEPHONE (916) 567-3960 <br /> TELECOPIER (916) 567-3967 <br /> January 26, 1999 <br /> VIA FACSIMILE (209/468-3433) AND U.S. MAIL <br /> Ms. Donna Heran, REHS, Director <br /> Public Health Services <br /> San Joaquin County Environmental Health Division <br /> 304 East Weber Avenue, Third Floor <br /> Stockton, California 95202 <br /> Re: Former Unocal Service Station 6981 <br /> 4707 Pacific Avenue, Stockton, California <br /> Dear Ms. Heran: <br /> We have been engaged by Unocal Corporation ("Unocal") to assist it in filing a <br /> petition for review with the State Water Resources Control Board ("the State Board"), pursuant <br /> to Health & Safety Code section 25297.1(h), requesting that the State Board set aside San <br /> Joaquin County Environmental Health Division's ("SJCEHD") January 8, 1999 directive to <br /> Unocal requiring it to undertake certain action to define the vertical extent of soil and <br /> groundwater contamination and to evaluate the effectiveness of the vapor extraction system at the <br /> former Unocal service station at 4707 Pacific Avenue, Stockton, California. <br /> As both Unocal and Tosco Marketing Company have repeatedly explained to <br /> SJCEHD, all operating 76 branded service stations in the state of California were acquired by <br /> Tosco Corporation from Union Oil Company of California on March 31, 1997, including the <br /> subject service station. As part of the transaction, the parties entered into an Environmental <br /> Agreement, pursuant to which Tosco has agreed to assume the performance of ongoing <br /> corrective action at the site. Unocal provided a copy of the Environmental Agreement to <br /> SJCEHD some time ago. <br /> Although SJCEHD is aware of Tosco's acquisition of the subject service station, <br /> including its agreement to perform ongoing corrective action at the site, and Unocal has been <br /> informed by Tosco that its environmental engineers have been requested to prepare a work plan <br /> and to initiate the other action discussed in SJCEHD's January 8' directive, Unocal believes that <br />