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Patrick D. Riddle,Esq. (SBN 56037) <br /> Jennifer A. Coenenberg, Esq. (SBN 264425) <br /> LAW OFFICE OF PATRICK D. RIDDLE, P.C. <br /> 1811 Grand Canal Boulevard, Suite 2 <br /> Stockton, California 95207 <br /> Telephone: (209) 367-6992 <br /> Facsimile: (209) 367-6997 <br /> Email: riddlelaw@patriddlelaw.com <br /> Attorneys for Petitioner <br /> VALLEY PACIFIC PETROLEUM <br /> SERVICES, INC. <br /> CALIFORNIA STATE WATER RESOURCES CONTROL BOARD <br /> In the Matter of the Petition for Review by <br /> VALLEY PACIFIC PETROLEUM DECLARATION OF PATRICK D. <br /> SERVICES, INC., of Technical Reporting RIDDLE IN SUPPORT OF REQUEST <br /> Order No. R5-2011-0800 FOR STAY AND HEARING/PETITION <br /> FOR REVIEW <br /> I, Patrick D. Riddle, the attorney for Petitioner,Valley Pacific Petroleum Services,Inc. <br /> ("VPPS"), declare as follows: <br /> 1. I am an attorney at law licensed to practice in the State of California and, as such, <br /> represent VPPS in this matter. I have been involved with VPPS for approximately 15 years and <br /> therefore have personal knowledge of the facts contained herein. <br /> 2. VPPS does not own the property located at 23100 S. Kasson Road. VPPS leases the <br /> facility from LTH Trust. <br /> 3. The Regional Water Quality Control Board contends that spills occurred in 1998 and <br /> 2008 on VPPS's leased property and that those spills may be responsible for contamination <br /> found in wells on adjacent Chevron Banta Terminal property. The Regional Water Quality <br /> Control Board,by letter dated September 28, 2010, directed VPPS to submit either a report of <br /> investigation or cleanup documenting that the spills have not or no longer pollute groundwater, <br /> or submit a site assessment workplan. <br /> 4. I assisted VPPS in contacting environmental consultants who investigated the incident <br /> and prepared a report dated December 14, 2010. In their report,the consultants concluded that <br /> the 1998 spill was abated and had virtually no chance of impacting groundwater and that <br /> groundwater beneath Petitioner's site was likely contaminated with fuel hydrocarbons originating <br /> at Chevron's site. <br /> 4. I have reviewed the San Joaquin County Environmental Health Department's file <br />