SITE INFORMATION AND CORRESPONDENCE

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Ms. Kitty Walker • - 2 - • 14 October 2003 ti • 3 August 1982 letterfromthe Stockton RDA leasing the property back to L&M Petroleum; and • 2 November 1982 letter from the Stockton RDA denying L&M Petroleum's request for an extension of the lease term beyond 31 January 1983 and stating the RDA's intention to have a demolition contractor on site by early February 1983. The information provided in these documents shows that the Stockton RDA purchased Parcel 2A in 1982 and leased the property to L&M Petroleum for"use as a petroleum distribution facility," as stated in the lease agreement. Based on the 2 November 1982 letter, the Stockton RDA hired a demolition contractor to dismantle the petroleum distribution facility once L&M Petroleum operations ended in January 1983. As an owner of the property and former lessor to L&M Petroleum, the Stockton RDA had knowledge of the petroleum pollution and the ability to control the migration of pollution. The State Water Resources Control Board and the Regional Board have long taken the position that current owners with knowledge of and the ability to control the pollution on their property are responsible for cleanup and abatement of the pollution. For this reason, the Regional Board considers the Stockton RDA to be a Discharger and RP for the pollution at Parcel 2A, along with the other RPs. The Regional Board requests the Stockton RDA to submit any technical information it may have regarding its activities, including information related to the dismantling of the L&M Petroleum facilities. Information and data about this dismantling could aid in interpreting current investigation results and reviewing remediation proposals. In particular, information needed includes whether tank bottoms, pipelines, or other artifacts were left in place, any soil data obtained after the dismantling, and any test results on fill material used to backfill excavations (this material may have contained metals which are now being found in soil samples). Please submit this information by 10 November 2003. If you have any questions, you may contact Devra Lewis at (916) 255-3119. WENDY L. COHEN, P.E. Chief, Private Sites Cleanup Unit Enclosure cc: Mr. Steve Becker, Department of Toxic Substances Control, Sacramento Mr. Jeffrey Wong, San Joaquin County Public Health Services, Stockton Mr. Robert Cochran, Chevron Environmental Management Company, San Ramon Mr. Tracy Sizemore, ConocoPhillips, Tempe, AZ Mr. Robert Goodman,Law Office of Robert C. Goodman, San Francisco Mr. Sean Sherlock, Snell &Wilmer,Irvine Mr. William Brown, Esq., Daley&Heft, Solana Beach