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Shell Oil Company (D�l <br /> P.O.Box 4848 <br /> 511 N.Brookhurst Street <br /> Anaheim,California 92803 <br /> October 15, 1991 <br /> O C Y 1 8 ""l <br /> DOWNEY, BRAND, SEYMOUR & ROHWER ENVIRONMENTAL HEALTH <br /> Attn: Steven H. Goldberg, Esquire PERMIT/SERVICES <br /> 555 Capitol Mall, 10th Floor <br /> Sacramento, Ca 95814-4686 <br /> Re: 1766 Mt. Diablo Ave <br /> Stockton, Ca <br /> Dear Mr. Goldberg: <br /> We are in receipt of a letter, dated September 24, 1991, from your <br /> client, Russell F. Chapin, regarding certain matters at the service <br /> station site currently owned and operated as Chapin Brothers Shell. <br /> In order to properly focus on those issues needed to allow the <br /> Chapins to comply with the September 9, 1991 directive from Pam Violett, <br /> of the San Joaquin County Public Health Services, we felt we should <br /> offer the following observations. <br /> 1. The August 6, 1991 letter from Public Health Services notified <br /> Shell that we were being named as an additional responsible party for <br /> the subject site. The specific language dealt with reimbursing the <br /> agency for "oversight of assessment and clean up activities". There is <br /> nothing in the letter to direct us to remove the underground storage <br /> tanks. <br /> 2. The September 9, 1991 letter from Public Health Services, cites the <br /> Chapins for "improper abandonment" of the underground storage tanks. <br /> Specific reference was made to the fact that there was "no quantitative <br /> release monitoring occurring at this time (e.g. precision test for 1991, <br /> inventory reconciliation, manual tank gauging, etc. )". These are all <br /> matters pertaining to the present operation of the underground storage <br /> tanks. As such, it is a matter of compliance to be met by the Chapins. <br /> 3. The Chapins have owned and operated the tanks for the past 18 plus <br /> years. Based upon long-standing Shell policy, we do not pay for the <br /> removal of underground storage tanks that are used past our tenure. <br /> Since the Chapins enjoyed beneficial use of these tanks for 18 plus <br /> years, it is for their account to excavate the tanks and to file the <br /> required tank closure report. <br /> 4. Once they have filed the tank closure report, we would request that <br /> three copies be provided for review by our staff. After review, our <br /> staff will make a recommendation as to the most reasonable course of <br /> LT113003 <br />