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No-we <br /> � t`oducts Company <br /> e t . 6 Environmental Claims Management <br /> IA ` P O Box 2099 <br /> •/ Houston TX 77252 <br /> Thomas F.Maher <br /> SEPTEMBER 9, 1996 Tel: (713)241-0434 <br /> Fax: (713)241-5044 <br /> Mr. Michael Infurna, Senior REHS <br /> LOP/Site Investigation Unit <br /> Environmental Health Division <br /> Public Health Services <br /> San Joaquin County <br /> Post Office Box 388 <br /> Stockton, CA 95201-0388 <br /> Re: Former Shell Station Located at 1267 Country Club Boulevard, Stockton <br /> Dear Mr. Infurna: <br /> Your letter on this subject to our Mary Ellen Tucker dated July 25, 1996, requested <br /> that the Shell Oil Company (Shell) submit a work plan that addresses verification of <br /> underground tank removal and characterization of the extent of the soil and ground <br /> water plumes still in place. You based your request on the April, 1995, subsurface <br /> investigation of the property performed by Geosystem Consultants, Inc. <br /> (Geosystem). I have reviewed the Phase I and Phase II Environmental Site <br /> Assessment prepared by Geosystem that contained the results of the April 1995 <br /> subsurface investigation and I ask that you withdraw your request for the reasons <br /> given below. <br /> TANK REMOVAL VERIFICATION <br /> Shell owned only one underground tank at this site, an 8,000-gallon tank installed in <br /> 1970. The remaining tanks were the property of the owner of the site and were <br /> utilized by Shell under our leasehold interest in the property. The Geosystem site <br /> assessment indicates that permit for the removal of the tank was issued in 1974. <br /> Moreover, Figure 2 of the site assessment indicates that the 8,000-gallon tank <br /> would have interfered with the foundation of the present structure if it remained on <br /> the premises. Figure 2 likewise indicates that at least two of the other tanks would <br /> have interfered with that foundation. Finally, Page 3-3 of the site assessment states <br /> that Bank of the West indicated that a purchase agreement clause required that the <br /> any tanks be removed prior to their occupancy. In view of the foregoing, any further <br /> verification of the tank removal would either be redundant or the responsibility of the <br /> present owner. Therefore, it would not be appropriate for Shell to address this <br /> issue in any required work plan. <br /> J:\MKTGENG\ENVCLAIM\MAHER\RE371LTR.000 <br />