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6131 Pacific, Stockton Page 2 of 7 This is about as clear as I can make this requirement. The vent lines will need to be tested after the asphalt over them is replaced and a permit will need to be obtained from our office. As far as our office is concerned, the owner doesn't have to pay for the test, Shell can offer to do that or the contractor who apparently didn't follow Shell's protocol (if that is what happened) can do so. ---------------------------------------------------------- Kasey L.Foley,R.E.H.S., Program Coordinator San Joaquin County Environmental Health Department 304 E. Weber Avenue Stockton,CA 95202 (209)468-3451 (209)468-3433 Fax kfoley@sjcehd.com -----Original Message----- From: denis.1.brown@shell.com [ma ilto:den is.1.brown @shell.com] Sent: Wednesday, December 06, 2006 4:34 PM To: Kasey Foley [EH] Cc: Margaret Lagorio [EH]; Raymond von Flue [EH]; kahemmen@sbcglobal.net; dlescure@cambria- env.com Subject: RE: 6131 Pacific, Stockton Thanks again for response. As you're indicating, it appears that only the vent lines were exposed. We do not have any reason to believe we impacted or compromised any of the UST system by the work completed. However, you're indicating that since the vent lines were exposed, a pressure test needs to be completed. While the initial indication was that the UST system needed to be tested, then perhaps this would be better news for the owner. In your first paragraph you are still indicating that "potentially", if anyone installs a remediation system, or performs work near a UST or lines, the UST system will need to be tested, depending upon your interpretation of work performed. Leastwise, you are indicating that potentially "Unit Ill's" testing requirements need to be complied with. I am not disagreeing with the ability to enforce UST regulations, nor that your Dept. must ensure UST system integrity, however, I am unclear what determines the need to have this test performed if we, or any other company performs, work such as saw cutting, drilling, or just trenching only near UST or UST lines. Your still indicating that even though you don't know anything was impacted, you may still require UST system or line testing. This is not a cheap proposition for owner or operator. Nor is it clear what criteria should we be aware of in order not to have a UST test performed after completing some work "near" the lines or USTs. 1. Our policy is that we do not perform any work where there is pea gravel. 2. Any work is usually at least 10' from the system or even 10' from around any canopy on site. We have stated policies/procedures to all of our contractors regarding work around station and station systems. 7/11/2007