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ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> OP C <br /> Unit Supervisors <br /> Q• "?, Donna K.Heran,R.E.H.S. Carl Bergman,R.E.H.S. <br /> 304 East Weber Avenue, Third Floor g <br /> Director Mike Huggins,R.E.H.S.,R.D.I. <br /> •',k> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> F:: - c • Program Manager <br /> gtiFoa�� Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S, <br /> Laurie A.Cotulla,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Program Manager - Mark Barcellos,R.E.H.S. <br /> DAVID M BOYERS ESQ OCT 2 8 2004 <br /> STATE' WATER RESOURCES CONTROL BOARD <br /> OFFICE OF CHIEF COUNSEL <br /> P 0 BOX 100 <br /> SACRAMENTO CA 95812-0100 <br /> RE: Petition of Mabel Keir For Review of San Joaquin County's Identification of <br /> Responsible Parties for Corrective Action at 1601 Turnpike, Stockton, California <br /> This letter is in response to the petition of Mabel Keir for review of San Joaquin County's , <br /> failing and refusing to name Turnpike Associates, a partnership and the partners thereof, <br /> Bill Snyder, Mervyn Totman, and Ralph Smith, as responsible parties with regard to an <br /> underground storage tank release site at 1601 Turnpike in Stockton, California. <br /> In April 1986, Mr. and Mrs. Duncan (Mabel) Keir purchased the above referenced <br /> commercial/industrial property that included an underground storage tank from Turnpike <br /> Associates, a partnership with principals stated above. In October 1987, Mr. and Mrs. <br /> Keir had the tank removed under permit and inspection by the San Joaquin County <br /> Environmental Health Department (EHD). The EHD inspector noted petroleum odor and <br /> discoloration of the soil beneath the tank during the removal. At the time of the tank <br /> removal, soil samples were obtained from beneath the tank and were subsequently <br /> reported as nondetectable for petroleum constituents. However, due to the discrepancy <br /> between the soil sample results and the field observations documented at the time of <br /> tank removal, the site was not considered satisfactorily closed. <br /> In June 1994, the site was placed in the San Joaquin County Local Oversight Program <br /> (LOP). In order to obtain a letter from the EHD stating that no further action was <br /> required regarding the underground storage tank closure, Mr. Keir arranged to have a <br /> soil sample collected from beneath the former tank location and have it analyzed for <br /> gasoline constituents in June of 1996. The analytical results from the soil sample were <br /> negative for petroleum contaminants. Based on that information, a uniform closure letter <br /> (with wording prescribed in California Health and Safety Code Section 25296.10 (g) and <br /> the LOP contract) dated May 23, 1997, was provided to the responsible parties by EHD. <br /> In August 2003, a work plan for a Phase II Site Assessment of this property was <br /> submitted to the EHD by a consultant working on a potential property transfer. The <br /> results of this investigation showed the presence of significant soil and groundwater <br /> contamination. During the consultant's site assessment, it was noted that that soil <br /> sample collected in June 1996 was not obtained from beneath the former tank location <br /> but from a location 10 to 15 feet away. <br />