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4� m PUBLIC YIEALTH SERVICES SAN JOAQUIN COUNTYrs ENVIRONMENTAL TAL HEALTH DIVISION 9� Wiest NL Fuji oto,M. D., M.P.H., Acting Health Officer � .. 364 F. Weber Ave,,Third rd Floor P. 0. Bax 388 Stockton, CA 95201-0388 2019/4+ 8-842 = x From the P_eskof Mary eav Senior�H5 To Lori Casias Date: September 25, 1996 a Su ect Spanos Petition regarding 5000 South Airport, Stockton CA Lori, I reviewed the memorandum dated September 23, 1996 from Dorothy Jones, Office of € Chief Counsel whichindicated that it was her opinion that insufficient evidence was available for her review to identify A.C. Spanos as a responsible party. As introduction, I have summarized the process used by San Joaquin County Public Health Services, Environmental health Division (PHS/ HD) for identifying responsible parties, To initiate the process, there must be some indication that there may have been a release of petroleum hydrocarbon contamination into the environment as a result of the operation of an underground storage tank. The indication of a of petroleum hydrocarbon contamination is documented with Unauthorized Release Reports (UARs) which are filed with the State Water Resources Control Board and Central Valley regional Water Quality Control Board The two mainreasons used to confirm that a release has occurred include. €bs rvations at the time of tank removal and review of analytical results from soil or groundwater that were collected beneath or in the vicinity of a tank prier to or following tare removal. Once a release has been confirmed the site is eligible for placement into the Local Oversight Program. Responsible parties are thea identified. PHS/ H 3 uses the definitions of responsible parties found in the Underground Storage Tank Regulations (Title 23 California Code of Regulations) and in the Local Oversight Program contract with the State Water Resources Control Board: PHS/EHE placed this site into the Local Oversight Program based primarily on analytical results which were obtained following the removal of underground storage tanks that were located in the formertank farm.' PHS/I HC? identified the various responsible parties bawl on property ownership and tank;operations. PHS/ HD assumes that the analytical results which were obtained from samples collected directly beneath-the four underground storage tanks, 1845-01 _ 1845-04,operatedby A.G. Spanos, were insufficient to demonstrate to the Office of {chief Counsel, that a release from the tanks occurred during or prior to the time that A.G. Spanos was in operation of the tams, because multiple tanks were located in the fanner tank farm A t�ivison r�#Sayoaquirti CourtCy Health Sergi