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Investigator: Barbara Anderson,Law Advisor Business Address: City of Stockton Attorney's Office 425 North El Dorado Street Stockton, CA 95202 Business Phone: (209)937-8333 IV. ALLEGED VIOLATIONS 25284 California Health&Safety Code(H&SC): Manuben Patel has not registered the Underground Storage Tank at the Cunningham Hotel,620 East Market Street in Stockton, with the San Joaquin County Environmental Health Division(the local implementing agency). 25285 H&SC : Manuben Patel has not paid tank registration fees,penalties,and surcharges to register the UST located at the Cunningham Hotel. 25292(d)H&SC: Manuben Patel has not complied with the December 22, 1998 upgrade compliance date for the UST. A routine inspection performed February 25, 1999 documented the UST was still in place with a black,oily substance remaining in the fill tube. 25293 H&SC: Manuben Patel,owner of the Cunningham Hotel,has not monitored the UST for unauthorized releases. 25298 H&SC: Manuben Patel,owner of the Cunningham Hotel,has illegally abandoned the UST at 620 East Market Street in Stockton. V. SITE HISTORY March 17,1997 A meeting was held at the Environmental Health Division,304 East Weber Avenue,Stockton to discuss the site assessment findings and three(3)USTs discovered in the 600 Block of East Market Street. Present at the meeting were Bob Seville and Barbara Anderson,City of Stockton;the Attorney for the Stockton Record,Kama E.Harrigfeld of Neumiller&Beardslee; and EHD representatives Margaret Lagorio, Steve Sasson,and Letitia Briggs. March 18,1997 Letitia Briggs generated complaint#COOO7881 for the improperly abandoned UST in front of the Cunningham Hotel. Briggs also completed A&B forms and billing for this site. April 11, 1997 Letitia Briggs performed complaint inspection to verify the location of the UST. After speaking with the hotel manager Sanjay Patel about the UST,Briggs went outside in front of the hotel. Briggs found a small metal plate covering a fill tube opening in the sidewalk. About 4 feet down inside the fill tube,Briggs observed a dark liquid with a slight petroleum odor. Briggs photographed the fill tube and liquid inside of the tube. April 16, 1997 Briggs completed the Notice to Abate with UST information,mailed it return receipt requested, started an UST file, and abated the complaint. April 23,1997 Briggs performed a second inspection with Sanjay Patel. Briggs photographed the heating room located in the rear of the Hotel and garage. The garage was once used for automotive repair and has an entrance on E. Market Street. 3