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PUBL <br /> � HEALTH SER �- ICES QPqu�N,•� V <br /> SA]OAQUIN COUNTY a <br /> ]OGI KHANNA M.D.•M.P.H. <br /> Health Officer <br /> P.O. Box 2009 (16o1 East fLuelton Avenue) •Stockton,California 95201 <br /> (209) 468-34 <br /> cc_ <br /> � 4 <br /> BJJ COMPANY INC <br /> P o BOX 30010 MAY 0 1 1992 . <br /> STOCKTON CA 95213-0010 <br /> RE: 6700 W. Grant Line Rd ;;SWRCB USI'CLEANUP FUND PROGRAM CLAIMANT#:378 <br /> Tracy, Ca <br /> SITE #1410 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has not issued - <br /> the above listed site a permit although the site has been in compliance with requirements to own or j <br /> operate the tank(s). <br /> Section 2712 (d) of the 1985 Underground Tank regulations (California Administrative Code,-Title 23, <br /> Chapter 3, Subchapter 16) stated that "the local agency shall not issue a permit to operate an <br /> underground storage tank" until the local agency had inspected the facility and determined that the <br /> tank(s) complied with the regulations. Our interpretation of the statute implied that underground } <br /> storage tank sites lacking a local agency site inspection or sites with soil or groundwater contamination <br /> could not be'issued operating permits until the following was achieved: 1) a site inspection evaluation; u1 <br /> 2) verification of appropriate monitoring method; 3) adequate and appropriate inventory reconciliation <br /> records; and/or 4) complete investigation and cleanup of the contaminated site. , } <br /> Due to this interpretation of the law, this site, as well as many others, was not issued a permit. <br /> However, it is our determination that this facility was operating in compliance with the regulations and <br /> should be considered for state funding. <br /> With the addition of Sections 2653 and 2654;to the 1991 Underground Storage Tank Regulations, <br /> PHS/EHD has the authority to require investigation and cleanup of contaminated sites, therefore, permits , <br /> will no longer be withheld. , <br /> h <br /> If you have any questions please contact Harlin Knoll, Senior REHS, at (209) 468-3442. <br /> Jogi Manna, M.D., M.P.H. <br /> Health Office <br /> ` • ii <br /> r g <br /> K <br /> Heran, REHS, Program Manager <br /> nmental Health Division <br /> DH/HK:Ib <br /> A Division of San Joaquin County Health Care Services <br /> 0, ' <br /> n <br />