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r � PUBLIC F?EALTH SERV?LTS ,oRq�1N. SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DMSION Karen Furst, M.D., M.P.H., Health Officer 304 East Weber Avenue, Third Floor - Stockton, CA 95202 209/468-3420 December 15, 1998 VIA FACSIMILE AND U.S. MAIL Ms. Beth S. Dorris, Senior Attorney ARCO Law 444 South Flower Street Los Angeles,CA 90071-1406 Subject: Status of Upgrade Permits for Arco Stations in San Joaquin County Dear Ms. Dorris: The Public Health Services Environmental Health Division (EHD)has received your letter dated December 7, 1998 concerning the status of construction permits for upgrades at Arco Service Stations located in San Joaquin County. The following information outlines the status for the seven plan submittals mentioned in your letter: Initial Plan Plan Returned Plan I Plan Approved For Facility Address Submittal Date With Deficiencies Resubmitted Upgrade Equipment Only 85 E. Louise, Lathrop 10-6-98 N/A N/A 11/24/98* 1711 E. Yosemite, Manteca 8-19-98 9-3-98 10-6-98 11/24/98** 501 W. Kettleman,Lodi 8-19-98 9-3-98 10-6-98 11/24/98** 3212 N.California, Stockton 8-19-98 9-3-98 10-6-98 12/8/98 ** 16 E. Harding, Stockton 8-19-98 9-3-98 10-6-98 12/9/98 ** 6100 N. Hwy 99, Stockton 8-19-98 9-3-98 10-6-98 11/24/98** 2908 Ben Holt, Stockton None N/A N/A N/A * This site will meet 1998 upgrade requirements upon EHD inspection and approval o permitted work. ** Plans approved for the installation of upgrade equipment only. Facilities do not meet December 22, 1998 upgrade requirements concerning structural soundness. The EHD has approved the construction plans submitted by ARCO for the installation of upgrade equipment on six of the seven sites. EHD staff will be accompanying Scott Company personnel to 4 of the sites (85 E. Louise, 1711 E. Yosemite, 501 W. Kettleman,and 6100 N. Highway 99)for construction inspections on December 17, 1998. The Scott Company has not yet scheduled inspections for the two remaining sites for which plans have been submitted. EHD staff are available to conduct these inspections as soon as notified by the Scott Company. The seventh plan referenced for 2908 Benjamin Holt, Stockton, has not been received by this office. Paul Ferreira of Scott Company confirmed that a plan for the Ben Holt site has not been submitted,but will be referred in the near future. As you are aware, even though the six construction plans listed above have been approved for the required upgrade equipment(such as striker plates, pipeline leak detectors, etc.), additional work is still necessary for the five single- walled fiberglass tank sites to meet structural soundness requirements pursuant to Title 23, CCR, Sections 2660 (i)(k) and 2662 (a) and to allow for issuance of Upgrade Compliance Certificates. In EHD correspondence to ARCO dated September 3, 1998 and November 23, 1998, and at the October 28, 1998 meeting with ARCO representatives, it was outlined that the single-walled fiberglass tanks and product piping must be visually inspected A Division of San Joaquin Counry Health Carc Services