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December 10, 1996 <br /> Ms. Elizabeth Thayer <br /> Page 2 <br /> s <br /> In discussing this matter Mr. Joseph Henao of the CRWQCB-CVR, he explained that the <br /> Regional Board "policy" is that the applicant would be responsible for all permit fees until <br /> the Regional Board and the County Staff determine that the discharge permit in not <br /> needed, irrespective of the permit expiration date. I asked for a copy of the"policy" <br /> because this approach seems entirely inconsistent with the permit conditions, or any other <br /> NPDES permits obtained by BP elsewhere in California or the United States. Invariably, <br /> the expiration date of an NPDES permit coincides with the termination of authority to <br /> discharge. No fees should be incurred for an expired permit. <br /> By copy of this letter to Ms. Lori Casias, the letter serves to notify the State Water <br /> Resources Control Board that BP desires to appeal a failure of the CRWQCB-CVR to <br /> rescind and cancel NPDES permit 92-023, and for any fees subsequent to the permit <br /> expiration date of January 1, 1997. We request that the State Water Resources Control <br /> Board hold this petition in abeyance while we try Ito resolve this situation informally with <br /> the CRWQCB-CVR and San Joaquin County Environmental Health Department. <br /> Please give me a call if you have any questions, comments or concerns regarding this <br /> matter. I can be reached at (206) 251-0689. <br /> Sincerely, <br /> /Cetoton <br /> Environmental Remediation Management <br /> attachment <br /> cc: State Water Resources Control Board, Division of Clean Water Programs, <br /> Attention Ms. Lori Casias, 2014 "T" Street, Suite 130, P.O. Box 944212, <br /> Sacramento, CA 94244-2120 <br /> Harli ;San Joaquin County Public Health Services, <br /> J.R. Rocco <br /> ' ..F r."� <br />