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• <br />May 13, 1991 <br />San Joaquin County <br />Department of Environmental <br />c/o Ms. Pam Violett <br />455 No San Joaquin Street <br />Stockton, Ca 95206 <br />Re: 7 -Eleven store # 14117 <br />2725 Country Club Blvd. <br />Stockton, Ca <br />Dear Ms. Violett: <br />THE <br />SOUTHLAND <br />CORPORATION <br />1 <br />Health <br />• <br />RECEIVEa <br />.: <br />MAY 2 0 1994 <br />ENVIRONMENTAL HEALT1 <br />p�RMITdP.FRVIQES <br />I am writing to you to comment on an unauthorized release re- <br />port recently filed by your office. A copy of the report was <br />received on April 11, 1991. You will recall that we also <br />spoke by telephone on April 26, 1991. <br />The unauthorized release report was apparently filed because <br />of the results of a precision tank test conducted on March <br />28, 1986. I have the following concerns regarding the filing <br />action: <br />The March 280 1986 precision test data indicates <br />that the tank performed at a rate of +4048 jrhich <br />is a passing rate for an underground storage tank. <br />In my discussion with you, it is my understanding that <br />San Joaquin County arbitrarily rounds the test result <br />up or down to the nearest 100th thereby in this case, <br />causing the regular tank to be listed at +.05 which <br />causes this tank to fall into the category of "out of <br />compliance." <br />I have the following comments on what is known thus far: <br />o I don't understand the logic of taking a number <br />which was arrived at by means of good engineering <br />practices and then for the sake of convenience, <br />changing it. <br />o In consideration of the hydrostatic pressure exerted <br />on the tank system during the course of a precision <br />test, I am unable to understand how a +.048 or a +.05 <br />leak rate could be construed as an actual leak. And <br />that an unauthorized release report would be filed <br />requesting that a site assessment be performed. <br />Southl:md Environmental Services ! Location 2957 i 5520 StunUiage Mail Ro.�.l ( wire 510 ! P.O. Box 404 ( Pleasanton, :A 945r3 <br />415.463-2711 1 FAX 415-463- M8 <br />