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PUBLIC AEALTH SERN-iCES <br /> SAN JOAQUIN COUNTY m ?� <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> 445 N. San Joaquin Street • P.O. Box 388 • Stockton, CA 95201-0388 tiFoA <br /> (209) 468-3420 <br /> CITY OF STOCKTON (C O nMAR 2 8 1994 <br /> 425 N EL DORADO �' u <br /> STOCKTON CA 95202 <br /> RE: City of Stockton Sites <br /> 1116 E. First Street, 6803 Alexandria Place, <br /> 1701 W. Washington Street, 550 E. Harding Way <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has not issued <br /> the above listed sites permits although the sites were in compliance with requirements to own or operate <br /> 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 /> tanks) 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; <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, these sites, as well as many others, were not issued permits. <br /> However, it is our determination that these facilities were operating in compliance with the regulations <br /> and 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 /> If you have any questions please contact Margaret Lagorio of my staff at (209) 468-3449. <br /> Ernest M. Fujimoto, M.D., M.P.H. <br /> Acting Health Officer <br /> Diane M. Hinson, Supervising R.E.H.S. <br /> Environmental Health Division <br /> DMH/ml <br /> A Division of San Joaquin County Health Care Service <br />