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• PHONE 285-2400 <br /> CABLE ADDRESS: TIMOIL <br /> TACOMATTLE A TEN (FAX) 206-283-8036 <br /> PORTLAND <br /> STOCKTON I2RENO I T° <br /> RICHMOND 2 ° <br /> LSANGS q E TIME O I L C O . <br /> LOS ANGELES 9�3 RECEIVED <br /> N <br /> 7 6 5 TE M <br /> 2737 WEST COMMODORE WAY SEATTLE,WA 98199 <br /> PRODUCTS TQM P.O. sox 24447 SEATTLE, <br /> TESTE MI <br /> ENTAL HEALTH <br /> PERMIT/SERVICES <br /> July 15, 1991 <br /> San Joaquin Health Dept. <br /> Attn: Doug Wilson <br /> 1601 E. Hazelton Ave. <br /> Stockton, CA 95205 <br /> Dear Mr. Wilson: <br /> As you know, Time oil Co. owns and operates a bulk storage terminal at <br /> 3015 Navy Dr. , Stockton, California. On 6/10/91 a notice of violation <br /> was prepared by Pam Violett pertaining to the underground SPCC sump. <br /> Based on our conversation of 7/12/91, it has become apparent that the <br /> San Joaquin Health Department intends to classify this sump as an <br /> underground tank in spite of federal and state interpretations to the <br /> contrary. To this end, Time oil Co. would like to petition the Health <br /> Department for an extension of time to implement a change in either <br /> the design of or monitoring procedures for this sump. <br /> This sump serves two functions. It is part of the spill response <br /> contingency plan required by 40 CFR 112 in the event of an unexpected <br /> release at the loading rack. It also serves as a runoff collection <br /> point for storm water control. Whenever liquid of any kind enters the <br /> sump it is immediately pumped out to the oil water separator. <br /> Because of its' design and construction, it does not appear possible <br /> to incorporate the provisions of alternatives 1, 5, 6, 7, and 8 of the <br /> California underground storage tank regulations. Also, because of <br /> pre-existing contamination at this facility, alternatives 2 , 3 and 4 <br /> are not feasible monitoring options. <br /> Therefore, due to the uniqueness of San Joaquin County's <br /> interpretation of the rules and because alternatives do not exist in <br /> the federal or state regulations to accommodate this site, Time Oil <br /> Co. is in need of information from the Health Department on <br /> appropriate methods and technologies for leak detection for tanks of <br /> this nature. Please advise us at your earliest convenience so that we <br /> may begin leak detection immediately. <br /> Thank you for your help in this matter. <br /> Si rely, <br /> J. Mel Paisley <br /> UST Specialist <br /> C:\WP51\MIKE\CORRESP.91\STOCKTN.SMP <br />