COMPLIANCE INFO 1987-2006 - Laserfiche WebLink

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f • � � P H O N E 2 8 5 2 4 0 0 CABLE ADDRESS TIMOII. SEATTLE TACOMA PORTLAND STOCKTON RO RICHMOND ' 12 ' N TIME OIL COMPANY R LOS ANGELES 83 E s TS 2737 WEST COMMODORE WAY SEATTLE,WASHINGTON 98199 1233 r P.O. BOX 24447,TERMINAL STATION SEATTLE,WASHINGTON 98124-0447 oaDDucrs Y TIME TESTED f April 24, 1987 L San Joaquin Local Health District r: I � Attn: Jogi Khanna M.D. k'i� ' 6101 E. Hazelton Avenue P.O. Sox 2009 ' ` Stockton, California 95201 ENV{R{IMENTAL HEALTH Dear Dr. Khanna: FERMIT/SERVICES Time Oil has received your billing statement for 1987 for two underground storage tanks at the Time Oil facility located at 3015 Navy Drive, Stockton, California. After reviewing this statement, we have several questions concerning the amount you are asking Time Oil to pay. For the reasons set forth in the remainder of this letter, we believe that no fees are required to be paid at this time. I would appreciate your consideration of the questions raised here so that we can better understand why we are being assessed these fees for 1987 and also to determine whether it would be appropriate for us to file a claim for a refund in the event we are required to pay a portion or all of the permit fees. As we read California law, storage tanks that are in fact sumps are exempted from the statutory definition of "underground storage tank". I refer you to California Hazardous Substance Act, Section 25281 (r)(5). One of the two tanks at the facility was in fact installed and has been continuously used as sump, as required by 40CFR112.7(e)(4)(ii ) . I employee;understand that Mr. William R. Snavely, an emp, y.... of the San Joaquin Local Health District, has inspected our facility and would be able to attest to the fact that one of the two tanks (4,000 gallons capacity) is indeed a sump. This being the case, we are hard to put to understand why we would be required to pay fees for this tank inasmuch as it does not constitute a "underground storage tank". We would appreciate it very much if you or someone from your office could address this question and advise us as to how we are misinterpreting this California statute. The next question has to do with the second underground tank located at the facility (5,000 gallon capacity) . On or about February 7, 1986 this tank (which formerly had also been used as sump) was converted to non-sump use. Accordingly, on February 7, 1986 an underground tank permit was filed by this office with the San Joaquin Local Health District. (copy attached) To date, no permit has been issued for that tank. Consequently, we are unable to determine how a permit fee can be assessed on account of that tank when in fact, no permit has ever been issued. 0244C