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GROUND ZERO ANALYSIS, INC. <br /> 1714 Main Street <br /> Escalon,California 95320 <br /> Telephone:(209)838-9888 RECEIVED <br /> Facsimile: (209)838-9883 <br /> MAR 15 2011 <br /> March 14, 2011 ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Ms. Kasey Foley <br /> San Joaquin County Environmental Health Department <br /> 600 East Main Street <br /> Stockton, CA 95202 <br /> Subject: Request for Clarification of Closure Status, Underground Storage Tanks <br /> M&L Commodities (former Southwest Hide Facility) <br /> 11651 E. Palm Lane, Manteca, CA <br /> Dear Ms. Foley: <br /> We are writing on behalf of M&L Commodities and Southwest Hide Company to formally <br /> request written clarification of the regulatory status of underground storage tanks (USTs) which <br /> were closed at the site in September 1988. <br /> According to your records, three USTs, two gasoline and one diesel, were properly permitted for <br /> closure, all fees paid, the USTs removed from the site and soil and groundwater samples <br /> collected under the supervision of Mr. Jaime Favala of San Joaquin County Environmental <br /> Health Department (SJ EHD) on September 1, 1988. Following the standard protocol at that <br /> time, analytical results for total petroleum hydrocarbons as gasoline, diesel, kerosene, motor oil; <br /> benzene, toluene, xylenes; organic lead and ethylene dibromide were transmitted directly from <br /> California Water Labs to SJ EHD. All results were non-detect. According to the Site <br /> L^.f rmztion Form ("Four. A") completed by SH EHD staff on October 7, 1988 the staves of the <br /> site as of that date was "Permanently Closed Site". <br /> By letter dated September 29, 1988 Southwest Hide Company requested written correspondence <br /> from SJ EHD verifying that no contamination had been found and that the case was closed. No <br /> record of a response is contained in your files. <br /> Apparently, during a 2004 phone conversation between Mr. Doug Ohland of Southwest Hide and <br /> Ms. Margaret Lagorio of SJ EHD, Mr. Ohland was informed that due to recent changes in the <br /> UST codes/regulations, a closure letter could not be issued until sampling for MTBE had <br /> occurred. Our understanding of the pertinent sections of the Health and Safety Code [particularly <br /> Section 25296(a)(1)] is that a closure letter cannot be issued for a contamination case (i.e., a case <br /> where a responsible party is taking corrective action due to an unauthorized release) absent <br /> testing for MTBE. The dilemma with this site, apparently, is that a contamination case has never <br /> been opened...which is proper given the non-detect results of the sampling. Even if your <br /> G\GROUNDZE\.SWHIDE\UST CORRESPONDENCE\I.etter to EHD 0311.doc <br />