COMPLIANCE INFO_2010 REPAIR - Laserfiche WebLink

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Jeff W EH From: Kasey Foley[EH] Seat: Tuesday, November 16, 2010 5:03 PM To: 'HARRELL, LARRY(ATTSI)';Jeff Wong [EH] Subject: RE: CUPA Permit Request UE042 Mr. Harrell, The letter from Jeff Wong says to"...comply with above request within 30 days of this letter"which would be December 10. I understand the box checked states"immediately"but the bottom of the letter clarifies within 30 days. Additionally, to quote your quote"...Settling Defendant shall file as promptly as reasonably practicable, but in no event later than 45 days after test failure(or no later than 60 days if engineering drawings are required, a complete application with the agency or agencies for a permit or other required regulatory authorization to undertake the repairs, and Settling Defendant shall complete the repair no later than 60 days after receipt of such permit or Other required authorizations ...(emphasis added)"looks to me like you aren't required to wait 45 days to submit a repair permit. We will be happy to accept a permit application sooner than the last day allowed in the judgment but we will not require an application for a permit be submitted before December 10, 2010. If I have misunderstood your concern, please contact me. I will be in the office Wednesday. Kasey Foley, REHS Program Coordinator San Joaquin County Environmental Health Department 600 East Main Street St Dckton, CA 95202-3029 (209)468-3451 Id @s hd.com --Original Message From: HARRELL, LARRY(ATTSI)fmailto:hh52590att.coml Sent:Tuesday, November 16, 2010 9:25 AM To: Kasey Foley[EH]; Jeff Wong[EH] Subject:CUPA Permit Request UE042 Importance: High Ms. Foley: I would appreciate it if you would examine the attached document from San Joaquin County found in the e-mail below. The request to immediately submit for a repair permit for failed equipment found during the SB989 testing conducted at 345 N.San Joaquin, Stockton, CA 95202 on 10/25/10 appears to be in conflict with Judgment Order#CV028367 issued by the State of California on January 13, 2006. 1 have attached the following link to that order from State Water Resources Control Board Web Page: http:/Avww.waterboards.ca.govtwater issuestproaramslenforcementtdocs/att _settlement.pdf Pursuant to this Consent Judgment, Section 6.3(page 12), "...Settling Defendant shall file as promptly as reasonably practicable, but in no event later than 45 days after test failure(or no later than 60 days if engineering drawings are required,a complete application with the agency or agencies for a permit or other required regulatory authorization to undertake the repairs, and Settling Defendant shall complete the repair no later than 60 days after receipt of such permit or other required authorizations ...(emphasis added). In light of the Consent Judgment,AT&T is respectfully requesting that we be allowed to observe the conditions of the Consent Judgment and submit a repair permit application no later than 12/9/2010 as we do not anticipate that engineering drawing are required for this repair. i