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cal'iefornia fuels <br /> R CEIVEr <br /> _ - JAN 13 1992 <br /> IRO <br /> !'.!V�IPEfI7AM�cl r <br /> Environmental Health UST Permit Services <br /> P.O. Box 2009 <br /> Stockton, CA 95201 <br /> Re: 2211 N. Wilson Way, Tank #0008 & 0009 <br /> To Whom It May Concern, <br /> The purpose of this letter is to request a refund of permit fees paid on March 4, 1991 <br /> for the tanks indicated above. I believe we should not have been assessed these fees, including <br /> Container Fees and State Surcharges, as the tanks are not now and never have been <br /> "underground". We paid these fees last year to avoid the 140% penalties involved and because <br /> we knew that the Legislature was working on a clarification of what was required for an <br /> exemption from UST regulations by non UST's. <br /> The original legislative intent was recently clarified in AB 1057 by the "Father" of UST <br /> legislation in California, Assemblyman Byron Sher. The Law exempts 'below grade' tanks in a <br /> secure secondarily contained structure when the "system" is regularly visually inspectable. <br /> The tanks we operate are in a structurally engineered concrete and steel lube "pit" which can <br /> contain over 50 times the volume of the recycled waste oil put thru the small tanks. Any leak <br /> would be immediately visible and could not escape. We also regularly inspect them. The new <br /> law adds that we must log these inspections. <br /> Your Department did not asses these UST fees until 1991 after much back and forth on <br /> the issue and many re-inspections. Back in 1988 at the initial inspection by County personal <br /> these tanks were deemed to be exempt but no letter was issued. I do not know why this policy <br /> had changed, but I guess it depends who was interpreting the law and regs. at that time. I would <br /> not be making an issue of this now except for the fact that we paid $1,742.00 for the permits <br /> and back fees, without penalty. That is a huge amount of money to a small company like <br /> California Fuels especially during this recession. <br /> I have been deeply involved in UST regulation for many years now and I know how <br /> confusing much of it can be. I appreciate your prompt action and response in this matter. <br /> Sinec�y` r <br /> David Atwater <br /> President <br /> 3005 Navy Drive • P.O. Box 1207 (209)466-5921 <br /> Stockton, California 95201 (800) 323-8357 <br /> FAX (209) 466-1910 <br />