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CITY COUNCIL BLAIR KING JOHN BECKMAN, City Manager SUSAN HITCHCOCK Mayor CITY OF L O D I SUSAN J. BLACKSTON Mayor Pro Tempore PUBLIC WORKS DEPARTMENT City Clerk LARRY D. HANSEN D. STEPHEN SCHWABAUER BOB JOHNSON CITY HALL, 221 WEST PINE STREET City Attorney JOANNE L. MOUNCE P.O. BOX 3006 RICHARD C. PRIMA, JR. LODI, CALIFORNIA 95241-1910 Public Works Director Telephone (209) 333-6706 FAX (209) 333-6710 EMAIL pwdept@lodica.gov http:\\www.lodi.gov November 10, 2005 FI-11� NOV 1 4 2005 Dennis Catanyag ENVIRONMENT HEALTH San Joaquin County, Environmental Health Department PERMIT/SERVICES 304 E. Weber Avenue Stockton, CA 95202 SUBJECT: Underground Storage Tank (UST) Program Inspection Report at City of Lodi Municipal Service Center, 1331 South Ham Lane, Dated October 27, 2005 The UST Inspection Report of 10/27/05 for the City of Lodi Municipal Service Center listed four violations. The first item, #4, is that your office does not have a copy of the certification of financial responsibility form and letter from the chief financial officer on file. This was sent by fax to you on 6/24/05 (see Enclosure #1, including fax cover page). We apologize that a copy was not found on site while you were present. However, a copy was maintained in my files and has now been added to the on-site UST Operation and Maintenance manual/binder. The second item, #23, was that the monthly inspections being performed by the designated operators were not sufficient. We were using a form from the Designated UST Operator Training Manual that was from the EPA Guidance Documents, EPA Publication No. 510-B-00-008. That form contains substantially the same information as the form you supplied as your preferred form. As such, we think the citation for noncompliance for the "form of the form" is not appropriate. Nevertheless, we have replaced the one we used with the UN-057 form located on the Unidocs.org website, as you suggested, and will now attach the monthly alarm history printout (from our monitoring system). We had trained several employees consistent with our understanding that training is only required for one on-duty staff person per CCR 2715(f), but did not have an adequate record of the training; we have now corrected that by training all of the staff and documenting this training. For your reference, copies of the Designated UST Operator Monthly Visual Inspection Report and Training Record are enclosed (Enclosure #2). The last two items, #24 and #25, were that we had not met the 10/15/05 deadline for annual monitoring testing or line leak detection testing. The Annual Monitor Certification, Static Pressure Decay Testing, Dynamic Back Pressure Testing, Spill/Overfill Containment Testing, and Leak Detector Testing were conducted on Thursday, 10/27/05, the date of the inspection, and were the reason you were on site. It was our understanding that the deadline for the tests was consistent with the San Joaquin Valley Air Pollution Control District requirements, which specify tests be performed no later than 30 days after the anniversary date. We now know the J:\PROPERTY\UNDERGROUNDTANKS\LSJHEALTH1105.DOC