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PUBLIC HEALTH SERVICES <br /> SAN JOAQUIN COUNTY <_ <br /> " I <br /> JOGI KHANNA M.D,M.P.H. <br /> Health Officer <br /> P.O. Box 2009 • (1601 Past Hazelton Avenue) • Stockton,California 95201 <br /> 4iFOR� <br /> (209) 6&3400 <br /> C1100, Py <br /> CHARLES E SKOBRAK SR M <br /> 9947 E HM 26 MAY O L 1992 <br /> STOCKTON CA 95215 <br /> RE: 308 N. Grant SWRCB UST CLEANUP FUND PROGRAM CLAIMANT #:1028 <br /> Stockton, CA <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has not issued <br /> the above listed site a permit although the site has been in compliance with requirements to own or <br /> operate the tank(s). <br /> Section 2712 (d) of the 1985 Underground Tank regulations (California Administrative Code, Title 23, <br /> Chapter 3, Subchapter 16) stated that "the local agency shall not issue a permit to operate an <br /> underground storage tank" until the local agency had inspected the facility and determined that the <br /> tank(s) complied with the regulations. Our interpretation of the statute implied that underground <br /> storage tank sites lacking a local agency site inspection or sites with soil or groundwater contamination <br /> could not be issued operating permits until the following was achieved: 1) a site inspection evaluation; <br /> 2) verification of appropriate monitoring method; 3) adequate and appropriate inventory reconciliation <br /> records; and/or 4) complete investigation and cleanup of the contaminated site. <br /> Due to this interpretation of the law, this site, as well as many others, was not issued a permit. <br /> However, it is our determination that this facility was operating in compliance with the regulations and <br /> should be considered for state funding. <br /> With the addition of Sections 2653 and 2654 to the 1991 Underground Storage Tank Regulations, <br /> PHS/EHD has the authority to require investigation and cleanup of contaminated sites, therefore, permits <br /> will no longer be withheld. <br /> If you have any questions please contact Linda Turkatte, RENS, of my staff at (209) 468-0339. <br /> Jogi Khanna, M.D., M.P.H. <br /> Health Officer <br /> Donna Heran, RENS, Program Manager <br /> Environmental Health Division <br /> DH/LT:Ib <br /> A Drminn of San Joaquin Co ,y Hcahh fire S mces 10 <br />