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HEALTH SERVICESPUBLIC <br /> SAS'JOAQUIN COt!NTY c l y< <br /> JOGI KHANNA MD..MY H <br /> Health Officer XPi <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) • Stockton,California 95201 <br /> (209)468-3400 <br /> (COO Ply <br /> December 2, 1991 DECO 21991 <br /> Dave Deaner <br /> State Water Resources Control Board <br /> Division of Clean Water Programs <br /> Underground Storage Tank Cleanup Fund Program <br /> F.O. Box 944212 <br /> Sacramento, CA 94244-2120 <br /> Re: SB 2004 Eligibility <br /> Dear Dave: <br /> As we discussed at the recent SB 2004 workshop at Micke Grove Park, <br /> San Joaquin County required owners of previously exempt farm tanks <br /> to obtain permits when they discontinued use of their tanks for <br /> agricultural purposes. During closure activities, contamination <br /> was identified at several of these sites and assessment and <br /> remediation activities were initiated. <br /> We understand that these individuals have been informed that they <br /> may not be eligible for reimbursement under the SB 2004 cleanup <br /> fund due to the prior exempt status of their tanks. <br /> Enclosed is a copy of LG-109 (revised) , received in August 1990, <br /> which states that farm tanks no longer used for agricultural <br /> purposes are required to obtain an operating permit or a closure <br /> permit. This requirement was also included in the recently adopted <br /> UST regulations in Title 23 , Chapter 16, Section 2621 (c) . On <br /> November 4 , 1991, we received notification that this regulation is <br /> being revised to exclude these tanks from all permit requirements. <br /> The San Joaquin County Environmental Health Division requests a <br /> clarification of the eligibility status of former farm tank owners <br /> who complied with the existing UST regulations and permit <br /> requirements. It would seem that these tank owners are being <br /> penalized for compliance since it is unlikely that contamination <br /> will be identified or reported to regulatory agencies by owners not <br /> required to obtain UST permits for operation or closure. <br /> A DM%ion of San Joaquin Counn.Hcahh Care.Services 7 <br />