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PUBLIC hEALTH SERVfeES <br /> 1 <br /> SAM+ JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DNISION <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> [iFOR�' <br /> 445 N. San Joaquin Street • P.O. Box 388 • Stockton, CA 95201-0388 <br /> (209) 468-3420 <br /> C(Oply <br /> JIM ESCOBAR <br /> CITY OF STOCKTON <br /> 425 NORTH ELDORADO STREET <br /> STOCKTON CA 95201 AUG 2 2 1994 <br /> RE: OPERATING PERMITS FOR 11© W SONORA STREET AND FONTANA DRIVE AT <br /> SMITH CANAL - — --- <br /> The review of the files for the two above noted sites by San Joaquin County Public Health Services, <br /> Environmental Health Division (PF%EHD) staff revealed that no operating permits had been issued by <br /> this office. These permits were not tzued although the sites had been in compliance with requirements to <br /> own or operate the tanks. <br /> Section 2712(d) of the 1985 Undo?round 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 underground <br /> storage tank" until the local agency h2d inspected the facility and determined that the tank(s) complied <br /> with the regulations. Our interpretation of the statute implied that underground storage tank sites lacking <br /> a local agency inspection or sites with soil or groundwater contamination could not be issued operating <br /> permits until the following was achieved. 1) a site inspection evaluation; 2) verification of appropriate <br /> monitoring method; 3) adequate and appropriate inventory reconciliation; and/or 4) complete investigation <br /> and cleanup of the contaminated site. <br /> Due to this interpretation of the law,these sites, as well as many others, were not issued a permit.. <br /> PHS/EHD did not issue permits for these two sites because they both had documented soil contamination. <br /> However, it is our determination that these facilities were operating in compliance with the regulations <br /> and should be considered for state funding. <br /> If you have any questions or wish to discuss this matter in more detail, please contact Linda Turkatte, <br /> Senior REHS, at (209) 468-3441. <br /> Donna Heran, RENS, Director <br /> Environmental Health Division <br /> Linda Turkatte, Senior REHS Diane M. Hinson, HS <br /> Site Mitigation Unit Supervisor <br /> LT <br /> A [N,i4m of San Joaquin County Health Care Services <br />