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*Environmental Management <br />West Region <br />March 16, 2005 <br />Steven C. Shih, Senior R.E.H.S. <br />San Joaquin County <br />Environmental Health Department <br />304 E Weber Avenue, 3`d Floor <br />Stockton, CA 95202 <br />RE: Inspection on 9/7/04 at SBC Pacific Bell —10 E. 12th Street, Tracy <br />SBC Insp. # 1864 <br />Dear Mr. Shih, <br />P.O. Box 5095 <br />Room 3E000 <br />San Ramon, CA 94583 <br />VIA CERTIFIED MAIL <br />ENVIR ENT HEALTH <br />PE`?MMSEIRVICES <br />Pursuant to the Inspection referenced above, the status of the corrective action for the violation found is noted below: <br />• Piping sump (L3) was replaced on 5110104 by Gettler-Ryan. No permit was submitted to this off ce for <br />approval. A copy of work order was received on site. Immediately submit a permit to this office.. <br />I am responding to the referenced inspection report that cites Pacific Bell for failing to obtain a permit for <br />the replacement of an L3 piping sensor on its monitoring system for an underground storage tank at its <br />facility at 10 East 12th Street, Tracy, California. The report indicates that California Health and Safety <br />Code Section 25286(a) requires a permit before making monitoring system replacements of this nature. <br />However, California Health and Safety Code Section 25286(a) does not address permits for monitoring <br />systems. It only addresses applications to obtain or renew permits to operate underground storage tanks. <br />California Health and Safety Code Section 25286(a) states in pertinent part: <br />An application for a permit to operate an underground storage tank, or for the renewal of the permit, shall <br />be made, by the owner or operator of the tank, or, if there is a CUPA, by the owner or operator of the <br />unified program facility on which the tank is located, on a standardized form provided by the local agency. <br />(emphasis added) <br />Since California Health and Safety Code Section 25286(a) does not require permits to perform monitoring <br />system sensor replacements, Pacific Bell requests that you send us a letter verifying that the violation cited <br />in the inspection report was issued in error. <br />If you have questions or need additional information, please call me on (925) 823-6161. <br />Sincerely, <br />Andrew Taylor 7 <br />Sr. Environmental Manager <br />cc: Irene Soto <br />AT:sb <br />