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1 A <br /> PUBLICHEALTH SERACES <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH,DIVISION <br /> Ernest M. Fujimoto, M.D.', M.P.H., Acting Health Officerq P <br /> Lf F04 <br /> 445 N. San Joaquin Street 4 P.O. Box 388 ! Stockton, CA 95201-0388 <br /> (209) 468-3420 <br /> E _ MAR 2 2 1994" <br /> BERNIE SLOOP <br /> P O BOX 8220 <br /> STOCKTON CA 95208 <br /> RE: American Moulding&Millworks <br /> E': 2801 West Lane <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 was in compliance with requirements to own or operate <br /> the tank(s). <br /> Section 2712 (d) of the 1985 Underground Tank regulations (California Administrative Code, Title 23, <br /> Chapter 3, Subehapter:16) stated that"the local agency shall not issue a permit to operate an <br /> I+, 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 /> I records; and/or 4) complete investigation and cleanup of the contaminated site. <br /> i, 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 Margaret Lagorio of my staff at (209) 468-3449. <br /> Ernest M. Fujimoto, M.D., M.P.H. <br /> Acting Health Officer <br /> � Diane M. Hinson, Supervising R.E.H.S. <br /> U ii Environmental Health Division. <br /> DMH/ml <br /> A Division of San Joaquin County Health Care.Services <br />