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Shieldsi P Har er tco. 3274 TOMAHAWK DRIVE, UNIT B • STOCKTON, CALIFORNIA 95205 • FAX (209) 462-0536 • (209) 462-9211 February 25, 1998 TO: Mr. Robert McClellon R.E.H.S. Environmental Health Division 304 East Weber Avenue Third Floor Stockton, California 95202 SUBJECT: Mr. Ed Cardoza Gas Station Dear Robert: I appreciate how thorough you and your department are in evaluating gas station upgrade permit applications. After speaking with you and Mr. David Holtry at the State Water Resource Control Board I understand what the laws governing containment and single wall pipe are. It is unfortunate that with regard to a trench liner the laws are unfair to the business owner. The fact that a single wall pipe can be monitored with line leak detection and a single wall pipe in a trench liner cannot be monitored the same way seems unfair. Please let me clear up a sentence in your letter dated February 17, 1998 to Mr. Jack Coffelt. in that letter you wrote, "He, (Greg Matas) , explained that the secondary containment was in failure and the system is basically a single line system" . There is no evidence that any of Mr. Cardoza's Gas Stations have a failure in the respective secondary. I was merely using a fictitious scenario to point out that a single wall system with a trench liner is better that a single wall system. In conclusion, I read in Title 23, Division 3, Chapter 16, Section 2636(F) (3) , that your office has the authority to accept an alternate to secondary containment monitoring if a business owner, "demonstrates to your satisfaction an alternate method" . (See Attachment) , please consider Mr. Jack Coffelt's application to install electronic line leak detection as an acceptable alternate to monitoring the trench liner as a means for leak detection. Thank you for your consideration. Regards, ZSHI LDS, HARPER & COMPANY - Li/� eg 2tas District Manager cc: Jack Coffelt cc: Ed Cardoza OAKLAND SACRAMENTO FRESNO SAN JOSE STOCKTON