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PUBLIC AEALTH SERVICES <br /> SAN JOAQUIN COUNTY r :y <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202 <br /> 209/468-3420 <br /> February 17, 1998 <br /> Jack Coffelt � � <br /> Elite 4 Contractors Inc . C <br /> 2535 Wigwam Drive <br /> Stockton, Ca 95205 <br /> RE : Two Guys Feed and fuel 147 E. Lathrop Road, Lathrop and 1151 <br /> Louise Avenue, Manteca Ca. <br /> This letter is in response to your letter of February 12, 1998 . <br /> The plans to upgrade the above referenced facilities were <br /> received by PHS-EHD. The plans were reviewed and I spoke with you <br /> on February 9, 1998 . I informed you that the equipment that you <br /> intended to use would not be allowed to provide auto-shutdown as <br /> indicated in the plan proposal . I informed you that the sensor in <br /> the secondary would have to provide auto-shutdown. You indicated <br /> that you had another means of providing auto-shutdown with the <br /> existing equipment by adding a series of relays . You indicated to <br /> me that you were going to check on it and would get back to me. I <br /> informed you that any changes would need to be submitted in an <br /> addendum. I indicated that the Incon LLD could be used to do the <br /> annual line test . This would allow the facility to conduct its <br /> own line test annually. Your letter describes the trench liner as <br /> additional protection to the environment . Title 23 Section <br /> 2636 (d) describes the trench liner as secondary containment . <br /> Title 23 Section 2636 (8) describes the exemption for the positive <br /> automatic shutdown. I have attached a copy of the above <br /> referenced code sections to this letter. On February 9, 1998 I <br /> received a phone call Form Greg Matas of Shields Harper Inc. He <br /> informed me that he was familiar with the site and questioned the <br /> reason for not allowing the Incon LLD to provide auto-shutdown. <br /> He argued that the Incon LLD is approved by the state and capable <br /> of providing auto-shutoff at this site . I explained that the <br /> sensor in the secondary containment would have to provide the <br /> auto-shutdown. He explained that the secondary containment was in <br /> failure and the system is basically a single line system. If the <br /> secondary containment is in failure as he indicated this would <br /> require a repair to the secondary containment in accordance with <br /> Title 23 CCR. The repair of the secondary containment would <br /> require a permit from PHS-EHD. If there has been a release do to <br /> the failed secondary the owner or operator would be required to <br /> comply with Health and Safety Code Section 25295 and submit an <br /> unauthorized release form within 24 hours of the release . The <br /> A Division of San Joaquin County Health Care Services <br />