COMPLIANCE INFO_2016 - 2017 - Laserfiche WebLink

Home Browse Search

Last we talked you were going to confer with a colleague about the issue of whether a permit is required or not for a pipe leak connecting to the generator for the Sprint Site located in Stockton.Again,the leak is a small weep at a pipe joint that is at the generator return line which is aboveground and inside the building. It is upstream (above ground level)of the UST system, not downstream (below ground level). It would be the same as having a leak in the piping inside a suction dispenser/pump. We have been in the business for many years and never have we had to have a permit to repair a pipe aboveground as UST regulations are for components and piping below the level of the fuel island, UDC and below ground. I respectfully request that your CUPA allow us to make these repairs without a permit, as we believe it does follow in- line with my below statements from the November 8t"email. Regards, Bill Rogers Jauregui &Culver, Inc. From: Bill Rogers [mailto:bill@icincorp.net] Sent:Wednesday, November 08, 2017 9:38 AM To: 'Stacy Rivera [EH]' <srivera@sicehd.com> Cc: Pete@icincorp.net; john.culver@icincorp.net 'Melissa Palermo'<Melissa COD[cincorp.net> Subject: RE: Permit application Hi Stacy, I left you a voice message about this. I see where our repairs would be no different than your guidance letter under#9, section titled: No-permit required repairs and specifically: "9. Dispenser replacement/repair except when conversion frames are required". Repairs to the dispenser would be no different than removing the dispenser for repairs, thus disconnection of the primary piping and making repairs to the dispenser or as in#1 of the same section under no-permit required: "1. Shear valves connected to Bravo float&chain devices"whereas,the shear valve is part of the primary piping.This system is a suction system and when the line is disconnected, the product will flow back to the tank and is not under pressure. My thinking is that, as allowed in the Guidance,there are instances where even though there are components and piping that is part of the primary piping definition, certain repairs can be made to piping and components in the primary piping path allowing repairs without a permit and I believe this would be one of those instances.Also,these repairs are aboveground and not underground which the UST regulations apply to. Therefore, can we agree that the repairs to the pipe leak is a non-permit required repair? Regards, Bill From: Stacy Rivera [EH] [mailto:srivera@sicehd.com] Sent:Wednesday, November 08, 2017 8:36 AM To: bill@icincorp.net Subject: Permit application UST website: http://www.socehd.com/Programs/Unitill/ust.html Generic UST email address: ust@sicehd.com Stacy Rivera 2