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0 0 <br />4) Alleged Violation (209): CCR 2715(c) Designated operator did not inspect all required Items and/or the inspection <br />reports not completed. The designated operator failed to documental] the alarms from the attached alarm history on <br />the September 2016 designated operator monthly inspection report and foiled to check that they were responded to <br />appropriately. The missing alarms include: 511 (87A Vent Vacuum) Communication alarm - 8/16/15 <br />Response: The 00 (Belshire) did not record the alarms because of their brief nature, but has committed to <br />adhere to the regulatory conditions of reviewing and alerting the Owner/Operator of any conditions discovered <br />during the UST Operator Monthly Visual Inspection Checklist which may require any follow-up. <br />5) Alleged Violation (3041• HSC 25290.1(d) Monitoring system not maintained to detect entry into secondary <br />containment (after July 2004). According to the maintenance records on site, the L9 (87B Fill) sensor went into sensor <br />out alarm on 10/29/15. The technician who responded to the alarm noted that the sensor would not go into o fuel <br />alarm, even when flipped upside down. A service request application was submitted on 11/2/15. A permit approval <br />letter was issued dated 11/19/15. The maintenance records on site indicate the sensor was not replaced until 1120/16, <br />on the day of functionality verification testing with an EHD inspector. The 87B fill sensor was incapable of detecting a <br />leak from 10/29/15 until 1120/16. The continuous monitoring system shall be maintained to detect the entry of the <br />liquid or vapor phase of the hazardous substance stored in the primary containment into the secondary containment <br />and to detect water intrusion into the secondary containment. The sensor has been replaced and retested. Ensure that <br />all sensors are maintained to detect the entry of the liquid or vapor phase of the hazardous substance stored in the <br />primary containment into the secondary containment and to detect water intrusion into the secondary containment at <br />all times. <br />Response: The Owner/Operator has been educated on the correct procedures for UST repair/modification <br />permits for EHD prior to updated permit charges dated October 1, 2016. Owner /Operator will review new <br />guidance for San Joaquin EHD dated October 1, 2016 with senior management staff. <br />6) Alleged Violation 1306)• CCR 2630(d) Monitoring equipment is not installed or maintained to detect a leak at the <br />earliest opportunity. The brine sensors monitoring the annular spaces 01 011 eight UDCs were found not located at the <br />top of the UDCs to detect a leak at the earliest opportunity. The brine level in alt of the UDCs was low and the sensors <br />were located too low to have detected the drop in brine level. In some UDCs, the brine level was not high enough to <br />reach the site gauge. Monitoring equipment shall be maintained to be able to detect a leak at the earliest possible <br />opportunity. The brine was topped off and all sensors were relocated to the top of the UDC annular level by the service <br />technician. Ensure that all monitoring equipment is maintained to detect a leak at the earliest opportunity. <br />Response: The sensor was replaced and retested during the inspection. <br />7) Alleged Violation 13161: HSC 25290.1(c3), 25290.2 (0) Secondary containment not constructed to prevent water <br />intrusion (after July 2003). Water was found in the 87 east STP sump. Secondary containment shall be constructed to <br />prevent any water intrusion into the system by precipitation, infiltration, or surface runoff. The service technician <br />removed liquid from the sump and returned the sensor to its proper location. Immediately contact a properly licensed, <br />trained, and certified contractor to address the water intrusion into the 87 east STP sump under permit and inspection <br />of the EHD. <br />Response: This was corrected on site during the inspection. <br />81 Alleged Violation (318): CCR 2636(0(2) Leak detector failed to detect a 3.0 gph leak at 10 psi. The 87A and 878 line <br />leak detectors failed to detect a leak when tested. All line leak detectors shall be capable of detecting a 3 -gallon per <br />hour leak at 10 psi. The service technician changed the siphon jets on the 87 turbines, retested the leak detectors, and <br />they passed. <br />Response: This was corrected on site during the inspection. <br />