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6 0 Muniappa Naidu [EH] Page 1 of 2 From: Mary Rose Holtz [rholtz@a Barghausen.comj Sent: Tuesday, December 11, 2007 10:51 AM To: Muniappa Naidu [EH] Cc: Harley Mattson; File Subject: Costco Gasoline, Manteca, CA - CUPA Comments - BCE #12919 Mr. Naidu, According to a conversation you had with David Painter of our office, it is my understanding you have the following concerns with the Manteca, California Costco gasoline site. i have included the comments, followed by my responses in RED, 1. Why are we putting a single float in the tank annular? The site is a wet site. It is our standard specification to include a single float in the tank annul, r. If you squire a dual float, I will modify our plans to indicate such. Please advise. vW/J (_ca_ . 2. Sheet T1, Note 913: Muni doesn't understand why we would specify "30 minutes" for the test; his experience is the lines would be pressurized and held there for a significant length of time— maybe 24 hours. This note has been modified to read: B. TANKS AND PRIMARY PIPING HYDROSTATICALLY OR PNEUMATICALLY TESTED IN ACCORDANCE WITH MANUFACTURER'S GUIDELINES. 3. Sheet T1, Note 12: This is possibly semantics, but he believes the note should more clearly read, "Prior to fuel being dropped" or "Prior to first fill" rather than "Prior to fuel being pumped." This note has been modified to indicate, "Prior to first fill". 4. On Sheet T1, the note on the tank profile says with a 2" level sensed, a 72 hour window would start before shut down. With a 5" level sensed, there would be an immediate shutdown. Muni understood there should be a shutdown immediately with a 2" level sensed. This note is what Costco desires, If you will require a shutdown immediately with a 2" level sensed, I will modify our plans to indicate such. Please advise. ,�- Dyi 1 rot ted by th��fL, 5. Sheet T2, Detail D: Muni believes if the fiberglass pipe is exposed, and only protected by the 20 mil wrap, the first time the wrap is damaged, the pipe will start to degrade and will become ft porous and problematic very soon. I think he was looking for completely buried fiberglass or �,, greater protection than the wrap, To alleviate concern, I have added a vent transition sump on the plans giving greater protection to the vent piping. 6. Sheet T2: Guidance Letter from the State Water Res. Board LG -150-1 stipulates (or perhaps suggests) that the ball float level and tank gauge full indication should be the same. We have the ball float at 95% and the tank gauge at 90%. According to LG -150-2 (supersedes LG -150-1), The UST Overfill Prevention Requirements, Option A indicates that the overfill prevention system alerts the transfer operator when the tank is 90 percent full by restricting the flow into the tank OR triggering an audible and visual alarm and does not allow for manual override. This option allows for the use of one of two methods. We use option 2) External (audible and visual) alarm which alerts the delivery operator when the UST is 90 percent full. As a design back-up, we install a ball float at 95 percent in addition to the methods indicated by the UST Overfill Prevention Requirements. Please note that your immediate response is required for comments 1 and 4. Also, will you be requiring a formal letter outlining the responses to your comments as well as revised plans for your review. If you require plans, how many sets will you require, Your immediate attention to this issue would be greatly appreciated. If you have any questions, please feel free to contact me at this office. Thank you, Mary Rose Holtz 12/11/2007