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I I <br /> DocuSign Envelope ID:516EDCEC-B4B6-4460-9*F73EA468C04 • <br /> rrco <br /> HIMES"E <br /> May 22, 2017 R E 13 � � <br /> H .r <br /> Vicki McCartney 3 2017 <br /> Senior REHS <br /> San Joaquin County Environmental Health Dept. ENVIRONMENTAL HEALTH <br /> 1868 E. Hazelton Ave. DEPARTMENT <br /> Stockton, CA 95205 <br /> Dear Inspector McCartney <br /> This letter is in response to the May 17 inspection of the Costco gas station located at 2680 <br /> Reynolds Ranch Pkwy, Lodi. The specific violation was for very small amounts ("%cup") of <br /> liquid found in the turbine sumps of two of our underground storage tanks. Inspector Cesar <br /> Ruvalcaba, EHS Trainee, signed the inspection report but our tester informs me that you were <br /> on site as well. It was noted that the Lodi infraction was a repeat violation for liquid intrusion. <br /> Attached for your convenience is my letter to you, dated March 31, 2017, regarding a similar <br /> violation at our Stockton location. To date I have received no reply to that letter. <br /> Costco objects to violations that affect our compliance record for which we have no practical <br /> course of avoidance, and that do not negatively impact safety or the environment. These small <br /> liquid accumulations are due to condensation, and not liquid intrusion per code (i.e., "water <br /> intrusion by precipitation, infiltration, or surface runoff'). <br /> We feel that any liquid accumulation insufficient to trigger a properly-placed liquid sensor should <br /> not be a violation, by definition, as we rely on the liquid sensors to tell us when a sump has <br /> failed per state and local requirements. <br /> Included is a photo taken by our tester Alltech Petroleum, that shows the tiny amount of sump <br /> moisture that triggered this latest violation. Although Costco inspects all our CA tank sumps <br /> twice annually, and any moisture is removed at those intervals, we cannot control condensation <br /> accumulation of amounts less than one cup. We protest this second instance of a "liquid <br /> intrusion" NOV for condensation moisture, and ask that it be stricken from our compliance <br /> record. We further ask that in the future no violations be written for moisture insufficient to <br /> trigger an alarm. <br />