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Art and Corey, <br /> According to item #3 of our deficiency letter: <br /> According the submitted information 2" Ameron Coaxial LCX will be used for the biodiesel conventional <br /> suction piping and 3" Ameron Coaxial LCX will be used for tapping into the existing AO Smith 3" over 2" <br /> pressurized diesel piping. Sheet PP5 illustrates that the interstitial space of the diesel piping entering <br /> and exiting the transition sump in the injection building will be hydrostatically monitored. The <br /> interstitial space for the pressurized diesel piping must utilize pressurized liquid level <br /> monitoring. Please note that according to the CA State Water Resources Control Board's enclosure <br /> to the letter from February 29, 2008, "Matrix of Nonmetallic Piping Monitoring Applications", updated <br /> August 26, 2013, only Ameron's Brine Filled Interstitial Space Monitoring System must be used for <br /> pressurized liquid level monitoring. The current method of monitoring the hydrostatic piping uses a <br /> Bravo Manometer with a Veeder Root sensor. Furthermore the AO Smith 3" over 2" piping is not <br /> approved for any type of interstitial liquid level monitoring. The maximum distance that secondary <br /> piping can utilize pressurized liquid level monitoring is 344 feet. Provide a revised Sheet PP1 that <br /> illustrates greater detail for the area of transition of the Ameron Dualloy LCX 3" pressurized piping <br /> exiting and entering into the AO Smith 3" over 2" pressurized piping and how continuous monitoring of <br /> the secondary containment will be achieved. <br /> The 2" Ameron Coaxial LCX suction piping interstitial space can use ambient liquid level monitoring. The <br /> issue is that the 3"Ameron Coaxial LCX pressurized piping interstitial space must utilize pressurized liquid <br /> level monitoring since the product in the primary is pressurized, see attached "Matrix of Nonmetallic Piping <br /> Monitoring Applications" from the CA State Water Resources Control Board. A representative for NOV piping, <br /> Mr. Rob Motes, who is Cc'ed on this email, informed me that the 3" Ameron Coaxial LCX is approved to be <br /> monitored by pressurized liquid level monitoring, however he recommends not using it since they have <br /> experienced continuous alarms for this type of monitoring. The 3" Ameron Coaxial LCX piping is also <br /> approved for monitoring of the interstitial space by either vacuum or pressure. <br /> Please let me know how you will proceed with the type of interstitial monitoring that will be utilized for the 3" <br /> Ameron Coaxial LCX pressurized piping. If you plan to use the pressurized liquid level monitoring system, <br /> please provide cut sheets for Ameron's system, which is required to be used according to LG 113: <br /> http://www.waterboards.ca.gov/water issueslprogramslustlleak prevention/18113/vendors/ameron b.shtml <br /> I will be available during the holidays. The only days I have off are on Dec. 25 and Jan. 1. <br /> s <br /> Raymond von Flue <br /> Lead Sr. REHS, CUPA Programs <br /> San Joaquin County <br /> Environmental Health Dept. <br /> 1868 E. Hazelton Ave. <br /> Stockton, CA 95205-6232 <br /> (209)468-9848 <br />'i <br /> i <br /> a <br /> From: Art Lujan [mailto:ArtI0)mrbec.com] <br /> Sent: Tuesday, December 17, 2013 2,47 PM <br /> 4 i <br /> y <br />