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nKTHE CIRCLE K CORPORATION CONVENIENCE FOOD STORES January 25, 1989 Mr. Charles Hunt San Joaquin Local Health District P.O. Box 2009 Stockton, CA 95201 Subject: Review of Precision Tank Tests for 1986, 1987 and 1988. Dear Mr. Hunt: This letter is in reply to your request that I review the precision tank tests for our stores in San Joaquin County and determine if the test data indicates a product loss in excess of one (1) gallon. The NFPA code 329.02 criteria for a "tight" tank system is a tolerance of .050 gallons per hour. Because of the almost infinite variables involved the test results are not intended to be a mathematical tolerance and is not permission for any leakage of the tank system. In the event the precision tank testing indicates a tolerance and/or a leak rate in excess of .050 gallons per hour further investigation of the tank and lines must be performed to determine if the excessive tolerance or leak rate is due to temperature, tank end deflection, tank leak, an air pocket, line leak or incorrect testing procedures by test personnel, or a combination of the variable. For most tank and line tests we employ contractors that utilize Petro-tite test equipment. Enclosed herewith is a review of the tank test data on our San Joaquin County stores. Store #1205, 16470 Cambridge Street. , Lathrop, CA. 1986, 1987, 1988 all tanks tested "tight", no review required. Store 11334, 2650 lit. Diablo Street, Stockton, CA. 1986 and 1987 all tanks tested "tight". 1988 the regular and unleaded tanks and lines tested "tight". The The premium unleaded tank failed (7/21/88). After investigation the failure was determined to have been caused by a loose pipe connection on the vent line. The problem was repaired and the tank was retested (8/25/88) and found to be "tight". See test data sheet enclosed. The temperature compensation use factor column (1137) indicates the settled loss rate at -.250 gallons per hour on high level (-.250 x 2 hours=. 5 gallons loss). The loss as calculated is assuming that the only tank variable is due to the loose vent pipe connection and not partially due to an air pocket, temperature, tank-end deflection, etc..