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Circle K Stores Inc.-West Coast Business Unit 495 East Rincon,Suite 150 so Corona,CA 92879 qualified personnel and make appropriate adjustment to make the float and chains detect leak at the earliest point A permit must be taken out for the work done. Response: Our service vendor(Elite IV)obtained the required permit from your Office and adjusted the floats and chains to detect a leak at the earliest possible point. Issue#4: The 87 spill bucket failed the hour hydrostatic test. Immediately repair/replace the spill bucket with a permit from this Office. Response: Our service vendor(Elite IV)obtained the required permit from your office and replaced a spill bucket for one of the tanks. Unfortunately,the spill bucket was replaced for the wrong tank. We have requested our service vendor to rectify this immediately by obtaining another permit from your Office and replace the spill bucket for the appropriate tank. You should see the additional permit application within the next few days. Issue#5: Could not locate facility Designated Systems Operator statement or the D.O.training record for the UST employees. Immediately prepare a D.O. statement and submit to this Office,also locate D.O.employee training records and submit a copy to this Office by 6/15/08. An employee must be trained by the D.O.within 30 days of hire and annually there after. Response: I have enclosed a copy of the Owner Statements of Designated Underground Storage Tank(UST) Operator and Understanding of and Compliance with UST Requirements for your information. A copy has also been forwarded to the store manager to maintain at the store. I have also enclosed copies of the D.O.training records. Copies of these training records were left with the store manager to be maintained at the store. Issue#6: A return to compliance must be submitted to this Office by 6/15/08. The annular space for the 91 tank is under investigation. There was unexplained alarms and liquid fluctuations. LC Services have been hired by the facility owner to perform repairs. Response: As we discussed in our last phone conversation,LC Services requested Xerxes to consider the impact to the tank of a short term exposure of brine fluid in the annular riser at a measurement in excess of 12-inches. LC Services also requested Xerxes to modify their previous letter if a short term exposure was acceptable. 1 have enclosed a copy of the letter from Xerxes dated June 11, 2008. The letter states"Using the monitor for a reservoir should not damage the tank as long as the brine level is no higher than 12"above the top of the tank for over 12 continuous hours. The brine level should never be allowed to be over 36"above the top of the tank,especially when the tank is empty." Circle K proposes the following plan: relocate the annular riser to the other end of the tank, refill the annular space with brine to no more the 6"above the top of the tank, install and adjust the annular sensor,drop a full load of fuel under the supervision of a qualified service technician who will adjust the brine level if needed,and place the tank system back in service. Circle K would also put our service provider on a mandatory 8-hour emergency response for this