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Raymond von Flue EH <br /> From: Raymond von Flue[EH] <br /> Sent: Friday, March 02, 2012 4:14 PM <br /> To: 'bsmith@wpsac.com' <br /> Cc: 'dbock@costco.com'; Kasey Foley[EH]; Willy Ng [EH]; Thuy Tran [EH] <br /> Subject: Secondary Containment Test Failure <br /> Tracking: Recipient Delivery <br /> 'bsmith@wpsac.com' <br /> 'dbock@cosico.com' <br /> Kasey Foley[EH] Delivered:3/2/2012 4:14 PM <br /> Willy Ng[EH] Delivered:3/2/2012 4:14 PM <br /> Thuy Tran[EH] Delivered:3/2/2012 4:14 PM <br /> Brandon, <br /> I wanted to reiterate the phone call that we had today regarding the failed secondary containment test at Costco <br /> Gasoline#658, 3250 W. Grant Line Rd.,Tracy CA on the 87 product piping and Under Dispenser Containment(UDC) 5/6 <br /> on February 7, 2012. The service technician stated in the notes of the test results that he found a leak at Jumper Boot in <br /> UDC 5/6. Our office was contacted to see if a permit application would be required for this failure. Upon speaking with <br /> my supervisor we determined that a permit application would not be required since the failure was determined to be <br /> from the test boot. However once the test boot is replaced and the 87 secondary flex piping and/or UDC 5/6 are <br /> retested and found to fail the test again,a permit application would be required to be submitted. <br /> I also informed Mr. Smith that after the completion of the test,the jumper hose connecting the two test boots must be <br /> disconnected in a way that the 87 secondary piping would be able to communicate with the UDC if a leak occurred. Mr. <br /> Smith stated that all of the jumper hoses at this facility are still connected to the test boots in all of the <br /> UDC's. According to Title 23, CA Code of Regulations,section 2630(d): "All monitoring equipment used to satisfy the <br /> requirements of this article shall meet the requirements of section 2643 (f) and shall be installed and maintained such <br /> that the equipment is capable of detecting a leak at the earliest possible opportunity. Additionally, all monitoring <br /> equipment used to satisfy the requirements of this article shall be installed,calibrated,operated, and maintained in <br /> accordance with section 2638." <br /> So our interpretation of this regulation is that the product flex piping secondary containment must have communication <br /> to the nearest point of monitoring(UDC) so that a leak can be detected at the earliest possible opportunity. If the <br /> jumper hose is left on, a potential leak would have to travel across the hose and to the secondary containment of the <br /> adjacent product pipe,thus bypassing the monitoring equipment. <br /> Please let me know if you have any further questions. Thank you. <br /> Raymond von Fide <br /> Lead Senior Registered Environmental Health Specialist <br /> San Joaquin County Environmental Health Department <br /> 600 E. Main St. <br /> Stockton CA 95202 <br /> Voice: (209) 468-9848 <br /> Fax: (209)468-3433 <br /> t <br />