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a /BELSHIRE <br />ENVIRONMENTAL <br />SERVICES, INC. <br />PMB 269 <br />25422 Trabuco Road #105 <br />Lake Forest CA 92630-2797 <br />(949) 450-1010 <br />Fax (949) 450-1177 <br />March 17, 2003 <br />Ms. Dina Abate <br />County of San Joaquin <br />Environmental Health Division <br />304 East Weber Street <br />Stockton, CA 95202 <br />Re: Secondary Containment Testing and Repairs <br />ARCO Fac# 2186 <br />3212 N. California, Stockton <br />Dear Ms. Abate: <br />EtN'Vi ;ONMEF� iAi. HEAL 111 <br />►'UY!T SFR1/1 f' <br />03 MAR 19 AM 9: 54 <br />This letter is being submitted on behalf of BP West Coast Products LLC (BP) in response to your <br />request for further information regarding repairs made at ARCO Station 2186 in the course of <br />secondary containment testing. <br />BP's contractor CGRS conducted initial testing at the site on 12/12/2001. At that time, all <br />components other than the 91 product turbine sump and 87 product master turbine sump passed. <br />CGRS believed that the failures were caused by penetration fittings associated with an inactive <br />siphon line that extended between the two sumps (see attached drawings). When the tanks at <br />station 2186 were installed in 1999, it was common for ARCO tank systems to be installed with a <br />siphon line in order to preserve the ability of the station to connect the tanks if, in the future, the <br />tanks held the same grade of product. Based on field observations, the contractor could find no <br />evidence that the siphon line at Station 2186 had ever been in service (no odor, discoloration, <br />etc.). In addition, the tanks linked by the siphon line at Station 2186 hold different grades of <br />product (premium and regular). This strongly indicates that the siphon line had never been used <br />because there is no reason to siphon two tanks holding different grades of gasoline product. <br />These factors provided us with reasonable assurance that the line had never been in service. <br />The repairs consisted of removal of the inner pipe, cutting back of the outer pipe flush with the <br />sump walls, and patching of the resulting holes with fiberglass mat and resin. These repairs were <br />made in accordance with common industry stands. Upon completion of the repairs, the sumps <br />were tested and passed on 12/18/01. Enclosed are copies of the record of testing results and <br />repairs conducted by CGRS. <br />Page 1 of 2 <br />