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Shell Facility <br />4315 E. Waterloo Rd. 92 PRODUCT PIPING REPLACEMENT <br />Stockton, CA 16 March 2001 <br />HISTORY <br />On or about February 10, 2001, the Veeder-Root TLS -350 went into L2 Fuel Alarm (Positive Shutdown) for <br />the Shell Station @ 4315 Waterloo Rd Stockton. Approximately 5 gallons of product was found in the pre- <br />mium turbine sump. Station currently has DW tanks and lines with full containment for the turbines and <br />dispensers. With this equipment, there were no concerns of product release. Product was properly removed <br />and the station was placed in close observation. Three days later, product was again found in the same lo- <br />cation. This time, it was observed dripping out of the secondary piping inside the sump. Premium product <br />line was immediately taken out of service and a permit application was submitted to San Joaquin County <br />PHS-EHD to investigate the possible problem. Line was tested with inert gas (Nitrogen) and the pressure <br />held. Under EHD observation, additional long-term and repetitive pressure tests were performed and the <br />pressure continued to hold. On February 16, 2001, EHD allowed the line to be operational again with the <br />condition that the premium turbine sump was observed on a daily basis for 30 days. <br />Daily observations were performed for about 3 weeks without any trace of product in the premium turbine <br />sump. On March 8, 2001, approximately 2 ounces of product was found dripping out of the secondary and <br />into the contained turbine sump. Product was taken out of service at the dispensers, EHD was informed, <br />and additional pressure tests were performed. Pressure held again. Sump was observed for 2 more days <br />and found increased amounts of product each day. LC Services was instructed to purge the line and investi- <br />gate the problem. <br />On March 14, 2001, LC Services began exploratory excavations at underground fitting locations. Investiga- <br />tion was started at the midpoint of the line, and continued upstream or downstream depending on what was <br />found. No residue was initially found, so the downstream path towards the sump was followed. Some <br />residue was found in the section from the first elbow to the penetration into sump. Because pressure held <br />through all the pressure tests, the residue was the best indicator of location. <br />WORK PLAN <br />Replace premium line from the turbine sump to the second 90 degree elbow and repair secondary piping in <br />the other two excavations. New pipe will match existing (AO Smith). <br />REMEDY <br />Due to pressure holding, the residue inside the secondary pipe by the sump area provided the best indicator <br />of the problem. All exposed sections upstream towards the initial excavated point were dry and no trace of <br />residue. This indicates that the line sections upstream are tight. A conservative section of the line will be <br />replaced to ease any concerns. <br />The plan is to begin piping replacement on March 19, 2001. <br />Excavations <br />0- <br />