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11 <br />Zachary D. <br />Feingold/E M PL/CA/Verizon <br />10/22/2007 01:04 PM <br />Muni, <br />Ll <br />To mnaidu@sjcehd.com <br />cc <br />bcc <br />Subject Fw: Question on Title 23, Section 2636 <br />Please see the response below from the State Water Resources Control Board and get back to me as <br />soon as you can. <br />Thank you, <br />Zachary D. Feingold <br />Verizon - Environment Management <br />Desk: (909) 613-1554 <br />Fax: (909) 628-3380 <br />Emergency Hotline: (800) 386-9639 <br />----- Forwarded by Zachary D. Feingold/EMPL/CA/Verizon on 10/22/2007 01:03 PM ----- <br />"Scott Bacon" <br /><sbacon@waterboards.ca.go To Zachary D. Feingold/EMPL/CA/Verizon@VZNotes <br />4 v> <br />10/22/2007 01:00 PM cc <br />Subject Re: Question on Title 23, Section 2636 <br />Zachary, <br />You are correct that section 2636(f)(6) applies only to pressurized piping. <br />2636(f)(6) is an allowable alternative to installing an automatic line leak <br />detector as required by 2636(f)(2). Since automatic line leak detectors are <br />only required on pressurized piping, the alternative to automatic line leak <br />detectors only applies to pressurized piping. <br />Before jumping to the conclusion that the local regulatory agency is wrong in <br />applying this section, I would need to know a bit more about the specific UST <br />system. There are some cases where the CUPA may be correct in applying <br />section 2636(f)(6). For example, is there a pressurized fuel return line from <br />the generator back to the UST? If so, the local agency may be applying <br />2636(f)(6) to the return line rather than the delivery line. Also, section <br />2632(d)(1) requires that you notify the local agency, in writing, about the <br />frequency and reporting format for your monitoring. If the UST owner/operator <br />has previously agreed with the CUPA that they would conduct and record daily <br />checks of the monitoring system, they are required to comply with what has <br />been agreed to. Of course, in such a case, the UST owner/operator always has <br />the option of submitting a new written monitoring plan to the CUPA for <br />approval. <br />Please let me know if you have further questions on this subject. <br />Scott Bacon <br />State Water Resources Control Board <br />UST Program, Leak Prevention Technical Unit <br />1001 I St. 15th Floor <br />