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08/22/2006 11:31 5592665371 SHIELDS HARPERRSNO PAGE 02 <br />Shields, Harper & Co. <br />Fresno, CA 93706 <br />August 21, 2006 <br />Mr. Willey Ng (209) 468-3420 phone, (209) 468-3433 fax <br />Mr. Ray Von Flue (209) 468-9848 phone, (209) 468-3422 fax <br />San Joaquin County Environmental Health <br />Stockton, CA 95202 <br />Re. UDC Repairs <br />Country Mart <br />34243 South Chrisman Road <br />Tracy, CA 95202 <br />Dear Mr. Ng, & Mr. Von Flue, <br />6 UDC's at this site required repairs in order to pass SB989. We recognize the use of <br />Parasealant 626 was a non -approved material to make such ,repairs. In, an effort make <br />approved repairs and open the station for the owner as soon as possible we are submitting <br />the following work plan. <br />As you know 5 of the 6 UDC's will pass SB989 and I of them still, fails. Our plan is as <br />follows: <br />First, Blue Line Technologies has a UL listed and labeled "R ellethG ne" non -split <br />penetration. that can be installed from the inside of the UDC with self -tapping screws. <br />The UL .Listing is enclosed and the D & S Dragline certification to install the Blue Line is <br />enclosed. May we change our original submittal for penetrations where needed to Blue <br />Line? <br />Second, of. the 5 UDC's that now pass SB989 one of three repairs has taken place—Tri <br />certai,z,. UDC's adjusting and tightening the existing penetration and/or test reducer sealed <br />the UDC. In other cases tightening the steel conduit joints and/or replacing the inner, seal <br />within the conduit and within the UDC sealed the UDC. Tn other cases, the Parasealant <br />626 sealed the UDC. <br />Since the use of Parasealant 626 is not an approved repair we propose that where that is <br />the confirmed method that sealed the LDDC, we replace the existing penetration with the <br />Blue Line Technologies, non -split Pellethane penetration or test reduce. As for the UDC <br />that remains in a failed state we propose to dig around the outside of the UDC in order to <br />confirm where the UDC is failing. Then we will make the required repair according to the <br />information submitted herein. <br />If this proposal. meets with your approval, I will ask D & S Dragline to provide you with <br />a sump -by -sump report explaining what has been done to each and what still needs to be <br />