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i�: % IOl 41 <br />BP West Coast Products LLC <br />bp 4519 Grandview Rd:, Bldg. 1 <br />Blaine, WA 98230 <br />Phone: (360) 371-1500 <br />Fax: (360) 371-1684 <br />0 Email: sarah.samuels@bp.com <br />September 25, 2014 <br />Inspector Stacy Rivera <br />San Joaquin County <br />Environmental Health Department <br />1868 East Hazelton Ave. <br />Stockton, CA 95205 <br />REGF1vtt., <br />Subject: Underground Storage Tank Program Inspection <br />Facility #05450 <br />1617 West Fremont St. <br />Stockton, CA 95203 <br />Dear Inspector Rivera, <br />This letter is in response to the Underground Storage Tank Program Inspection Report, dated <br />August 5, 2014, which was issued to the subject facility. Please be advised that the following <br />issues have been addressed: <br />319 Water in secondary containment not removed, analyzed, and properly disposed <br />of (pre -Jul 2003). Per our conversation on September 24, 2014, and as noted in your <br />Inspection Report, the liquid released into the 87 main STP sump upon removal of the test <br />boot during testing was analyzed by the Gettler-Ryan technician on site and found to be <br />water. The technician removed the water from the sump during the inspection. It is unclear <br />why the test boot was not in proper position at the time of the inspection, and further <br />research has not positively determined the source of the problem. However, our policy is to <br />ensure that all piping, sumps, and annular spaces are maintained free of liquid, and we will <br />continue to pursue that standard going forward. <br />321 All releases in secondary piping do not flow to a collection sump. Per our <br />conversation on September 24, 2014, and as noted in your Inspection Report, the test boot <br />on the product line in the 87 main STP sump that was found to be improperly positioned <br />was corrected by the Gettler-Ryan technician during the inspection. It is unclear why the <br />test boot was not in proper position at the time of the inspection, and further research has <br />not positively determined the source of the problem. However, our policy is to ensure that <br />all secondary containment systems are maintained to proper specifications, and we will <br />continue to pursue that standard going forward. <br />As an additional matter, both of the above -referenced violations were noted to be repeat <br />violations; however a review of all Agency inspections back to 2010 did not reveal any such <br />previous violations. Therefore, we respectfully request re-evaluation of this determination. <br />