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lir ,,Mrco IVH L.ESALE July 20 , 2017 Inspector Daniel LaPel San Diego County Department of Environmental Health Hazardous Materials Division P. O . Box 129261 San Diego , CA 92112 Dear Mr. LaPel This letter is in response to your July 13 , 2017 inspection of the Costco gas station in Rancho del Rey, located at 895 East H Street , Chula Vista . The record ID number is DEH 2002- H U P F P- 137226 . There were two alleged Class II violations noted during the inspection , and we believe the facts presented below show the violations are without merit . As such , we respectfully request the violations be vacated . We are available to discuss in more detail at your convenience . Violation #1 : Failure to keep water out of the secondary containment All four of our turbine sumps were cited for having water intrusion , yet the alarm record demonstrates the quantity of water was insufficient to put the liquid sensors into alarm . The monitor certification confirmed that the sensors were working , and that they were properly positioned at the lowest point in the sump . Since we reasonably rely on sensors to alarm if a liquid intrusion is detected , by definition there is no violation if the sensors do not alarm . The very slight water accumulation was likely due to condensation as opposed to the regulated "water intrusion by precipitation , infiltration , or surface runoff. " ( HSC 25290 . 2 ( c ) ( 3 ) Violation #2 : Failure to comply with Designated Operator requirements . . . alarm response documentation . The second alleged violation asserts insufficient documentation of two alarm events ; the first on February 23 , 2017 and the second on April 4 , 2017 . The inspection report states these alarm events were not documented properly by our service provider, Western Pump , and then not addressed by our Designated Operator. The violation report says "The work orders . . . did not specify why alarms were triggered and how they were cleared . " Attached are both service work orders in question . In both cases , the documentation reflects the likely cause of alarms and how each was cleared . Belshire Environmental provides Designated Operator services to Costco , and they concur the record is sufficient . Sensors designed to continuously monitor station performance are sometimes tripped while servicing other aspects of the interconnected system . Both alarm events were documented and explained on the work 999 Lake Drive 0 Issaquah, WA 98027 • 425/313-6061 • Fax 425/417- 2068 • www. costco. com