Laserfiche WebLink
1000 FedEx Drive <br /> Moon Township, PA 15108 <br /> 1.412.262.6291 TEL <br /> 1.412.874.2977 CELL <br /> 1.412.859.2232 FAX I V, <br /> fedex.comlus <br /> DEC 202017 <br /> From: Betty Ho [EH] [mailto:bho@sjcehd.com] <br /> Sent: Wednesday, December 20, 2017 12:02 PM ENVIRONMENTAL HEALTH <br /> To: Debra Gehm <debra.gehm@fedex.com> "PARTMENT <br /> Subject: RE: 5655 Hood Way,Tracy, CA_fuel filter outside UDC footprint issue <br /> Good morning Debra, I have attached a non-compliance letter and the attached letter will also be mailed out. These are <br /> the remaining items that still needs to be addressed for the site. If you have any questions, please feel free to contact <br /> me. <br /> From: Elena K. Manzo [EH] <br /> Sent: Wednesday, December 6, 2017 12:08 PM <br /> To: Muniappa Naidu [EH] <Mnaidu@sjcehd.com>; Gaylyn Frosini <gaylyn.frosini@fedex.com>; Debra Gehm <br /> <debra.gehm@fedex.com> <br /> Cc: Betty Ho [EH] <bho@sicehd.com>; Garrett Backus [EH] <gbackus@sicehd.com>; Michelle D. Henry [EH] <br /> <mhenry@sicehd.com> <br /> Subject: RE: 5655 Hood Way,Tracy, CA_fuel filter outside UDC footprint issue <br /> Hi Debra, <br /> Thank you very much for your email indicating that FedEx"would not be obligated to retrofit"their system "until such <br /> time that the Water Board makes a formal decision and proposes these modifications to the California Health &Safety <br /> Code". I would like to offer some additional information to clarify the issue of the installed fuel filters and piping <br /> (installed outside their respective UDC footprint's) a little further: <br /> 1) Attached please find the EHD correspondence to FedEx dated 8-17-2016, which indicated "If the Water Board <br /> comes back with a determination that piping and filters must be contained within the under dispenser <br /> containment (UDC} footprint, FedEx must immediately cease operations until the piping and filters can be <br /> reconfigured under permit from my department."Attached please also find FedEx's response,dated 8-17-2016, <br /> with assurances in connection to the aforementioned email correspondence. <br /> 2) Per the Title 23 definitions(section 2611): "Under-Dispenser spill containment or control system" means a <br /> device that is capable of preventing an unauthorized release from under the dispenser from entering the soil or <br /> groundwater or both." Furthermore, "Dispenser" means an aboveground or underground device that is used for <br /> the delivery of a hazardous substance from an underground storage tank. Dispenser includes metering and <br /> delivery devices, and fabricated assemblies located therein. UDCs provide secondary containment for the piping <br /> within the dispenser which means if there is a release from within the dispenser, it must be contained by the <br /> UDC to be detected and cleaned up. (Health and Safety Code, chapter 6.7, sections 25290.1(c)(2) &(d), <br /> 25290.2(c)(2) & (d), or 25291(a)(2) & (b) and California Code of Regulations,title 23,chapter 16, sections 2611. <br /> Under-dispenser containment.) <br /> 3) Also, per HSC 25292.1(a)-All underground tank systems shall meet the following operational requirements: (a) <br /> The underground tank system shall be operated to prevent unauthorized releases, including spills and overfills, <br /> during the operating life of the tank, including during gauging, sampling, and testing for the integrity of the tank. <br /> 4) Attached please find the State Water Resources Control Board documentation (CLARIFICATION OF EXISTING <br /> REGULATIONS FOR UNDER-DISPENSER CONTAINMENT) according to which, "If the piping within the dispenser <br /> extends beyond the footprint of the UDC,two options exist: 1. Replace the existing UDC with a new UDC, that <br /> encompasses the entire dimensions of the dispenser,or 2. Install a State Water Board approved under- <br /> dispenser spill containment or control system that will direct leaks from all dispenser piping into the existing <br /> Z <br />