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BTW, what is ARAR? I'm not familiar with the acronym. Best Regards, Jeff Wong -----Original Message----- From: SATRE, RODRICK (ATTSI) [mailto:rs464a@att.com] Sent: Monday, July 19, 2010 5:37 PM To: Jeff Wong [EH) Subject: 345 N. San Joaquin, Stockton CA (SKTNCA01) Inspection Report Importance: High Dear Mr. Wong, I am enclosing a copy of the inspection report you prepared on May 13, 2010. I would like to go over with you some ARAR's related to the entries of <<UE042-110125 (2) .pdf>> #5 - CCR 2632(b) and #33 - HSC 25286(a) [for both our use, I've added those sections of the code below my signature I've tried to see where the regulations are supporting you assessment and where they are conflicted. If possible, I would like to talk to you later today or tomorrow. I will be traveling but available on my cell phone (when in signal range) . (I'm off to a mountain top transmitting station of AT&T near Cisco Grove) I would truly like to discuss this issue with you as AT&T takes these matters seriously as do I. «UST Install.pdf>> <<ustmonplan.pdf>> «UST Response Plan.pdf>> Regards, Rod Satre PST-Sr. PM rs464a@att.com 916-972-2211 (o) 916-992-4451 (c) Re Item #5 California Code of Regulations 2632 (b) : § 2632. Monitoring and Response Plan Requirements for New Underground Storage Tanks Constructed Pursuant to Section 2631. (a) This section is applicable only to underground storage tanks constructed pursuant to the requirements of section 2631. (b) Owners or operators of underground storage tanks subject to this section shall implement a monitoring program approved by the local agency and specified in the underground storage tank operating permit. The program shall include interstitial space monitoring as described in subsection (c) and shall include the items listed in subsection (d) . (c) Monitoring of the interstitial space shall include either visual monitoring of the primary containment system as described in subsection (c) (1) or one or more of the methods listed in subsection (c) (2) . (1) A visual monitoring program shall incorporate all of the following: (A) All exterior surfaces of the underground storage tanks and the surface of the floor directly beneath the underground storage tanks shall be capable of being monitored by direct viewing. (B) Visual inspections shall be performed daily, except on weekends and recognized state and/or federal holidays. Inspections may be more frequent if required by the local agency or the local agency may reduce the frequency of visual monitoring at facilities where personnel are not normally present and inputs to and withdrawals from the underground storage tanks are very infrequent. In these instances, visual inspection shall be made weekly. The inspection schedule shall take into account the minimum anticipated time during which the secondary containment system is capable of containing any unauthorized release and the maximum length of time any hazardous substance released from the primary containment system will remain observable on the surface of the secondary containment system. The inspection schedule shall be such that inspections will occur on a routine basis when the liquid level in the tanks is at its highest. The inspection frequency shall be such that any unauthorized release will remain observable on the exterior of or the surface immediately beneath the underground storage tanks between visual inspections. The evaluation of the 2