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14.� N-J <br /> all tank sumps and pipe transition sumps. This increases maintenance costs, decreases the <br /> amount of preventive maintenance performed, and creates an additional safety hazard. <br /> The owner has regarding additional concerns with the maintenance of the underground <br /> dispenser sumps and it getting water in it during wash downs in the fueling area. They <br /> want the PMC dispensers because of their performance and low maintenance. The PMC <br /> meter has only 6 points where a leak can occur. <br /> PHI is requesting an interpretation of the code to permit the use of a steel, single wall, <br /> aboveground Bravo Containment Sump. PHI feels the use of a single wall sump <br /> aboveground should be permitted for the following reasons: <br /> - All piping and equipment inside the building is in a containment sump or <br /> double-wall piping. <br /> - The fueling area has a concrete cap which prevents leaks from entering the <br /> environment or flowing outside the building. Leaks in the fueling area drain to <br /> an oil/water separator. <br /> - All leaks can be visually inspected. <br /> - Aboveground secondary pipe is monitored by the Veeder-Root vacuum sensor <br /> and programmed for positive shut down. <br /> - The Bravo single wall sumps will be monitored by a Veeder-Root 208 sensor <br /> and programmed for positive shut down. <br /> - All non-welded piping is contained in containment sumps. <br /> - The current permit drawing(Sheet FS9.02, Detail 1) shows an underground <br /> double wall sump with brine monitoring. We have aboveground DW piping <br /> running into an underground dispenser sump. PHI feels the proposed single <br /> wall aboveground sumps with sensors will pose less risk to the environment <br /> than installing a DW below ground sump exposed to the earth. <br /> - Brine monitoring on all Bravo double wall underground sumps terminates <br /> approximately 13"below finish concrete grade under the dispensers (see <br /> Exhibit 5). The upper 13" of the sump is single wall with no brine monitoring. <br /> PHI believes the aboveground single wall sump being above the finish <br /> pavement would comply with the codes intent as does the single wall portion <br /> of the below grade double walled brine monitor sump. <br /> PHI appreciates the opportunity to receive an interpretation on this matter. The code <br /> currently does not address an installation of this type of hybrid system. PHI believes the <br /> intent of the code is met by our design. PHI takes pride installing code compliant, leak <br /> free, maintainable fueling systems that meet the customer needs. <br /> If you have any questions or require any additional information please feel free to contact <br /> me at 310-345-2016. <br /> Sincerely, <br /> Matthew Bodde <br /> Project Manager <br />