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Jeff Wong [EH] From: Jeff Wong [EH] Sent: Wednesday, September 10, 2014 4:15 PM To: 'Dan Peterson'; 'SMcBride@McCarthy.com' Cc: Culbertson, Pamela (PCulbertson@McCarthy.com); 'Fuller,Jeffrey'; Raymond von Flue [EH]; Kasey Foley [EH];Willy Ng [EH]; Garrett Backus [EH] Subject: RE: Sump installation Dan,Steve, everyone at McCarthy: This email is to reiterate EHD'S position on several items Steve inquired about on 9/9/2014. Steve phoned me yesterday inquiring if the UDC for the aboveground piping can be at grade or does it have to be built on a pad. I first confirmed that if it's the UDC(Bravo Transition sump) for the piping coming out of the underground portion into the solenoid valve at the filter room (FS9.01, Diagram 3),then it's permissible because it's surrounded by a 6 inch curb. The reason that it is acceptable for the UDC to be at grade in this case is because the 6 inch curb meets UDC construction requirement under Title 23: 2636(8)(2) UDC shall be designed constructed, installed and monitoring in accordance with section 2631,2636(c)2, 2636(e), and 2636(g)l(A)or(8) 2631(d)(5) The floor of the secondary containment system shall be.... sloped to a collection sump... access casings shall be installed in the sump and sized to allow removal of collected liquid. The access casing shall.... be enclosed in a surface security structure that will protect access casings from entry of surface water, accidental damage... Afterwards,Steve asked me about the diagram on FS9.02. To which I replied only the UDC in the filter room with the 6 inch curb all around can be at grade.Anything else has to be either on a pad, or protected in a structure that meets Title 23 Section 2636(g)(2)and 2631. Since the diagram on FS9.02 is not the UDC in the filter room but one at the dispenser, installing the UDC at grade and not on a pad is not acceptable. I confirmed this position in a separate phone conversation with Dan on 9/10/2014. Steve also asked about the prospect of placing a concrete structure in the tank pit for the UST to sit on. I told Steve if it has 4 connecting walls and bottom and meets the definition of a tank in a vault,then it would require complete revision to the work plan, resubmittal of all the application, and re-approval from the EHD before installation can proceed. If it's just a single bottom pad, EHD would require submittal of official document from the UST manufacturer certifying that installing their UST on a concrete pad is acceptable to them before proceeding with such a step. At last, I mentioned to both Steve and Dan that the diamond plate over the UDC on FS9.01, Diagram 3 is not acceptable since it may prevent collection of a release. As an example, I pointed out an acceptable alternative would be the grated plate as described on FS9.02 Finally,any significant changes to the approved work plan would require submittal of the revision to the work plan and approval from EHD before any such change can proceed. Best Regards, Jeffrey Wong Sr REHS 1