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®EInIUM,Q 9111011N AIL <br /> ram <br /> uuwou <br /> 81rsIw 01IR <br /> w� ®I[.�I <br /> State Water Resources Control Board <br /> February 2, 2012 <br /> To: Certified Unified Program Agencies and Participating Agencies <br /> COSTCO WHOLESALE STATEWIDE PROJECT TO INSTALL UST FOR THE <br /> STORAGE OF PROPRIETARY FUEL ADDITIVE ULTRAZOL 9888 <br /> Costco Wholesale (Costco) is seeking to obtain permits from various Certified Unified <br /> Program Agencies and Participating Agencies (CUPAs) to install a 1,500-gallon <br /> underground storage tank (UST) at approximately 80 of their existing gasoline fueling <br /> facilities. To assist with expediting the permitting process with the CUPAs, Costco has <br /> requested that State Water Resources Control Board (State Water Board) staff review <br /> the proposed tank, piping, and leak detection equipment for compliance Title 23, <br /> California Code of Regulations (UST Regulations), sections 2631 and 2643 as it relates <br /> to the storage of Ultrazol 9888 (Ultrazol). <br /> Title 23, CCR Section 2631 <br /> State Water Board staff reviewed various technical documents, independent testing <br /> reports, affirmative statements of compatibility, and Material Safety Data Sheets for <br /> Ultrazol. From these sources, it is our understanding that Ultrazol consists of the same <br /> constituents that are already used in gasoline, and that the constituent make up of <br /> Ultrazol is similar to materials used in the evaluations of tanks and piping. The <br /> independent testing organization approvals for the proposed components are not <br /> specific to this fuel additive and concentration, therefore the requirements of section <br /> 2631 of the existing UST Regulations are not fully satisfied. <br /> As you are aware, the State Water Board has proposed amendments to section 2631 of <br /> the UST Regulations that will allow the use of a manufacturer affirmative statement of <br /> material compatibility under certain circumstances. The affirmative statements of <br /> compatibility provided by the manufacturers on behalf of Costco, in conjunction with the <br /> independent testing organization approval for petroleum products, appears to meet the <br /> requirements of the proposed regulation. Manufacturer statements of material <br /> compatibility reviewed include: Containment Solutions UST (Novolac Vinyl Ester Resin <br /> System), Ameron International piping (Dualoy 3000/L), and Flexing flex-connector <br /> (Fireflex). <br /> CN nw R. HOPPIN,CHMMM I THOMAs HowARo,EXECUTIVE DIRECTOR <br /> 1 ODI I shoot.Saaomonto.CA 05814 I Malling Address:P.O.Box 100,Saaamonlo.CA 05812-0100 I w .wotarboards.ca.gw <br /> (�s[crcuoPwu <br />