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6131 Pacific, Stockton Page 4 of 7 <br /> Regarding the testing question, I want to be sure we are using the same language. We <br /> would like the exposed vent piping tested to show it wasn't compromised. If there is any <br /> other piping that may have been impacted then it should be tested as well. There is no <br /> annual testing requirement for vent or vapor lines from an Environmental Health standpoint, <br /> there may be an APCD annual testing requirement. <br /> If the product piping was impacted (and we don't know that it was)then its secondary <br /> containment should be tested. If the secondary containment of the entire system was tested <br /> then it would not be due again for another 36 months. <br /> I hope I was able to answer your questions. <br /> ---------------------------------------------------------- <br /> Kasey L. Foley, R.E.H.S., Program Coordinator <br /> San Joaquin County Environmental Health Department <br /> 304 E. Weber Avenue <br /> Stockton, CA 95202 <br /> (209)468-3451 <br /> (209)468-3433 Fax <br /> kfoley@sjcehd.com <br /> -----Original Message----- <br /> From: denis.[.brown@shelI.com [mailto:denis.[.brown@shell.com] <br /> Sent: Wednesday, December 06, 2006 9:07 AM <br /> To: Kasey Foley [EH] <br /> Cc: Margaret Lagorio [EH]; Raymond von Flue [EH] <br /> Subject: RE: 6131 Pacific, Stockton <br /> I appreciate your detailed response here and clarification as to why you <br /> are requesting this test. I was not aware the vent lines were exposed, <br /> and my understanding from our consultant was that no UST lines were <br /> exposed during our work. <br /> It appears there was some misunderstanding/interpretation of why you <br /> were requesting this test, and as it was relayed to me, this test would be <br /> a requirement for all work "performed near a UST system" to check to <br /> see if any compromise occurred to the system. Thus, my questions <br /> concerning drilling or other activities near or around UST systems which <br /> we perform on a somewhat regular basis. <br /> So, to clarify, the owner will have to perform a pressure test for <br /> secondary containment for all of the UST system, or only a portion of <br /> the system? <br /> Also, if this test is performed and witnessed, would this test meet his <br /> annual testing such that he would not have to retest again until the <br /> following year? This is an expensive test, the owner claims this will hurt <br /> him financially, particularly if he needs to complete it twice for this <br /> year. <br /> Finally, if my understanding is correct, your permit system will be <br /> changed somewhat in that where ever any work exposes the UST <br /> system, your agency will be notified through Margaret's group. This will <br /> 7/11/2007 <br />