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(VPH) components listed above under permit and inspection by the Environmental Health
<br /> Department (EHD). On February 28, 2017, BP Testing and Maintenance Vendor, Gettler-
<br /> Ryan, Inc., tested communication of the liquid filled annual spaces of all UDCs, vent sump,
<br /> all fill sumps, and all turbine sumps with San Joaquin County inspector Garrett Backus
<br /> onsite. Inspector Garrett Backus issued his Inspection Report stating tests to verify
<br /> communication were successful. His inspection report, as well as the Monitoring System
<br /> Certification Form: Addendum for Vacuum/Pressure Interstitial Sensors, are enclosed herein
<br /> for your review and records.
<br /> • Seepage was observed at the union/shear valves at under dispenser containments 1-2
<br /> and 7-8, indicating a leak in the primary piping. All primary containment for the UST
<br /> system must be tight. Immediately have a properly licensed, trained, and certified
<br /> contractor repair or replace the failed components. On February 23, 2017, BP Testing and
<br /> Maintenance Vendor, Gettler-Ryan, Inc., inspected the shear valves for leaks and ran a
<br /> manual leak test to search for leaks, but ultimately did not observe any leaks. The
<br /> technicians then tightened the unions on the shear valves in UDCs 1-2 and 7-8 in order to
<br /> ensure proper seals. A copy of Gettler-Ryan's work order, as well as a picture showing
<br /> completion of work, is enclosed herein for your review and records.
<br /> • Approximately one-half cup of liquid was observed in the 87-product submersible turbine
<br /> pump (STP) sump, approximately one quart of liquid was observed in the diesel STP sump,
<br /> approximately one-half cup of liquid was observed in the diesel fill sump, approximately
<br /> one-half cup of liquid was observed in the 91-product STP sump, a trace of liquid was
<br /> observed in the under dispenser containment (UDC) 1-2, approximately one-half cup of
<br /> liquid was observed in UDC 3-4, and approximately three cups of liquid were observed in
<br /> the vent box. Secondary containment shall be constructed to prevent any water intrusion
<br /> into the system by precipitation, infiltration, or surface runoff. Immediately remove this
<br /> liquid, make a hazardous waste determination per Title 22 hazardous waste regulations,
<br /> and manage accordingly. Immediately contact a properly licensed, trained, and certified
<br /> contractor to address the water intrusion into the sumps, UDCs and vent box listed above.
<br /> BP Testing and Maintenance Vendor, Gettler-Ryan, Inc., removed all liquids in the sumps,
<br /> UDCs, and vent box at the time of the Monitoring System Certification on February 1, 2017.
<br /> The liquids were placed in the 30-gallon hazardous waste drum onsite. Pictures showing
<br /> completion of work are enclosed herein for your review and records.
<br /> The diesel secondary containment fill sump is not liquid and vapor tight. The gasket for
<br /> the inner sump opening is missing. Secondary containment shall be impervious to the
<br /> liquid and vapor of the substance contained and constructed to prevent structural
<br /> weakening as a result of contact with any hazardous substances released from the
<br /> primary containment. This same violation was reported during the 2016 monitoring
<br /> system certification inspection and still has not been corrected. Immediately contact a
<br /> properly licensed, trained, and certified contractor to replace the gasket for the inner
<br /> sump opening of the diesel fill sump. On February 28, 2017, BP Testing and Maintenance
<br /> Vendor, Gettler-Ryan, Inc., replaced the gasket for the diesel fill sump. A copy of Gettler-
<br /> Ryan's work order, as well as a picture showing completion of work, is enclosed herein fp,r
<br /> your review and records. REG
<br /> MAR 0 9 2017
<br /> ENVIRONMENTAL HEALTH
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