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Vicki McCartney [EH] <br /> From: Lee, Daryl <DARYL.LEE@bp.com> <br /> Sent: Tuesday, February 14, 2017 2:21 PM <br /> To: Vicki McCartney [EH] <br /> Subject: RE: Inspection report for ARCO 06080 <br /> Attachments: PG8_2016_Equipment Checklist.pdf; 85 Louise ARCO 2-1-17 (3).pdf <br /> Hi Vicki <br /> I have some questions or would appreciate your clarification regarding a couple of violations. I'll reference them by item <br /> #105—Yesterday(2/13)our consultant, Belshire, changed the Visual Inspection Records entry in CERS to"Yes" as you <br /> requested. But isn't this particular section in CERS dedicated to the monitoring system,therefore the Visual Inspection <br /> Records entry is for any visual inspection of the monitoring system? This facility only performs daily equipment <br /> inspections(copy attached), which are primarily focused on the dispensers and hanging hardware, not on the <br /> monitoring system itself. In fact there is only one item in the daily inspection checklist pertaining to the monitoring <br /> system (item#21), but even this item only checks to see if the monitoring system is powered on and not in <br /> alarm. Furthermore,the text for this item in the report cites"failed to have an approved UST monitoring plan." Our <br /> CERS submittal was 'Accepted'just last month (1/11/2017) by Willy Ng. Please advise? <br /> #201—This is the first time I've been made aware of failure to maintain alarm logs, so please excuse my <br /> inquisitiveness! As you know,the facility stores the alarm records in the Veeder-Root Monitoring Panel. Each month <br /> the DO prints out the alarm history from the panel, reviews, and provides documentations or explanation for actions <br /> taken for each alarm. It is my understanding that the facility is not required (at least by federal/state law or regulation) <br /> to keep a separate, handwritten, log of alarms if the aforementioned DO activities are performed. The regulations Title <br /> 23 CCR 2712(b) do not specify what form the alarm records must be maintained either. Does the Veeder-Root <br /> Monitoring System not satisfy the requirement to maintain alarm records? Furthermore,the associated entry in CERS <br /> (under Monitoring Plan—Recordkeeping) is presented as "Alarm Logs" and does not provide guidance or criteria. Please <br /> advise? <br /> I greatly appreciate your assistance with this. Feel free to call me to discuss or if you have any questions. Thanks in <br /> advance! <br /> Daryl Lee <br /> Retail Compliance Coordinator <br /> BP—Fuels North America <br /> 415.902.5089 <br /> From: Vicki McCartney [EH] [mailto:vmccartney(cbsjcehd.com] <br /> Sent: Friday, February 10, 2017 8:54 AM <br /> To: Lee, Daryl <br /> Cc: kaylynn.rammell@belshire.com <br /> Subject: Inspection report for ARCO 06080 <br /> Hello Daryl and Kaylynn, <br /> 1 <br />