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s �r <br /> January 4,2003 QQ(�L9 <br /> Page 3 1103 <br /> LIST INSPECTION <br /> The following is BP's response to the three items noted during the October 10, 2002 �I^ <br /> underground storage tank (UST) inspection. <br /> • Item 3: CCR 2711(b) & (c) Current State Forms A& B. <br /> The Inspection Report stated that the facility did not possess current State Form B. A copy <br /> of the current State Form B is enclosed as Attachment D. In addition, a copy of the current V" <br /> form is being provided to the facility. <br /> • Item 13: CCR 2635(b)(1) Spill container. 12 <br /> The Inspection Report stated that the spill containers for two of the regular tanks contained <br /> debris in the spill container and had disconnected drain valve chains. As noted in the <br /> Inspection Report, both of these issues were"corrected on site"during the inspection. <br /> Although the items noted by the inspector should not be considered a violation of CCR <br /> 2635(b)(1), it is BP's policy to address these maintenance issues promptly. To facilitate <br /> maintenance of the equipment, BP has requested the lessee-dealer to conduct daily visual <br /> equipment inspections of the spill container. BP has provided the lessee-dealer with a <br /> checklist of items to be inspected. <br /> • Item 20: CCR 2712(b) Maintenance &monitoring records. <br /> The Inspection Report stated that the inspector found one monitoring log for August 2002, <br /> and requested BP to inform employees/managers to provide copies of the past six months <br /> of logs and/or begin completely filling out the daily monitoring log immediately. The <br /> Inspection Report also noted that the facility does not have a printer on the monitoring <br /> panel. <br /> Per the owner-operator agreement between BP and the lessee-dealer, the lessee-dealer is <br /> responsible for implementing the facility Monitoring Response Plan (MRP), which requires <br /> the lessee-dealer to record inspection observations on the Daily Visual Underground <br /> Storage Tank Monitoring Log. BP has reminded the lessee-dealer of this responsibility. <br /> We are not aware of a requirement to have a printer on the monitoring panel at the facility. <br /> • Request for SB-989 testing results. <br /> In the Inspection Report, you requested a copy of the results for the secondary containment <br /> testing conducted on October 2 to 4, 2002 at the facility. BP provided these results to <br /> EHD on November 7, 2002. The results indicate that all secondary containment <br /> components at this facility passed the secondary containment testing. In response to your <br /> request, I am also enclosing a copy of the test results with this letter (Attachment E). <br />