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dams <br />recision <br />Qnstrumentation, co. <br />4-15-94 A.P.I./ROMAN LEAK DETECTION SYSTEMS <br />Kasey Foley <br />County of San Joaquin Environmental health <br />PO Box 2009 <br />Stockton, CA 95202 <br />Subject: Shell Oil facilities with manifolded 5,000 gallon product tanks and existing APYRonan <br />X76ETM leak detection systems <br />Dear Mr. Foley: <br />In a recent telephone conversation we discussed the dilemna that the State Water Rescources Control <br />Board has put us in regarding monitoring manifolded single wall product tanks. To briefly summarize <br />many of our customers including Shell Oil were forced to effect a monthly monitoring program to meet <br />the January 1, 1993 deadline for tanks with a ground water table within tweny feet of the tank bottom. <br />Most agencies including San Joaquin approved automatic tank gaging for this monthly monitoring <br />compliance. The dilemna is that there was no restriction for applying automatic tank gaging to manifolded <br />tanks at the time of permitting and installing this equipment. The State Water Rescources Control Board, <br />which has never to my knowledge provided a written restriction to applying tank gaging to manifolded <br />tanks, has only verbally indicated concerns for this application well after the January i, 1993 deadline. <br />Enclosed you will find a copy of our third party evaluation which clearly states our ability to monitor <br />manifolded tanks. We had this evaluation performed in response to the concerns of Carol Oz with your <br />agency. I am hoping that with this third party report you can allow automatic tank gaging on manifolded <br />tanks in your jurisdiction. <br />At a very minimum, I am requesting that you allow all equipment currently installed on manifolded tanks <br />to be approved monthly monitorings systems. The following is a list of the Shell Oil sites in your county <br />where we have the X76ETM performing monthly monitoring on manifolded tanks: <br />2575 Country Club, Stockton <br />2494 E. Fremont, Stockton <br />4315 Waterloo Rd., Stockton <br />880 Victor Rd., Lodi <br />Thank you for your consideration of this issue. <br />Sincerely, <br />Bill Bunch <br />API/Ronan <br />cc Karen Clark, Shell Oil Company <br />JR <br />SALES/SERVICE & SHIPPINGIRECEIVING 9 2300 E. Artesia Blvd., Long Beach, CA 90805 a 310-984-5380 • FAX 310-984-5390 <br />N.W. REGIONAL OFFICE a 3031 Tisch Way, Suite 200, San Jose, CA 96128 • 408-244-6739 a FAX 408-244-6801 <br />S.W. REGIONAL OFFICE • 13194 Veterans Memorial, Suito 190', Houston, TX 77014 • 713-537-6309 • FAX 713-537.9449 <br />ZO'd 2ZO'oN VT:ST b6,SZ 21dd T62S-V86-OT2:GI ***NdNO2/Idd <br />