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• 0 1 did,discuss.with management your request to rescind violation 315 of the inspection report for monitoring system certification, spill container, and line leak detector testing completed on July 26, 2016 at ARCO 05450 at 1617 West Fremont Street, Stockton, CA. As noted in the inspection report,the service technician removed approximately two cups of water from the 87-product master STP sump, approximately one cup of water from the 87-product siphon STP sump and approximately one cup of water from the 91-product STP sump. It is the responsibility of the facility to routinely inspect these sumps and remove any liquid if found. Liquid should not be allowed to accumulate in any of the sumps. This is the reason that the facility received violation 315. 1 respectively decline your request to rescind violation 315. Vicki McCartney, Senior REHS San Joaquin County Environmental Health Department 1868 East Hazelton Avenue Stockton, California 95205 Phone: (209)468-9852 Email: vmccartney(cDslcehd.com From: Samuels, Sarah [mailto:Sarah.Samuels(@bp.com] Sent: Friday, August 19, 2016 4:35 PM To: Vicki McCartney [EH] Subject: ARCO 5450 (1617 Fremont, Stockton, CA) - Annual Inspection 7/26/16 Hi Vicki, Just wanted to follow up on one of the violations written during the annual inspection at the above-referenced site regarding water intrusion in the STP sumps. Your specific statement, in pertinent part,was as follows: HSC 25291(e) Water in secondary containment not removed, analyzed,and properly disposed of(pre-Jul 2003). Water was found in the 87-product master submersible turbine pump (STP)sump, 87-product siphon STP sump, and 91- product STP sump. Secondary containment shall be constructed to prevent any water intrusion into the system by precipitation, infiltration, and surface runoff. However, the code section cited, HSC 25291(e), states, in pertinent part: (e) If water could enter into the secondary containment by precipitation or infiltration, the facility shall contain a means of monitoring for water intrusion and for removing the water by the owner or operator. Not only does this section not appear to prohibit water intrusion, but in this case,the water found in the STP sumps was from condensation occurring inside the sumps due to temperature fluctuations in the environment, not by precipitation or infiltration. This condensation was exacerbated when the system was opened for testing and further exposed to the external elements. Therefore,the liquid did not originate outside the sumps, but was rather generated within the environment due to natural factors, and therefore does not meet any of the elements(intrusion, precipitation, infiltration, or runoff) identified in either analysis above. In addition,the majority of the liquid was produced after the system was opened for testing, a status not contemplated under this regulation, as it pertains to a closed system. Lastly, all of the sumps at issue are continuously monitored for liquid infiltration and/or accumulation by 208 sensors, which are set to positively shut down the site if triggered and prevent any further operations until the liquid is 3