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/ . 0 0 Vicki McCartney [EH] From: Samuels, Sarah <Sarah.Samuels@bp.com> Sent: Monday, August 22, 2016 4:40 PM To: Kasey Foley [EH];Vicki McCartney [EH] Cc: Garrett Backus [EH]; Stacy Rivera [EH]; Michelle D. Henry [EH] Subject: RE: ARCO 5450 (1617 Fremont, Stockton, CA) -Annual Inspection 7/26/16 Hi Kasey, Thanks very much for the response and explanation, I really appreciate the reconsideration. My understanding of the situation from the statements of the technicians on site is that the water found upon opening the sumps was predominantly appreciable as"sweating" on the pipes and turbines themselves, not sitting in the sumps, and then later accumulated with excess condensation thereafter, ultimately resulting in the small amount of total water removed. However, I understand your reasoning. I still believe this comes down to our respective reading of the regulations, but I appreciate your willingness to review the issue. Thanks again, Q3crdh Sarah Samuels Retail Compliance Coordinator BP—Fuels North America 360.526.3917 phone 360.255.9743 cell This message is intended for review by the named addressee(s)only and may be privileged,confidential or private. If you are not the named addressee(s),please delete this message and do not retain a copy. Inadvertent disclosure of this message does not constitute a waiver of any privilege. From: Kasey Foley [EH] [mailto:KFoley@sjcehd.com] Sent: Monday, August 22, 2016 4:08 PM To: Samuels, Sarah; Vicki McCartney [EH] Cc: Garrett Backus [EH]; Stacy Rivera [EH]; Michelle D. Henry [EH] Subject: RE: ARCO 5450 (1617 Fremont, Stockton, CA) -Annual Inspection 7/26/16 Hello Sarah, It is our practice to cite this violation because we don't know how long the liquid has been stored inside the sump and because it doesn't always trigger the sensor to alarm. I have read your emails and I don't find information indicating how long the liquid has been stored in the sump with the exception of your statement that"the majority of liquid" was caused by technicians opening it for testing. And I'm not sure how this was determined. Your analogy that the liquid in the sump "is akin to rain accumulation due to a passing shower" indicates the liquid was not in the sump before the testing,that it appeared only during the testing and was then removed at the end of the testing. This doesn't appear to be consistent with what was observed by the EHD inspector onsite. If this was the case there would be no citation for violation#315. 1