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1 • 0 0 <br /> To: Vicki McCartney [EH] <br /> Subject: ARCO 5450 (1617 Fremont, Stockton, CA) - Annual Inspection 7/26/16 <br /> Hi Vicki, <br /> Just wanted to follow up on one of the violations written during the annual inspection at the above-referenced site <br /> regarding water intrusion in the STP sumps. Your specific statement, in pertinent part,was as follows: <br /> HSC 25291(e) Water in secondary containment not removed,analyzed,and properly disposed of(pre-Jul 2003). Water <br /> was found in the 87-product master submersible turbine pump (STP)sump, 87-product siphon STP sump, and 91- <br /> product STP sump. Secondary containment shall be constructed to prevent any water intrusion into the system by <br /> precipitation, infiltration, and surface runoff. <br /> However,the code section cited, HSC 25291(e), states, in pertinent part: <br /> (e) If water could enter into the secondary containment by precipitation or infiltration, the facility shall contain <br /> a means of monitoring for water intrusion and for removing the water by the owner or operator. <br /> Not only does this section not appear to prohibit water intrusion, but in this case,the water found in the STP sumps was <br /> from condensation occurring inside the sumps due to temperature fluctuations in the environment, not by precipitation <br /> or infiltration. This condensation was exacerbated when the system was opened for testing and further exposed to the <br /> external elements. Therefore,the liquid did not originate outside the sumps, but was rather generated within the <br /> environment due to natural factors, and therefore does not meet any of the elements (intrusion, precipitation, <br /> infiltration, or runoff) identified in either analysis above. In addition,the majority of the liquid was produced after the <br /> system was opened for testing, a status not contemplated under this regulation,as it pertains to a closed system. <br /> Lastly, all of the sumps at issue are continuously monitored for liquid infiltration and/or accumulation by 208 sensors, <br /> which are set to positively shut down the site if triggered and prevent any further operations until the liquid is <br /> removed. Therefore, in the event there is water intrusion or infiltration,the second clause of the above-referenced <br /> section has also been met(means of monitoring for water intrusion, etc.). <br /> Based on the analysis above, we respectfully request a rescission of this violation. Will you please review the reasoning <br /> and let me know your thoughts? <br /> Thanks very much! <br /> ,TY6fl! <br /> Sarah Samuels <br /> Retail Compliance Coordinator <br /> BP—Fuels North America <br /> 360.526.3917 Phone <br /> 360.255.9743 cell <br /> This message is intended for review by the named addressee(s)only and may be privileged,confidential or private. If <br /> you are not the named addressee(s),please delete this message and do not retain a copy. Inadvertent disclosure of this <br /> message does not constitute a waiver of any privilege. <br /> 4 <br />