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r .1 r 0 <br /> Vicki McCartney [EH] <br /> From: Vicki McCartney [EH] <br /> Sent: Monday, August 22, 2016 10:09 AM <br /> To: 'Samuels, Sarah' <br /> Subject: RE:ARCO 5450 (1617 Fremont, Stockton, CA) - Annual Inspection 7/26/16 <br /> Good morning Sarah, <br /> I will certainly discuss this with my management and will get back to you. <br /> Thank you. <br /> Vicki McCartney, Senior REHS <br /> San Joaquin County <br /> Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton, California 95205 <br /> Phone: (209)468-9852 <br /> Email: vmccartney6d sjcehd.com <br /> ,atLiYxk � <br /> a " <br /> t <br /> From: Samuels, Sarah [ma ilto:Sarah.Sam uels(abbp.com] <br /> Sent: Friday, August 19, 2016 4:35 PM <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 /> I <br />