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February 27, 2012, of the intention to perform the final SB 989 test on March 6, <br />2012. A UST Service Request Inspection report cannot be located by PFJ, Jones <br />Covey, or the EHD for March 6, 2012, therefore the six-month follow up requirement <br />for the T-5 91 octane turbine sump was not communicated to PFJ. As a result, the <br />six-month follow up testing was not completed for these two components. <br />PFJ and Jones Covey work very closely to maintain compliance with all County and <br />Regional regulations, and Jones Covey was in contact with the EHD throughout this <br />time to ensure that all repairs and retesting were performed to the satisfaction of the <br />Inspector. Additionally, all retesting was witnessed by Muniappa Naidu with the EHD <br />and the six-month follow up testing was not discussed as a requirement. The final <br />test report was submitted to the EHD and presumably accepted. <br />Although PFJ respects the EHD's interpretation of the regulations regarding SB 989 <br />testing, it is PFJ and Jones Covey's understanding that this type of testing is required <br />following the installation of new components and not a repair of individual <br />components. After conversations between PFJ, Jones Covey, and the EHD, the <br />components in question were retested and passed on June 6, 2013. The report was <br />submitted to the EHD and a copy is enclosed for your review. <br />2. Maintenance records for L1 and L3 alarms on 11-18-12 were not found on site. <br />These records shall be kept on site for at least 3 years. Immediately locate and <br />maintain the maintenance records on site and submit copies to the EHD by June 29, <br />2013. <br />The L1 and L3 alarms on 11-18-12 were determined by store personnel to be caused <br />by rainwater intrusion. The alarms were also captured remotely by the PFJ <br />HelpDesk who contacted the store and verified the cause of the alarm. Since the <br />water was removed by a PFJ employee, there are no maintenance records available. <br />3. The designated operator failed to document all the alarms from the attached alarm <br />history on the designated operator monthly inspection reports and failed to check <br />that they were responded to appropriately. The missing alarms include: L3: 11-18-12 <br />and L28: 3-11-13. During the monthly inspection, the designated operator shall <br />review the alarm history for the previous month, check that each alarm was <br />documented and responded to appropriately, and attach a copy of the alarm history <br />with documentation taken in response to any alarms to the monthly report. Ensure <br />that designated operators performing monthly inspections at this facility are including <br />all of the required information on the reports. <br />Although the designated operator failed to document the L3 and L28 alarms <br />appropriately on the respective monthly inspection reports, PFJ feels that each of <br />these alarms were responded to correctly. As previously stated, the L3 alarm on <br />November 18, 2012, was caused by rainwater intrusion. The PFJ HelpDesk <br />captured the alarm and worked with store personnel to determine the cause. <br />Additionally, the designated operator performed a visual inspection of this sump on <br />December 13, 2012, and noted that it was free of water, debris and hazardous <br />substances, as well as verifying that the sensor was in the proper position. Although <br />this specific alarm was logged by store personnel on the Daily UST Monitoring <br />