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DocuSign Envelope ID : 8CE92D2A-3F50-43AD-8C8D- 1E49DDAB6D53 <br /> Shewit Woldearegay <br /> Environmental Health Department <br /> San Joaquin County -2- May 19 , 2020 <br /> In March and May 2017 , San Joaquin DEH issued two similar "water intrusion " violations at our stations in <br /> Lodi and Stockton . Costco sent letters protesting those violations ( attached) , making two points : <br /> 1 . The moisture was not intrusion , but condensation . <br /> 2 . Moisture insufficient to trigger an operable , properly-placed liquid sensor should not be a <br /> violation . <br /> In August 2017 , Costco received a response from Vicki McCartney of the San Joaquin DEH disputing our <br /> position , but without specifically addressing the substance of our argument (attached) . Plainly, small <br /> amounts of condensation do not mean that water is being " stored " in our secondary containment sumps. <br /> To our knowledge , the DEH took no further action related to these violations . Yet notably , the May 7 <br /> inspection is shown as a repeat violation . <br /> Concerned about this issue in 2017 , we asked the State Water Resource Control Board for clarification . At <br /> the 2018 CUPA conference , Laura Fisher of SWRCB showed a slide (attached) titled "Water Intrusion . " <br /> Since Laura ' s slide and comments confirmed Costco' s position , we didn ' t follow up until the repeat violation <br /> was issued on May 7 . <br /> These alleged violations do not adversely affect the environment, the proper operation of our secondary <br /> containment and monitoring systems, or human health . Sending employees or contractors into these <br /> confined spaces to wipe up condensation would add risk where none is warranted . We believe that if the <br /> inspection had been conducted in the late afternoon , much of this condensation would have evaporated <br /> into vapor phase . <br /> Costco takes our compliance record seriously , and we operate our stations in the safest and cleanest <br /> manner possible . We ask that San Joaquin DEH rescind these violations , and that no future " liquid intrusion " <br /> alarms be written for quantities of sump water insufficient to trigger a properly-placed liquid sensor. <br /> Respectfully , <br /> DocuSlyned by: <br /> 41 <br /> �uE 196 44A7... <br /> Im r�oc�Cer <br /> Director of Fuel Quality and Compliance <br /> Costco Wholesale <br /> (425) 313 -6010 <br /> thurlocker@costco . com <br /> TH/N L/hd <br /> 12919c . 091 . docx <br />