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Thanks, <br /> Daryl Lee <br /> Retail Compliance Coordinator <br /> BP—Fuels North America <br /> 415.902.5089 <br /> From: Hootman, Cory@Waterboards [mai Ito:Cory.Hootman@waterboards.ca.gov] <br /> Sent: Wednesday, October 03, 2018 10:00 AM <br /> To: Lee, Daryl <br /> Cc: Wehner, Jennifer; Henderson, Tom@Waterboards <br /> Subject: RE: Overfill Prevention Equipment Inspection Requirements <br /> Daryl <br /> After our phone discussion today, please let me know if you have any further questions. <br /> CORY HOOTMAN, P.E.-MECHANICAL#37242 <br /> STATE WATER RESOURCES CONTROL BOARD <br /> UNDERGROUND STORAGE TANK LEAK PREVENTION UNIT <br /> 100 1 1 STREET, 1 5T" FLOOR <br /> SACRAMENTO, CA 95814 <br /> PH: (91 6) 341-5668 <br /> The question,Whether one generation of men has a right to bind another Then no man can by natural right oblige the lands he occupied,or the persons who succeed him <br /> in that occupation,to the[payment]of debts contracted by him.For if he could,he might during his own life,eat up the[usefulness]of the lands for several generations to <br /> come,and then the lands would belong to the dead,and not to the living,which would be reverse of our principle. <br /> Thomas Jefferson,Sep.6,1789 <br /> From: Lee, Daryl <DARYL.LEE@bp.com> <br /> Sent:Tuesday, October 2, 2018 9:29 PM <br /> To: Hootman, Cory@Waterboards<Cory.Hootman@waterboards.ca.gov>; Henderson,Tom@Waterboards <br /> <Tom.Henderson @Waterboards.ca.gov> <br /> Cc:Wehner,Jennifer<lennifer.wehner@bp.com> <br /> Subject: RE: Overfill Prevention Equipment Inspection Requirements <br /> Hello Cory and Tom, <br /> I am seeking guidance regarding the requirement to first inspect the overfill equipment by October 13, 2018 [23 CCR <br /> §2637.2(a)(1)(A)]. I have inquired with various CUPAs as to which method will suffice to record this first inspection, but <br /> received different responses without much further clarification. I've summarized the seeming options here: <br /> a. Last annual facility inspection <br /> i. For Audible/Visual alarm only [23 CCR§2635(c)(1)(A)], submit the most recent UST Monitoring System <br /> Certification Report Form <br /> ii. For Ball Float and Audible/Visual alarm [23 CCR §2635(c)(1)(B)], submit the most recent UST Monitoring <br /> System Certification Report Form (for the A/V portion) and most recent BP-specific annual facility <br /> inspection form (for the Ball Float portion, example attached). For the BP-specific checklist,we have our <br /> testing technicians inspect the ball float every year to confirm they are set at 90%of tank capacity. <br /> iii. For Fill Tube Shut-off Valve [23 CCR §2635(c)(1)(C)], submit the most recent BP-specific annual facility <br /> inspection form (example attached). For the BP-specific checklist, we have our testing technicians <br /> inspect the drop tube every year to confirm the flappers are set at 95%of tank capacity. <br /> 2 <br />