HomeMy WebLinkAboutMINUTES - 06101986 - 1.57 To BOARD OF SUPERVISORS 1-057
FROM: Phil Batchelor Contra
County Administrator Costa
DATE: June 4, 1986 l rl�. *
SUBJECT: Implementation of Underground Tank
Inspection Program
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMMENDATION:
Acknowledge receipt of attached status report from Health
Services Director in response to Board referral of April 8, 1986.
BACKGROUND-
On April 3 , 1986, Supervisor Torlakson wrote to this office and
the Health Services Department bringing to the attention of both
offices a specific instance in which an individual was unclear
how to comply with new State laws and regulations pertaining to
the permitting of underground storage tanks.
The individual, Mr. George Clemonds, appeared before the Board of
Supervisors on April 8, 1986 and described the problems he had
had in having his underground storage tank removed once he
determined .it would be too expensive to keep it and have it
permitted. The Board requested an explanation of why the
apparent confusions had occurred.
In response, the Health Services Director has forwarded the
attached report in the form of a status report, commenting on the
particular facts involving Mr. Clemond' s situation and indicating
that a comprehensive report on the development and current status
of the underground tank enforcement program will be available
within 30 days. This more comprehensive report will be forwarded
to the Board with recommendations as soon as it is received.
CONTINUED ON ATTACHMENT: ', YES SIGNATURE:
�/1
X RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
X APPROVE OTHER
SIGNATURE(S):
ACTION OF BOARD ON June 10, 1986 APPROVED AS RECOMMENDED OTHER
VOTE OF SUPERVISORS
�— 1 HEREBY CERTIFY THAT THIS IS A TRUE
UNANIMOUS (ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: . ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN,
County Administrator
cc: Health Services Director ATTESTED
Dir. , Env. Health PTCHELOR, CLERK OF THE BOARD OF
Auditor-Controller SUPERVISORS AND COUNTY ADMINISTRATOR
Mr. George Clemonds aM382/7-83 BY G. DEPUTY
� f
75 i CONTRA COSTA COUNTY
HEALTH SERVICES DEPARTMENT
To: Board of Supervisors
via: Phil Batchelor, County Date: May 14, 1986
Administrator
From: Mark F i nucane, Dire or Subject:
Health Services Department,OQ,,,�� COMPLAINT BY GEORGE CLEMONDS
By: Dan Bergman, Assistant Hea th TO SUPERVISOR TORLAKSON
Services Director - Environmental Health
The purpose of this memorandum is to address the frustrating circumstances
detailed by Mr. George Clemonds to your Board concerning the process he
experienced while attempting to comply with requirements of the "Sher" Bill
and County Ordinance Code regarding his underground fuel storage tank.
I would like to express my regret for the lack of coordinated response that
Mr. Clemonds experienced and my inability to resolve his concerns during
our initial discussions following his referral to me by Supervisor
Torlakson on these issues.
The State Water Resources Control Board regulations were in the process of
being developed from 1984 through final adoption on August 12, 1985. The
site specific requirements for implementing the underground tank law are
contained in these State regulations and our jurisdiction in cities was
limited to new facility installations prior to the promulgation of these
State regulations. There are also a variety of exemption provisions that
evolved including the following categories:
• Motor vehicle fuel tanks located on farms used to fuel vehicles
used primarily for agricultural purposes;
° Home heating oil tanks of less than 1100 gal . capacity;
° Tanks located at an airstrip and used to fuel aircraft for
agricultural purposes;
° Tanks used to contain chemicals to control parasites on
livestock in agricultural operations.
In addition, specific statutory compliance dates were pushed back several
times as a consequence of subsequent cleanup legislation based primarily on
the failure of the State Water Resources Control Board to meet their statu-
tory deadlines for adopting the implementing regulations.
A-41 3/81
-2-
Environmental Health Enforcement Policy is generally predicated on
enforcing one legislative standard in both the unincorporated territories
of the County and the incorporated cities. Consequently, specific policy
and enforcement activities were not implemented for existing facilities
until the State regulations were adopted, thereby, extending our jurisdic-
tion over existing facilities to the cities as well . Interpretation and
clarification of State regulations for compliance also depends to some
extent on local site specific problems coming to our attention such as the
circumstance detailed to me by Mr. Clemonds. It is always our enforcement
intent to provide reasonable compliance times with minimal impact on regu-
lated parties to the extent we can assure responsible compliance with the
legislative mandates and absent a problem presenting a clear and present
public and/or environmental health danger.
Mr. Clemonds presented the following concerns in seeking my advice
regarding his compliance options: -
° Mr. Clemonds had one underground gasoline fuel storage tank
used to service his private vehicles;
° His facility appeared on our list from the Regional Water Quality
Control Board because he complied with his requirement to report
this underground tank in a RWQCB Survey conducted in 1985 as
required by the Cortese Bill ;
° Mr. Clemonds was exploring his costs and options to determine
whether to retain or abandon this underground tank;
° He wanted to know if any exemptions applied to his use as he
also has several acres under cultivation;
° Mr. Clemonds wanted to know whether soil samples and laboratory
analysis would be required if he elected to abandon his tank.
I met with Mr. Clemonds to discuss his compliance options on or about Feb.
10, 1986. It became clear to me that there was a need to further discuss
the matter with Mr. Benike in light of his prior conversations with Mr.
Clemonds and a probable need to discuss exemption options with the State
RWQCB staff to obtain their concurrence on any interpretations of State
regulations that would facilitate Mr. Clemonds preferences. Mr. Benike was
on vacation during the date of my conversations with Mr. Clemonds.
Consequently, I told Mr. Clemonds that I would discuss compliance options
with Mr. Benike upon his return the following week and with State Water
Resources Control Board staff if necessary and then get back to him with
our conclusions shortly thereafter. I did assure Mr. Clemonds that he
would not be subjected to enforcement action by the Environmental Health
Division during the interim pending my' obtaining clarification on the rele-
vant issues and reaching subsequent agreement with him. I also advised Mr.
Clemonds that he would likely receive subsequent notification from the
County Auditor-Controller's Office in the near future as this billing and
-3-
followup process was now automatic. In an effort to prevent the subsequent
frustrations and uncertainties described by Mr. Clemonds to your Board, I
also advised him to hold all subsequent communications directed from our
regulatory process and to communicate with me on these issues pending my
clarification of his compliance options and possible exemption under the
State Law and County Ordinance. I again assured Mr. Clemonds that enfor-
cement action would not be initiated against him by Health Services prior
to our having the opportunity to clarify and resolve all pending issues of
concern and reaching a compliance agreement.
With respect to the inspections conducted by fire services, I was not per-
sonally aware of these requirements when I talked with Mr. Clemonds. I sub-
sequently learned in discussions with Mr. Benike that fire services inspect
abandoned underground tanks to assure proper handling and disposal in light
of potential fire and explosion hazards pursuant to the Uniform Fire Code.
This requirement is being added to the press release that will be sent out
shortly advising the public of issues relating to the underground tank
inspection program at the request of Supervisor Torlakson.
I discussed Mr. Clemonds' compliance options with Mr. Benike when he returned
from vacation. The exemptions do not apply to Mr. Clemonds' underground
tank. Soil samples are expressly required by State regulations. Uniform
Fire Code provisions expressly apply to underground tank removal , transport
and disposal . Mr. Benike clarified these requirements with Mr. Clemonds
and his underground tank has been removed at Mr. Clemonds' election.
Program development and implementation on this scale involving over 1200
facilities and approximately 4000 underground tanks County-wide seldom
occurs without some confusion. Timing and coordination is difficult with
multiple jurisdictional responsibilities and when regulations are awaiting
State adoption and promulgation. We have been regulating new facilities
and tank abandonments for well over a year and have delayed full enfor-
cement of the Sher Bill involving facilities existing prior to 1984 due to
a compliance deadline that the State legislation has pushed back to
September, 1986. Permitting each. facility, however, is fully underway.
We are attaching information that had been sent to each facility owner for
their information.
It is unfortunate that Mr. Clemonds was caught in the early stages of this
program field enforcement; however, his calling attention to the process
issues that impacted him has been helpful to me in dealing more effectively
with our compliance process.
A comprehensive report on the development and current status of the
underground tank enforcement program is being drafted and will be directed
for your review and information within the next thirty days.
DB:cbc
(1 )Clemonds
Contra Health Services Department
Costa ENVIRONMENTAL HEALTH DIVISION
County
January 13 , 1986
Dear Underground Tank Owner :
As you may be aware , the State Legislature has recently
enacted legislation requiring the permitting and inspection of
most underground hazardous substance storage tanks in California.
A brief outline of this legislation is as follows:
(9/23/83) - Sher Bill (AB 1362) effective. Required inspection
and permitting of underground tanks used for the storage of
hazardous substances. Permits when issued will be valid for five
(5) years and are transferable.
( 1 / 1 /84 ) - Cortese Bill (AB 2013 ) effective. Required tank
registration with the State Water Resources Control Board. (This
mailing is based on the tank registration).
( 8/ 12/85) - State regulations written by State Water Resources
Control Board adopted. Dates set in Sher Bill were exceeded
before regulations were in place).
( 9/30/85 ) - AB 2239 effective. Set new compliance dates and
added provisions for issuance of interim permits.
10/ 1 /85) - Bradley Bill (AB 1755) effective: Minor change in
construction standards Tank testing interval extension for
early testing.
Compliance dates are : March 1 , 1986 for the issuance of
interim permits to operate an underground storage tank; interim
permits are valid only through September 1 , 1986 at which time
standard operating permits must be issued.
Operation of an underground tank storing a .hazardous
substance without a permit may result in a fine of $500 to $5000
per day of operation (Section 25299, California Health and Safety
Code) .
A complete copy of, the State Underground Tank Regulations
may be obtained from the State Water .Resources . Control Board, 901
"P" Street , P.O. Box 100, Sacramento , CA 95801
Please Reply or Call: '
0 Easticentral Office G Occupational Health 0 West Office
1111 Ward Street 1111 Ward Street 39th St 8 Bissell Ave.
Martinez,California 94553 Martinez,California 94553 Richmond,California 94805
(415)372-2521 (415)3i2-2286 (415)231-3141
Underground Tank Owner January 13, 1986
To obtain your interim permit you must:
1 . Complete the permit application form enclosed. Please fill
it out as completely as possible. If you do not have some
requested information, simply mark the space N/A (not
available). Your applications will be checked against your
underground storage tank registration statement , and
subsequently by field inspection.
2. Choose a monitoring alternative (see section 2641 , Title 23,
California Administrative Code.
3. Prepare a monitoring plan (see encl .- "Monitoring Programs" )
4 . Send the completed application, monitoring plan, and
appropriate fees to Contra Costa County, Office of the
County Auditor - Controller, Room 203, Finance Building ,
Martinez, CA 94553, within 30 days of receipt of invoice .
If you have any questions please call Bruce Benike or Hank
Bunczewski , Contra Costa County Health Services , (415) 372-2286.
Thank you.
Sincerely,
Dan Bergman
Assistant Health Services Director/
Environmental Health
DCB: BAB: bf
Encl .
• STATE ID NUMBER
APPLICATION FOR PERMIT TO OPERATE UNDERGROUND STORAGE TANK
t )
01 NEW PERMIT ( ) 05 RENEWED PERMIT ( ) 07 TANK CLOSED ( ) 09 DELETE FROM FILE (NO FEE)
( ) 02 CONDITIONAL PERMIT I ) 06 AMENDED PERMIT ( ) 08 MINOR CHANGE IND SURCHARGE)
I OWNER
NAME(COOPORATION.INozVIDUAL DR PUSt-IC AGENCY) PUBLIC AGENCY ONLY
( ) 01 FED t 102 STATE f ) 03 LOCAL
STREET ADDRESS CITY STATE ZIP
II FACILITY
FACILITY NAME DEALER/FOREMAN/SUPERVISOR
STREET ADDRESS NEAREST CROSS STREET
CITY COUNTY ZIP
MAILING ADDRESS CITY STATE ZIP
PHONE W/AREA CODE TYPE OF BUSINESS
( ) 01 GASOLINE STATION t ) 02 OTHER
NUMBER OF CONTAINERS RURAL AREAS ONLYTOSHIP RANGE SECTION
III 24 HOUR EMERGENCY CONTACT PERSON
OATS: NAME(LAST NAME FIRST) AND PHONE W/AREA CODE NIGHTS: NAME(LAST NAME FIRST) AND PHONE W/AREA CODE
COMPLETE THE FOLLOWING ON A SEPARATE FORM FOR EACH CONTAINER
IV DESCRIPTION
A. [ 1 01 TANK ( l 04 OTHER: CONTAINER NUMBER
B. MANUFACTURER (IF APPROPRIATE): YEAR MFG: C. YEAR INSTALLED ( ) UNKNOWN
0. CONTAINER CAPACITY: GALLONS f ) UNKNOWN E. DOES THE CONTAINER STORE: ( l 01 WASTE ( ) 02 PRODUCT
F. DOES THE CONTAINER STORE MOTOR VEHICLE FUEL OR WASTE OIL ? f ) 01 TES ( 1 02 NO IF YES CHECK APPROPRIATE BOXIESI=
( )
01 UNLEADED 1 ) 02 REGULAR t ) 03 PREMIUM l ) 04 DIESEL f I' 05 WASTE OIL (I ) 06 OTHER
V CONTAINER CONSTRUCTION
A. THICKNESS OF PRIMARY CONTAINMENT: ( ) GAUGE ( I INCHES ( ) CM ( 1 UNKNOWN
B. ( 1 01 VAULTED (LOCATED IN AN UNDERGROUND VAULT) ( l 02 NON-VAULTED ( ) 03 UNKNOWN
C. t 101 DOUBLE WALLED t ) 02 SINGLE WALLED ( ) 03 LINED
D. t ) 01 CARBON STEEL ( ! 02 STAINLESS STEEL ( ) 03 FIBERGLASS f ) 04 POLYVINYL CHLORIDE t ) 05 CONCRETE
( ) 06 ALUMINUM ( ) 07 STEEL CLAD ( l 08 BRONZE ( ) 09 COMPOSITE ( ) 10 NON-METALLIC
( ) 12. UNKNOWN t 1 13 OTHER:
MSC04-070185 PAGE 1
STATE ID NUMBER
CONTAINER CONSTRUCTION
E. ( ) 01 RUBBER LINED f ) 02 ALKYD LINING ( ) 03 EPDXY LINING ( 1 04 PHENOLIC LINING ( ) 05 GLASS LINING
( ) 07 UNLINED ( ) 08 UNKNOWN l ) 09 OTHER:
F. ( ) 01 POLYETHLENE WRAP t ) 02 VINYL WRAPPING ( ) 03 CATHODIC PROTECTION, ( 1 04 UNKNOWN ( ) 05 NONE
( 1 06 TAR OR ASPHALT ( ) 09 OTHER:
VI PIPING
A. ABOVEGROUND PIPING: ( l 01 DOUBLE-WALLED PIPE ( 1 02 CONCRETE-LINED TRENCH ( ) 03 GRAVITY
(CHECK APPROPRIATE BOX(ES) ( ) 04 PRESSURE ( ) 05 SUCTION ( ) 06 UNKNOWN ( ) 07 NONE
B. UNDERGROUND PIPING: ( 1 01 DOUBLE-WALLEO PIPE ( ) 02 CONCRETE-LINED TRENCH ( ) 03 GRAVITY
(CHECK APFROPRIATE BOX(ES) O 04 PRESSURE f 1 05 SUCTION ( 7 06 UNKNOWN f ) 07 NONE
VII LEAK DETECTION
t 1
01 VISUAL ( ) 02 STOCK INVENTORY ( 1 04 VAPOR SNIFF WELLS ( ) 05 SENSOR INSTRUMENT
L f ) 06 GROUND WATER MONITORING WELLS ( ) 07 PRESSURE TEST f ) 09 NONE f ) 10 OTHER:
VIII CHEMICAL COMPOSITION OF MATERIALS STORED IN UNDERGROUND CONTAINERS
IF YOU CHECKEO YES TO IV-F YOU ARE NOT REQUIRED TO COMPLETE THIS SECTION
CURRENTLY PREVIOUSLY DELETE CASK (IF KNCWN) CHEMICAL (DO NOT USE COMMERCIAL NAME)
STORED STORED
f ) 01 ( ) 02 ( 1 03 I� I I 1 II II II 1 II 1I,
f ) 01 ( ) 02 ( ) 03 _1 I-il -1 �— - —_-_---
( 1 01 O 02 ( 1 03 I I I ( ( I I I 1 1
) 01 O 02 O 03 I I I I I I I I I I I I
O01 ( ) 02 () o3I ILHLIIIIIII
t 101 ( ) 02 ( ) 03I I H I I I I I III I
I ) 01 O 02 O 03-1 111 I I I 1 1 I I I I _
I ( ) 01 ( ) 02 ( ) 03 I I
( ) 01 ( ) 02 ( ) 03 I,
1 1 01 ( ) 02 ( ) 03
IS CONTAINER LOCATED ON AN AGRICULTURAL FARM? ( ) 01 YES ( ) 02 NO
THIS FORM HAS BEEN COMPLETED UNDER THE PENALTY OF PERJURY AND, TO THE BEST OF MY KNOWLEDGE( IS TRUE AND CORRECT.
REPS ON FILING (SIGNATVRE) PHONE W/AREA CODE Il
1'
FOR LOCAL AGENCY USE ONLY
t
(AOMINISTRATING AGENCY CITY CODE COUNTY COO!
CCNTACT PERSON PHONE W/ARIA COO!
DATE OF LAST INSPECTION IN COMPLIANCEPERMIT APPROVAL DATE TRANSACTION DATE LOCAL PERMIT ID 0
( )
01 YES f ) 02 NO
HSC04-070185 PAGE 2
f
MONITORING PROGRAMS
UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES
The State Water Resources Control Board regulations
prescribe various methods ( alternatives ) for monitoring
underground tanks storing hazardous substances. We are attaching
excerpt from subchapter 16, Title 23 , Section' 2641 , California
Administrative Code, for your information. It is expected that
most service stations will use Alternate No. 5 for product , and
No. 7 for waste oil .
The monitoring plan should contain the following:
1 . Choice of monitoring alternative (e . g. #5)
2 . Detailed explantion of inventory control methods used .
3 . Description of how records are kept (please note that
quarterly reports will be required - sect 2644 . e )
4 . Tank testing dates , or copies of recently performed
tests (within 6 months).
5 . Description of facility .
6 . Description of local geology (depth to ground water ,
soil type) .
7. Name , address and phone number of person responsible
for cleanup of releases at the facility .
8 . Submit a Plot Plan showing the following:
- Plot plan scale , key of symbols used
- Location of all tanks and piping
- Property line(s)
- Buildings
- Any surface waters within 200 feet of the site
- Nearest intersection or road
- Proximity to surface waters
- Types of neighboring land uses
9 . Please limit submitted material to less than four pages
if possible .
Note: AB 1755 allows a 30 month interval before your next
test if you test before March 1 , 1986. A letter from a tank
testing firm scheduling your test , even if a number of weeks
after deadline , will meet this requirement , as long as
arrangements are made before April 1 , 1986.
PRESS RELEASE
In response to concerns expressed by some East County residents who own
underground tanks used to store hazardous substances, Supervisor Tom To'rlakson
has requested clarification regarding recently enacted state regulations being
implemented by the Contra Costa County Health Services Department (CCHSD) .
The applicable regulations have been developed by the California State Water
Resources Control Board (SWRCB) in response to legislation introduced by
Assemblyman Byron Sher, which became law on January 1, 1984. This state
leqislation was enacted to regulate underground tanks storing hazardous
materials in an effort to deal with groundwater contamination being disclosed in
many areas of the state. This law requires the inspection, testing, and per-
mitting of underground tanks used for storing hazardous substances, In addi-
tion, inspection and soil testing are required when such tanks are abandoned or
removed by both Contra Costa County Department of Health Services and Fire
Services.
Underaround tanks located on farms to fuel vehicles used primarily for agri-
cultural purposes are exempt from these regulations. The SWRCB has defined a
farm as an agricultural operation actually growing crops or livestock, and
generating $1,000 net annual income, or more, from agricultural production.
The tank registration data provided by the SWRCB and used by the CCCHSD as a
basis for invoicing tank owners for permit fees frequently does not indicate
that a tank is used for agricultural purposes.
Permit fees being billed by CCHSD cover a five year permit time period. Contra
Costa County Environmental Health Division staff will prorate the permit fees to
a yearly payment basis upon request from tank owners.
If a tank owner wishes to abandon an underground tank rather than obtain a per-
mit for continued use, they must complete an abandonment form available from
CCHSD and pay a required $100 per tank abandonment fee. This fee covers the
CCHSD staff and administrative costs associated with site inspection and
investigation for possible leakage or contamination problems that are reviewed
at the time tanks are removed or abandoned in place.
If you require additional information, please call CCCHSD, Environmental Health
Division, at 372-2286.
OB:rm
5/14/86
t
TUm Torlakson 45Civic Avenue
�_. Pittsburg.California 94565
_ (415)439-4138
Supervisor, District Five
Contra Costa County -
eoaro of Supervisors
COUK�
DATE: April 3 , 1986
TO: Phil Batchelor, County Administrator
Mark Finucane, Health Services Director
Attn: Dan Bergman, Assistant Health Services
Director, Environmental Health
FROM: Supervisor Tom Torlakson
SUBJ: UNDERGROUND TANK PERMIT PROGRAM
------------------------------------------------------------
I have received the press release prepared by Dan
Bergman to clarify the underground tank enforcement program
permit fees and exemptions. I noted that no reference was
made to required fire department permit for abandoning the
tank.
I learned of this fire inspection requirement from
George Clemonds, a constituent who contacted my staff for
assistance a few months ago with regard to the underground
tank permit program. My staff in turn referred Mr. Clemonds
to Dan Bergman who had previously explained that his office
would deal with these situations on an individual basis. I
am pleased to learn that contacts have been made with
persons we have referred.
The situation with Mr. Clemonds seems a rather unique
one. During a telephone conversation with Mr. Bergman, Mr.
Clemonds was told that if he received anything from the
Health Services Department that did not have his signature
on it, that Mr. Clemonds should "ignore it" as Mr. Bergman
would be reviewing his specific situation. Upon receiving
an invoice from the county, Mr. Clemonds contacted the
Auditor-Controller' s Office and was told by "Barbara" to
make this notation of Mr. Bergman' s instructions on the
invoice and return it. When this ,invoice was received by
Bruce Benike, an inspector in the Health Services Department
assigned to inspect underground tanks, he sent Mr. Clemonds
a letter informing him that the matter would be turned over
to the District Attorney' s Office if he did not comply. Mr.
Clemonds attempted to explain to Mr. Benike his conversation
with Mr. Bergman. (Mr. Clemonds expressed frustration that
there was no communication between Mr. Bergman and the
inspector. )
i
r,
Phil Batchelor
Mark Finucane
April 3 , 1986
Page TWO
After speaking to Mr. Benike who informed him that
removing the tank would cost $100 for an inspection fee by
Health Services Department, $62. 50 for a fire inspection,
and if a soils analysis was needed it would probably cost
around $86 , Mr. Clemonds made a decision to remove the tank
rather than pay for a. permit which Mr. Clemonds, understood
would cost around $750.
Mr. Clemonds pointed out that it appears staff has
embarked on this major program without first getting a clear
process established. He commented that procedures seem to
change from day to day. He was the first to go to the fire
department for a permit and staff there were not real sure
how to deal with him. His father-in-law applied for a
permit the following day and was instructed to fill out
forms that were different from what he had filled out just
the day before.
He also questioned the necessity for a fire inspection.
He pointed out that when the fire inspector came out, the
inspector merely asked two questions--Is that the hole the
tank was it? Is that the tank that was in it? His wife
responded affirmatively to both questions and that was the
extent of the inspection. I think he poses a legitimate
question: Why is it necessary to have two inspections, one
by the Health Services Department (at $100 ) and another by
the Fire Department ( for $62. 50) especially if the
inspection by the fire department is in fact that
superficial?
Mr. Clemonds was told by another Health Services
inspector ( "Hank" ) that a soils analysis would be needed and
provided him with a list of labs: He contacted the closest
lab and learned a soils analysis would cost around $450
which is quite an increase from the amount that Mr. Benike
originally estimated for him. Mr. Clemonds pointed out that
if he had been aware that a soils analysis would cost that
much, he may have elected to keep the tank.
I have gone into a great deal of detail about this
particular constituent case to point out the desperate need
for clarification ( and the press release helps ) , the
apparent lack of communication between Dan Bergman and Bruce
Benike ( at least in this particular case) , and the need to
establish clear procedures, including the fire permit
process .
Mr. Clemonds has expressed a desire to bring this
matter before the entire Board of Supervisors. Your prompt
attention to this matter would be appreciated.
TT:gro
• a Inventory Daily /esti" 2646 1. Most we approved meters for tank inputs and
Reconciliation witbdrwals.
mod 2. Inventory reconciliation which exceeds any of the
Tank Testing deans $setion 2667 foiloviag shall require further investigationt
mad A. Daily variation - 1100 gallons
pipeline Leak b. weekly variation - @y percent of throughput
Detector• continuous but an greater than 710 gallons
and t. Monthly variation - Z0.5 percent of throughput
soils so leu than 100 gallons
ad
Vadona Monitoring Variable section 2666 7. Minimum member of ground water wells--See
or Alternative go. 2.
Ground Yater
Monitoring Variable Section 1617 4. Limited to motor Miele fuels storage tanks.
7 Task 1. This alternative to limited to use on =all took@
Gauging weekly section 2644 that do net have frequent input or withdrawal,
and (a.g.# standby generator fuel supply) and where the
Task Testing Annum,lly section 2647 liquid level in the tank ua be meuured to the
accuracy of • at -7 gallons. A liquid level difference
of 1-percent of the tank volume or 7 gallons.
whichever is lose shall be nue for further
investigation.
a Tank Testing Aanumlly section 2667 1. This is an interim monitoring alternative that
mod eon be implemented for up to three years.
Inventory 2. Inventory reconciliation shall utilise approved
Reconciliation Daily $sell" 2644 Meters for impute and withdrawals mad shall
or maintain variations within the limits specified
Tank Gueging Daily or Section 2644 in Alternative 00. 6.
Weekly 7. Tank gauging is limited to use on tanks described
in Alternative No. 7 and to those tanks that can
eliminate inputs and withdrawals three times per
weak for 12 boors each. A liquid level difference
of I percent of the tank volume bat "t greater
than SO gallons shall be "use for further
investigation.
e This table is provided as a summary of the varies monitoring alternatives.
Section 2641 shall be meed to determine the actual requirements for each monitoring alternative.
4.7c
i '