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report also noted that the annual monitoring certification, spill container and line leak detector testing would be due by August 20, 2004. On July 20, 2004, Ms. Abate received the UST — Tank forms (former Form B), monitoring plan, response plan, and certification of financial responsibility from Mr. Rizwan (Attachment 3). On July 21, 2004, Ms. Abate sent follow-up letters (Attachment 4) certified to the facility and Mr. Rizwan's home mailing address requiring that the facility immediately conduct secondary containment testing on the under dispenser containment and obtain a permit to repair the turbine sumps. On August 5, 2004, Mr. Rizwan came to the EHD to request a copy of the facility's secondary containment test results. Ms. Abate provided him a copy of the test results dated March 25, 2003. Ms. Abate asked if a contractor had been out to the facility to see what repairs needed to be done to repair the turbine sumps. Mr. Rizwan said a contractor had not been out to his facility. Ms. Abate informed Mr. Rizwan that he needed to submit a permit to the EHD immediately to repair the facility's turbine sumps. Ms. Abate reminded Mr. Rizwan he had been informed in January, June and July 2004 of the failed secondary containment turbine sumps, and no repairs had been made. On August 19, 2004, Ms. Abate conducted a routine UST inspection (Attachment 5), a routine hazardous waste inspection (Attachment 6), and witnessed the annual monitoring system certification, spill container, and line leak detector testing. During the monitoring certification, Ms. Abate found that the sensors within the turbine sumps were located about 4-5 inches above the lowest point in the sump. The service technician replaced the sensors in the correct position in the turbine sumps after the monitoring certification was complete. The 91-octane piping within the turbine sump was found with a test boot still in place, preventing any liquid from flowing into the sump. The test boot was pulled back during the inspection to allow liquid detection at the earliest possible opportunity. The facility's overfill prevention system consists of mechanical flapper valve within the drop tubes, but measuring sticks were found in the 87-octane and-89 octane drop tubes that overrode the facility's overfill prevention system. It is unknown how long the facility did not have proper overfill prevention. The service technician removed the two measuring sticks from the 87-octane and 89-octane fill drop tubes (Attachment 7). The 89octane and 91-octane spill containers failed annual testing. Ms. Abate required a permit be pulled from EHD to replace the failed spill containers. Ms. Abate again wrote on the inspection report that a permit must be obtained from EHD immediately to repair the failed turbine sumps. Ms. Abate informed Mr. Rizwan the facility was going to be placed out of compliance by EHD and it was his decision whether or not to operate the USTs while they were out of compliance. A test report for the monitoring system certification and line leak detector testing was sent to San Joaquin Valley Air Pollution Control District, who forwarded it to this office on September 1, 2004 (Attachment 8). This office has not received a report for the spill container testing. 2