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During the hazardous waste inspection, Mr. Rizwan could not provide a valid Environmental Protection Agency (EPA) ID number for the facility. Mr. Rizwan was informed that the facility needed an EPA ID number to manage hazardous waste. Ms. Abate asked Mr. Rizwan where their hazardous waste was stored, and he showed Ms. Abate a 5-gallon container that had a hazardous waste label without any required information filled out. No hazardous waste receipts or manifests could be provided during the inspection. A return to compliance certification and supporting documents had not been submitted to this office. Upon returning to EHD, Ms. Abate placed the facility out of compliance. A new permit was sent to the facility stating the facility was out of compliance on August 24, 2004 (Attachment 9). Ms. Abate reviewed the facility's file and could not find secondary containment results for testing completed prior to January 1, 2003. EHD received notification from Shirley Environmental stating they would be conducting secondary containment testing on November 5, 2002 (Attachment 10). Shirley Environmental was contacted and asked to send results from the November 5, 2002 secondary containment testing. Shirley Environmental did not have results for the facility. Shirley Environmental also notified EHD secondary containment testing would be done at the facility January 10, 2003 (Attachment 11). Shirley Environmental did not have test results from January 10, 2003, either. EHD received notification from Tanknology that secondary containment testing would be done March 25, 2003 (Attachment 12). EHD received a secondary containment test report from USA Gasoline on April 17, 2003 for testing completed March 25, 2003, which was for the tank annulars only (Attachment 13). On the report, Ms. Abate wrote "sumps visual failure per Sandy Edwards." Ms. Sandy Edwards is the Senior Compliance Officer for USA Petroleum Corporation. Depending on how the tank top sumps or UDC sumps fail, the lines could also fail. No other components were tested that day. On October 1, 2004, secondary containment test results were submitted to EHD for testing conducted on August 15, 2003, when new UDC sumps were installed. Tank annulars, piping and UDC sumps were tested, but tank top sumps were not(Attachment 14). On September 16, 2004, Ms. Abate drove by the facility and took a photo of it operating without a valid permit (Attachment 15). On March 15, 2005, Ms. Abate approved a permit application (Attachment 16)to replace both spill containers. These were replaced on March 24, 2005, and testing was witnessed by Ms. Michelle Le, Sr. REHS, EHD. On July 13, 2005, Ms. Le performed a routine UST inspection (Attachment 17) and witnessed the annual monitoring system certification (Attachment 18) and Mr. Willy Ng, Sr. REHS, EHD, performed a routine hazardous waste inspection (Attachment 19). During the UST inspection, Ms. Le found that current financial responsibility documents had not been submitted to this office, and records of employee training by the designated operator were not available on site. During the hazardous waste inspection, Mr. Ng found a container of used absorbent improperly labeled and could not find copies of 3