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On April 3, 2008, Ms. Michelle Henry, Senior REHS, EHD, performed a routine UST
<br />inspection and witnessed the annual monitoring system certification, leak detector
<br />testing, and spill container testing. Testing was scheduled for March 31, 2008, but was
<br />rescheduled at the request of the EHD due to a scheduling conflict. During the
<br />inspection, Ms. Henry found that current financial responsibility documents and
<br />monitoring and response plans were not on file with this office. Current monitoring and
<br />response plans, maintenance and monitoring records, and February and March 2008
<br />designated operator monthly inspection reports were not found on site. Ms. Henry also
<br />found that none of the items noted in the March 13, 2007, UST inspection report were
<br />ever addressed. A checklist of noted violations was left on site (Attachment 20). A
<br />monitoring system certification test report, due within 30 days of testing, was never
<br />submitted.
<br />On April 3, 2008, Ms. Henry also performed a routine hazardous waste inspection. Ms.
<br />Henry found fourteen 55 -gallon drums of hazardous waste on site without proper
<br />labeling, and it could not be determined how long any of the drums were on site. One
<br />drum was found open and not in use at the time and piles of junk and trash were piled
<br />around the drum that was actively used to store the facility's hazardous waste when
<br />generated. During the review of the facility's paperwork, Ms. Henry found that the
<br />facility's EPA ID number was not active, documentation for the disposal of hazardous
<br />waste and universal waste for the last three years were not found on site, and the facility
<br />did not have a modified contingency plan or emergency coordinator. Ms. Henry did not
<br />have time to write a complete inspection report, so a checklist was left on site
<br />(Attachment 21).
<br />On May 14, 2008, Ms. Henry delivered the April 3, 2008, routine UST and hazardous
<br />waste inspection reports to the facility (Attachments 22 and 23).
<br />On July 8, 2008, a letter dated July 2, 2008, was sent by certified and regular mail to the
<br />facility asking for all the items requested on the April 3, 2008, UST and hazardous waste
<br />inspection reports (Attachment 24). None of the items were previously submitted.
<br />On July 21, 2008, Ms. Henry called Mr. Minhas to follow up on the April 3, 2008,
<br />inspection reports and left a message regarding a possible UST consultation.
<br />On August 6, 2008, Ms. Henry performed a consultation with Mr. Minhas and his son at
<br />the EHD to ensure all required forms were completed and submitted. The UST and
<br />hazardous waste inspection reports were reviewed. Mr. Minhas stated he forgot his
<br />glasses and asked if Ms. Henry would complete the monitoring and response plans for
<br />him. Ms. Henry replied, "No," but added she would help. Mr. Minhas stated he would
<br />have his designated operator help him complete the plans. Mr. Minhas also stated
<br />repeatedly that we should already have this information on file. Ms. Henry explained
<br />that the forms were not correct and need to be updated. Current financial responsibility
<br />forms were submitted, and Ms. Henry asked if the tank owner listed in the UST — Facility
<br />form, California Gas Station LLC, was correct, and Mr. Minhas stated he did not know,
<br />but would find out. When Ms. Henry reviewed the hazardous waste inspection report,
<br />Mr. Minhas repeatedly stated he knew what he had to do, but when Ms. Henry informed
<br />him of the return to compliance certification, he did not seem to understand and began to
<br />state that he didn't know any of this and why did we not tell him before? A modified
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