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On October 16, 2008, Mr. Fieock called Mr. Naidu and asked if two different contractors can share certifications for the UST system work. Mr. Fieock stated that Fuel Oil Systems has a contractor's license and ICC certification, but Saharagun Plumbing would be subcontracted to actually do the work. Saharagun Plumbing does not have an ICC - certification for this work. Mr. Naidu stated that Saharagun Plumbing cannot work on ft system because they did not have ICC certification. Mr. Fieock stated that Fuel Oil Systems would perform all of the work once the permit was approved. *n November 25, 2008, ICC certifications for Mr. Michael Bellis, manufacturer's cut ;heets, and revised drawings were submitted for permit application SR0055596 (Attachment 13). On December 18, 2008, Mr. Naidu and Ms. Kasey Foley, Program Coordinator, REHS, EHD, met with Mr. Fieock, Mr. Stroup, and several other people involved in the project at Kaiser to discuss the items needed for the approval of the permit application and inspections required. An agenda and meeting minutes showing a complete list of attendees prepared by Mr. Stroup was submitted (Attachment 14). On December 24, 2008, a line test on the diesel supply line was performed twenty -&Az (25) months late (Attachment 15). On February 13, 2009, Mr. Naidu called and spoke with Mr. Stroup regarding permit application SR0055596. Mr. Stroup stated that the project was on hold and he had no further information. This permit was never approved and a new permit was submitted on September 16, 2009. On August 7, 2009, Mr. Naidu performed a routine LIST inspection (Attachment 16) and witnessed the annual monitoring system certification and spill container testing (Attachment 17). A complete permit application for the unpermitted work done in 2008 had not been submitted, and secondary containment testing, due by April 2009, was not done. During a review of the facility's files, the monthly designated operator monthly inspection reports for May, June, and July 2009, were not found on site; it could not be shown that daily monitoring of the UST system was done on February 25, 26, and 27, 2009, and July 23, 24, and 25, 2009, as stated in the facility's approved monitoring plan (Attachment 18); and the response plan was not current or approved by the EHD. All sensors and the spill container were tested and passed. A response plan was submitted and approved by Mr. Naidu while on site. During the inspection, Mr. Fieock informed Mr. Naidu that they decided to install an aboveground storage tank (AST) and abandon the UST because they believe it would be more cost effective. Mr. Fieock also mentioned that they could not move forward with that plan right away because the City of Manteca ordinance would only allow a 1,100 gallon AST, but an 8,000 gallon AST would be required, and they were working with the city to change the ordinance. 0