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On May 3, 2005, Ms. Le called and spoke with Mr. Ravinder "Rinku" Singh, son of owner and manager, Mr. Surinder Singh Saini, of Wilson Way Chevron. Ms. Le informed Mr. Singh that the ELD test performed in February 2005 had failures. Ms. Le asked what actions had been taken to correct the failures. Mr. Singh was aware of the failures and had a conversation with CGS, who told him that they were unable to make any type of repairs. Mr. Singh stated he would call Elite IV Contractors (Elite IV) regarding the repairs and call Ms. Le back. On July 13, 2005, Ms. Le reminded Mr. Singh that the ELD failures still had not been corrected. Mr. Singh told Ms. Le that he had spoken with Elite IV, who requested a copy of the test results. With the permission of the owner, Ms. Le faxed a copy of the ELD results to Elite IV on July 14, 2005. On July 22, 2005, secondary containment testing was performed and a report was submitted to the EHD showing failures in two components, the 87-octane piping, and the 91-octane piping (Attachment 4). Comments in the report indicated that the test boots needed to be sealed. Ms. Lori Luces, Environmental Health Specialist (EHS), EHD, called and left a message for Mr. Singh to contact her. On August 17, 2005, Ms. Luces spoke with the owner, Mr. Saini, regarding the failed secondary containment testing results. Mr. Saini said he had contacted Elite IV to repair the boots but no date has been set to perform the work. Ms. Luces stressed the importance of repairing the failures in a timely manner. On September 19, 2005, Mr. Dennis Catanyag, Senior REH , EHD, performed a routine underground storage tank (UST) inspection (Attachment 5) and witnessed the annual monitoring system certification, line leak detector testing, and spill container testing (Attachment 6). The monitoring system certification and line leak detector testing were due by August 2005 and were one month late. Both spill containers failed to hold five gallons of liquid for one hour, the 91- octane line leak detector failed to detect a 3.0 gph leak at 10 psi, and the 91-octane piping sump sensor was not located at the earliest opportunity to detect a leak. Two inches of liquid with an oily sheen was also found in the 91-octane piping sump. The overfill prevention system was found inadequate due to a lack of either an enunciator or ball floats in the vapor recovery risers. During the review of the UST documents, Mr. Catanyag found that failed components from the February 2005 ELD testing and July 2005 secondary containment testing had not been repaired, current financial responsibility documents have not been submitted to the EHD, current monitoring and response plans were not found on site, and employee training by the designated operator was inadequate. On September 21, 2005, Mr. Catanyag confirmed the functionality of the 91-octane leak detector that had been replaced under an EHD permit on September 20, 2005. Mr. Catanyag also confirmed the removal of the liquid accumulation in the 91-octane piping sump. On September 22, 2005, Mr. Catanyag witnessed the testing of the two spill containers. Elite IV had replaced the gaskets and tightened the spill containers under manufacturer's specification in order for them to pass. On September 28, 2005, Mr. Catanyag verified the installation of ball floats on the vapor recovery lines. On October 24, 2005, Mr. Catanyag spoke with Mr. Saini regarding the failed components from 2