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<br /> the ELD and secondary containment tests. Mr. Saini stated he had given all the paperwork to
<br /> Elite IV to make any necessary repairs. Mr. Saini added that he would call Elite IV immediately
<br /> after the conversation.
<br /> On November 10, 2005, a follow up letter was mailed to the Wilson Way Chevron requesting a
<br /> response to the UST inspection performed on September 19, 2005 (Attachment 7).
<br /> On December 19, 2005, Wilson Way Chevron was sold to a new owner, BAP Enterprises, Inc
<br /> (Attachment 8). Secondary containment failures had not been addressed, and certification of
<br /> financial responsibility and certification of return to compliance from the previous owner were
<br /> never received by the EHD.
<br /> On February 17, 2006, EHD received notification from CGIRS that Praxair will be performing
<br /> another ELD test on February 20, 2006. No EHD staff witnessed the testing (Attachment 9).
<br /> On February 24, 2006, EHD received a permit application, SR0046523, for the installation of
<br /> additional ELD sample points (Attachment 10).
<br /> On May 12, 2006, a permit application, 5R0046666, was submitted by Elite IV for the exploration
<br /> of a leak due to the failing results from ELD testing. This permit was approved by Mr. Muniappa
<br /> Naidu, Senior RENS, EHD, on June 2, 2006 (Attachment 11). On July 5, 2006, Mr. Naidu spoke
<br /> with Mr. Jack Coffelt of Elite IV, who explained that he broke ground and tested the lines, but he
<br /> could not find any leaks. Praxair performed another ELD test on the previously failed vapor lines
<br /> on June 22, 2006, but it was done with an open excavation, and without notification to the EHD.
<br /> Mr. Coffelt said he received a verbal passing result.
<br /> On July 17, 2006, Affordatest performed two line tests as part of the June 2, 2006, permit
<br /> conditions. Both passed (Attachment 12).
<br /> On July 21, 2006, a permit application, 5R0047536, was submitted by Elite IV to replace the 87-
<br /> octane sump sensor and approved by Mr. von FlUe on July 25, 2006 (Attachment 13).
<br /> On July 28, 2006, Mr. von FlUe spoke with Mr. Brian Green of CGIRS regarding the ELD testing.
<br /> Praxair could not explain how or why the ELD testing on June 22, 2006, passed but confirmed all
<br /> ELD results were passing. The results were not released until the previous owner paid the
<br /> pending bill. The results for the February 22, 2006, February 25, 2006, and June 22, 2006, test
<br /> reports were eventually submitted to the EHD by CGIRS on February 15, 2007 (Attachment 14).
<br /> On August 30, 2006, Mr. von FIQe was on site to witness the functionality test of the 87-octane
<br /> sump sensor. He verified the audio/visual test and the shutdown of the turbine. He also
<br /> witnessed the test of the "sensor out" alarm (Attachment 15).
<br /> On November 7, 2006, Mr. von FlOe performed a routine UST inspection (Attachment 16) and
<br /> found that the annual monitoring system certification, leak detector testing, and spill container
<br /> testing were due by September 2006 and were two months past due. Also, failures from the
<br /> July 22, 2005, secondary containment testing had not been repaired, and passing test results
<br /> for ELD had not been submitted. Current financial responsibility documents had not been
<br /> submitted to the EHD, monitoring and response plans were not current or on file with the EHD,
<br /> and maintenance and monitoring records were not found on site. The designated operator had
<br /> not trained all required employees (at least one per shift) on site.
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