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Mr. von FIQe also performed a routine hazardous waste inspection on November 7, 2006.
<br /> (Attachment 17). During the inspection, Mr. von FlUe found two 55-gallon containers of
<br /> hazardous waste improperly labeled and used absorbent collected in open, unlabeled
<br /> containers. A modified emergency plan and manifests or disposal receipts for hazardous waste
<br /> were not found on site,
<br /> On November 14, 2006, Mr. Paul Judge, BAP Enterprises, left a phone message for Mr. von
<br /> FlUe stating he found a receipt from Elite IV, dated June 6, 2006, for repairing the July 22,
<br /> 2005, secondary containment failures. However, no receipt was ever submitted. Mr. von Flue
<br /> informed him that a test report was never submitted for this work. Current financial
<br /> responsibility documents were submitted this day (Attachment 18).
<br /> On November 16, 2006, Mr. Toua Yang, EH , EHD, witnessed the monitoring system
<br /> certification. Mr. Yang found that test boots were left on the 87- and 91-octane turbine sumps,
<br /> and sensors in the 87- and 91-octane fill sumps were not located at the proper locations to
<br /> detect a release at the earliest possible opportunity. Also, approximately four inches of liquid
<br /> was observed in the 87-octane vapor recovery spill container and approximately one inch of
<br /> liquid was found in the 91-octane fill and vapor recovery spill containers. The 91-octane leak
<br /> detector failed, and the 87- and 91-octane annular tank sensors were stuck and could not be
<br /> removed for testing. An inspection report was left on site (Attachment 19). A monitoring
<br /> system certification test report was submitted to the EHD on April 7, 2008, almost 1 1/2 years
<br /> after the monitoring system certification, and well after the required 30-day submittal
<br /> (Attachment 20).
<br /> On November 27, 2006, a permit application, SR0048983, was submitted to replace the 87-
<br /> and 91-octane annular sensors and the 91-octane leak detector and was approved the next day
<br /> (Attachment 21). On November 30, 2006, Mr. Yang witnessed the testing of the new 91-octane
<br /> leak detector and the 87- and 91-octane annular tank sensors. The service technician was able
<br /> to remove and test the annular sensors, and they did not have to be replaced. The leak
<br /> detector and both annular sensors passed and a report was left on site (Attachment 22).
<br /> On December 6, 2006, a return to compliance certification was received from Mr. Judge for the
<br /> hazardous waste and UST inspections. A corrective actions statement and copies of manifests
<br /> were submitted for the hazardous waste inspection (Attachment 23). A corrective actions
<br /> statement with a portion of an ELD test report were submitted for the UST inspection (Attachment
<br /> 24). Additionally, Mr. Chris Papas, attorney for Mr. Judge, faxed a more complete packet of ELD
<br /> test results which included ELD testing on February 22, 2006, that showed a failure on the vapor
<br /> recovery line, ELD testing on February 25, 2006, that confirmed the failure on the vapor recovery
<br /> line, and passing ELD testing for the vapor recovery line performed on June 22, 2006 (Attachment
<br /> 25).
<br /> Also on December 6, 2006, the 87- and 91-octane secondary piping was retested, passed, and a
<br /> report was submitted to the EHD(Attachment 26).
<br /> On December 28, 2006, a return to compliance certification was submitted with a corrective
<br /> actions statement addressing how each violation noted in the November 16, 2006, monitoring
<br /> system certification inspection report was corrected (Attachment 27).
<br /> On February 2, 2007, a copy of the monitoring and response plans that were approved on
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