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leak detector was witnessed by Mr. Ng on December 14, 2005. On November 28, 2005, Mr. Ng wrote an addendum to the November 21, 2005, routine LIST inspection report regarding the September 19, 2005, secondary containment failure on piping sump #2 and sent it by certified mail (Attachment 47). Mr. Saini was asked to obtain a permit from the EH D to repair the system within seven days of receiving the letter. A certified mail receipt was signed on November 30, 2005. A permit application was not submitted until November 21, 2008, after the system was tested on October 28, 2008. Repairs were finally completed on December 12, 2008, 39 months after the initial failure. On September 12, 2006, Mr. von FlOe performed a routine LIST inspection (Attachment 48) and witnessed the annual monitoring certification. The piping sump sensors for all three tanks were not properly located to detect a leak at the earliest opportunity, approximately one inch of liquid was found in the 91-octane tank annular, current certification of financial responsibility was lacking and the UST - Tank form (former Form B) needed to be updated for the diesel and 91-octane tanks. Fuel leaks were found under all four dispensers, and have been noted in the monthly designated operator inspection reports for the past several months. Mr. von FlOe also approved and filed the monitoring and response plans and faxed a UST-Tank form to Mr. Saini to update. On September 15, 2006, a permit application, SR0048208, was submitted to replace all three turbine sump sensors and approved by Mr. Ng on September 19, 2006 (Attachment 49). On October 12, 2006, Mr. von FlOe returned a call from Mr. Saini and left a message stating that the certification of financial responsibility was not completed properly and that updated UST - Tank forms, a recordable release statement and the return to compliance certification were still needed. Mr. von FlUe also faxed a UST - Tank form again and filed the designated operator employee training record that was submitted. On October 13, 2006, Mr. von FlOe wrote a follow up letter requesting items listed in the September 12, 2006, inspection report that have not been submitted (Attachment 50). On October 20, 2006, Mr. von Fibe received a voice mail message from Mr. Singh stating he received the follow up letter and had previously submitted the requested paperwork and would like a call back. Mr. von FlUe returned Mr. Singh's call and left a message listing the paperwork that was missing or incomplete. On October 23, 2006, Mr. von FlOe received copies of the return to compliance certification, hazardous materials inventory forms, LIST training records, corrective actions statement, and incomplete financial responsibility documents (Attachment 51). A recordable release statement and current LIST-Tank forms for the diesel and 91-octane tanks were not submitted. On October 25, 2006, Mr. von FlOe went to Charter Way Chevron and witnessed the testing of the new sump sensors (Attachment 52). The sensors are now located in the correct position to detect a leak at the earliest opportunity. Mr. von Abe also inspected the underneath dispensers 1/2 and 7/8 and found that there were still small leaks. The service technician stated that they will come back at a later date to fix the leaks. The LIST-Tank form for the diesel tank was submitted, but was incomplete. On November 7, 2006, a maintenance receipt was submitted by Elite IV for work on tightening the unions under the dispensers (Attachment 53). A fuel filter was also replaced. 7