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On May 3, 2004, a monitoring system certification, leak detector testing, and spill container
<br /> testing were performed without a witness from the EHD due to lack of staff availability. A report
<br /> was submitted to the EHD indicating that all sensors, leak detectors, and spill containers
<br /> passed, but a comment was noted in the report stating "electronic line leak detectors installed.
<br /> Verified that they recognized a 3 gph leak." (Attachment 78). There was no indication where
<br /> the leak detectors were installed or how many were installed. On October 17, 2005, Mr.
<br /> Catanyag spoke with Mr. Chuck Hill of Champion Precision Testing (CPT) to inform him the
<br /> leak detectors that were changed on May 3, 2004, required a permit. Mr. Hill replied that CPT
<br /> was under the old ownership of Mr. Chet Champion, when the incident occurred. A permit was
<br /> never obtained for this work.
<br /> On May 24, 2004, Ms. Le was on site to witness the testing of the new spill containers and
<br /> performed a routine LIST inspection (Attachment 79). Ms. Le found that the new spill
<br /> containers did not hold a minimum of five gallons and liquid was found in the 87-octane, 91-
<br /> octane, and diesel piping sumps. Verification of the 5-gallon capacities of the spill containers
<br /> was not noted in EHD files, but the EHD database shows three other site visits under this
<br /> permit on June 3, 2004, July 8, 2004, and July 9, 2004.
<br /> On June 27, 2005, Ms. Le performed a routine LIST inspection (Attachment 80). The annual
<br /> monitoring system certification, leak detector testing, and spill container testing were due by
<br /> May 2005 and were one month past due. Secondary containment testing was due by April
<br /> 2005 and was two months past due.
<br /> On July 13, 2005, Ms. Le performed a routine hazardous waste inspection (Attachment 81), a
<br /> routine UST inspection (Attachment 82), and witnessed the annual monitoring system
<br /> certification, leak detector testing, and spill container testing (Attachment 83), which were two
<br /> months past due. During the hazardous waste inspection, Ms. Le found that West Lane Chevron
<br /> had no records for the disposal of any hazardous waste or a container to store hazardous waste.
<br /> This facility also did not have a contingency plan or a valid EPA ID number to manage hazardous
<br /> waste.
<br /> During the LIST inspection, Ms. Le found that secondary containment testing was now three
<br /> months past due. A review of the alarm log showed that an alarm occurred on March 21, 2005, in
<br /> the 91-octane tank annular space and no maintenance receipts were found. Liquid was found in
<br /> the 87-octane piping sump and employee training records by the designated operator were not
<br /> available.
<br /> On July 20, 2005, secondary containment testing (Attachment 84) was performed at this site.
<br /> Although all secondary components passed, the test was three months past due. The last test
<br /> performed on April 2 and May 17, 2002, (Attachment 85) had two failures, at the 87- and 89-
<br /> octane piping sumps. These two failures were retested and passed on June 5, 2002 (Attachment
<br /> 86). There were no records that EHD was notified as to what repairs were made, nor by whom,
<br /> nor the retest date. Also on this date, Ms. Le called the owner and informed him that a leak
<br /> detector failed on July 13, 2005, and he would need a permit to repair or replace it. No failures of
<br /> any monitoring equipment were noted in the last inspection report or monitoring system
<br /> certification report.
<br /> On July 26, 2005, a permit application, 5R0043244, was submitted by Elite IV to replace the 87-
<br /> octane annular sensor. Ms. Le called Ms. Miller of Elite IV and explained that she recalled the
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