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0 • On October 14, 2005, EHD received a permit to replace the monitoring system from a Red Jacket to a Veeder-Root system. Mr. Catanyag spoke with Carne Miller, Elite IV Contractors stating the annular sensor the contractor plans to install does not meet the requirement of continuous monitoring. Ms. Miller replied she must speak with a Flying J representative, Rusty Mace regarding an approved part. Mr. Mace contacted Mr. Catanyag stating the model of the annular sensor will be changed to meet the requirements of the continuous monitoring. Mr. Catanyag stated the change in equipment must be documented in the permit application. On October 21, 2005, Mr. Catanyag received an addendum to the permit application changing the model of the annular sensor that met the requirement of continuous monitoring. On October 24, 2005, Mr. Catanyag approved the permit to change the monitoring system. Elite IV contractors are scheduled to begin work on November 10, 2005. As of November 7, 2005, the facility has not made any repairs to the failed secondary containment components and the monitoring certification is past due as of November 4, 2005. This facility has had problems scheduling required tests performed in a timely manner. The facility has been late scheduling the monitoring certification the last four years. The dates of the annual monitoring certification are listed below: August 8, 2002 August 21, 2003 (due August 8, 2003) November 4, 2004(due August 21, 2004) November 30,2005 (due November 4, 2005) On November 28, 2005, Elite IV started the replacement of the monitoring system from Red Jacket to Veeder-Root. The work involved the replacement of all sensors and monitoring panel, which included a dual float sensor for the brine-filled tanks. On November 30, 2005, Mr. Catanyag and Mr.Ng were on site to verify the functionality of the sensors and perform a routine UST inspection. Mr. Catanyag noticed the annular space sensors for six brine filled tanks were single float sensors. According to Mr. Robert Bush, Elite IV Contractors, Flying J had originally ordered dual float sensors for all components and returned all of them, only to order all single float sensors. Mr. Bush informed the Mr. Rusty Mace about the problem. However, Mr. Bush opted to install the component to make certain that the tanks have some type of monitoring even if it did not meet the requirement. The sensors have been ordered and will be installed under a new permit. On December 1, 2005, the inspection report (Attachmentl5) was discussed with the facility manager, Mr. Ricardo Buenrostro regarding all noted violations including secondary containment failures that still have not been addressed. On December 1, 2005, a routine hazardous waste inspection was performed after receiving approval to inspect, take samples and pictures from Mr. Buenrostro. During the inspection, one drum that contained liquid removed from the sumps encountered during the monitoring certifcation, was observed without labels. Another full drum of unknown was also observed, without any knowledge as to its content or length of time it has been on site. Another noted violation was the handling of sludge from the oil/water separator. -When-Mr. Catanyag asked how the waste stream-was handled; Mr. Buesrostro replied that it should be handled as hazardous. However, there were documents stating the sludge was being removed as non-hazardous. Lastly, the hazardous waste contingency plan did not specify an emergency coordinator. All violations were noted in the inspection report (Attachment 16) and discussed in detail with Mr. Buenrostro. All violations were requested to be corrected by January 1,2006. 5