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Naidu also discovered that a new designated operator was hired, and the EHD was not notified within 30 days. On June 23, 2008, Mr. Naidu also performed a routine hazardous waste inspection and found that the facility did not have a current Environmental Protection Agency (EPA) Identification Number to manage hazardous waste. The hazardous waste container was not properly labeled, and it had an accumulation start date of May 2, 2007, which indicated it was stored on site for over 180 days (Attachment 5). On September 11, 2008, a monitoring system certification, leak detector testing, and spill container testing was scheduled. Mr. Naidu arrived on site and was told that testing was cancelled, and the EHD had not been informed. Mr. Naidu informed the facility manager that there would be a charge for the rescheduled inspection appointment. On October 30, 2008, Mr. Naidu witnessed the annual monitoring system certification, leak detector testing, and spill container testing for the truck stop side of the facility. Testing was due by May 2008 and was five months past due. Testing for the automobile side of the facility was not performed due to time constraints and would be scheduled at a later date. Sensors in under dispenser containment (UDC) sump 16A/17B and the diesel north fill sump, both diesel leak detectors, and smart sensor for the diesel north product piping (S3) failed during testing. Approximately 25 gallons of diesel was found in UDC sump 16A/17B and five gallons of diesel was found in UDC sump 14A/15B. Smaller amounts of liquid were found in all the other UDC sumps and both diesel piping sumps. The service technician, Mr. Mark Fajardin, Sr., stated that he would remove all liquids and place them in the hazardous waste drums on site. During a review of the facility's paperwork, Mr. Naidu found that current financial responsibility documents and notification of a new designated operator were not submitted to the EHD, and an alarm history log was not maintained. All were repeat violations from the June 23, 2008, routine UST inspection that had not been corrected, though Mr. Naidu did not indicate this on the current inspection report. The fuel releases were not recorded and reported as outlined on the facility's approved response plan. An inspection report was left with the facility manager(Attachment 6). The monitoring panel system setup and alarm history from this day's testing is attached (Attachment 7). On November 7, 2008, permit application SR0055872 was submitted by the facility to replace the equipment that failed during the October 30, 2008, testing. The application was incomplete, and after several resubmittals, it was approved by Ms. Michelle Henry, Senior REHS, EHD, on December 19, 2008 (Attachment 8). On December 15, 2008, a statement indicating the names of the facility's designated operators was submitted (Attachment 9). On December 22, 2008, Ms. Henry witnessed the annual monitoring system certification, leak detector testing, and spill container testing for the automobile side of the facility. Testing was due by May 2008 and was seven months past due. The 87-octane and 91- octane leak detectors and the diesel piping sump annular sensor failed. These were all replaced and retested. Liquid was found in the diesel piping sump, 87-octane piping sump, and UDC sump 1/2. While on site, Ms. Henry also witnessed the testing on the truck stop side of the sensors and leak detectors that failed during the October 30, 2008, testing and were replaced under permit SR0055872 (Attachment 10). Approximately 25 2