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• respond to three inspection reports from June, October, and December 2008, and that he could find the required forms on the EHD website. Mr. Gill stated he would continue to work on completing the forms. On June 10, 2009, Mr. Gill submitted a return to compliance statement addressing each of the 2008 UST inspections (Attachment 21). The statements addressing both the June and October 2008 UST inspections stated that the "forms are submitted with this package to bring the site into compliance," but the only form included was an incomplete financial responsibility document. The statement addressing the December 2008 UST inspection included updated UPCF facility information and tank information forms, and an explanation for the "unauthorized release of diesel into one of the UDC." It explained that the leak in UDC sump 16A/17B was not detected due to a malfunctioning sensor and was replaced (which it was, and under permit and inspection of the EHD), but did not address the leak itself. It further explains that soon after, there was another leak in the same dispenser which the sensor detected, the leak was determined to be coming from a defective flex hose connection, and was repaired under permit and inspection of the EHD. The EHD is unaware of a second leak in this UDC sump and does not have any record of a permit or inspection associated with a flex hose connector replacement in this sump. Ms. Henry called Mr. Gill and explained that the documentation submitted was insufficient: the financial responsibility documents were incomplete, maintenance records and reportable release statements were not submitted, and straps to hold down the sump lids on the 20,000-gallon diesel tanks to make them vapor tight were not installed. Ms. Henry explained that all of the violations on the inspection reports needed to be addressed. Mr. Gill stated that he understood and would submit all necessary documentation. On July 30, 2009, Ms. Henry was informed by the EHD accounting office that the annual permit fees for 2009 had not been paid and the facility did not have a valid operating permit for the year. Ms. Henry changed the facility's status to `but of compliance." Ms. Henry also sent another follow up letter asking for all the outstanding items from the 2008 inspections (Attachment 22). On August 25, 2009, items were submitted in response to the July 30, 2009, follow up letter (Attachment 23). Included were statements addressing each of the 2008 inspections. The statement and supporting documentation addressing the June 23, 2008, routine hazardous waste and UST inspections included a copy of the facility's EPA ID number, but did not include a disposal manifest for the waste found on site as required. Current financial responsibility documents were submitted. All other violations on the June 23, 2008, inspections were adequately addressed. The statement addressing the October 30, 2008, UST inspection still incorrectly indicated that the leak in the UDC sump 16A/17B was due to a faulty flex hose connection that was repaired under permit and inspection of the EHD. The EHD does not have any record of a permit or inspection associated with a flex hose connector replacement in this sump. The October 30, 2008, monitoring system certification test report for the truck stop side of the facility that was also submitted contained a comment from the service technician that stated, "Diesel UDC 16a-17b had approximately 20 gallons of diesel fuel inside the UDC due to a leaking solenoid valve up inside the dispenser on dispensing side 17b." The statement did not address the straps to hold 5