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On August 11, 2008, Mr. Backus witnessed the successful testing of the replaced diesel
<br /> UST annular sensor (Attachment 4). While on site, Mr. Backus was given a copy of a
<br /> work order for repairs to dispensers 5/6 and 9/10 performed on August 1, 2008
<br /> (Attachment 5), and a manifest, 001738275FLE, for the disposal of one 55-gallon
<br /> container of oily liquid on February 25, 2008 (Attachment 6).
<br /> On August 11, 2008, a monitoring system certification test report was submitted,
<br /> presumably for the July 23, 2008 testing (Attachment 7). Of the four fields on the report
<br /> that indicated a test date, two of the fields had 7/23/08 entered, one had 7/23/07, and
<br /> one had 2/23/08. On one page, the test date was entered as 7/23/08, while at the
<br /> bottom of the page, next to the service technician's signature, was 3/23/08. Mr. Aris
<br /> Cacapit, Senior REHS, EHD, apparently filed this report without reviewing it.
<br /> On September 9, 2008, a statement of designated UST operator, a recordable release
<br /> statement for a spill on an unknown date, and an incomplete modified emergency
<br /> contingency plan was submitted (Attachment 8).
<br /> On October 9, 2008, Mr. Cacapit sent a follow up letter to the July 23, 2008, hazardous
<br /> waste inspection report (Attachment 9).
<br /> On November 17, 2008, Mr. Cacapit performed a hazardous waste inspection
<br /> (Attachment 10) as a follow up to the July 23, 2008, routine inspection, and a complaint
<br /> that was received on September 23, 2008. The complaint, C00029141, alleged that
<br /> there was an open drum on site that was %full, labeled "gasoline/water mixture," and
<br /> marked with an accumulation start date of 4/25/08 (Attachment 11). During the
<br /> inspection, Mr. Cacapit found four 55-gallon containers, one of which was empty. None
<br /> of the containers were labeled. The facility still did not have a valid EPA ID number to
<br /> manage hazardous waste, and the disposal records for two of the containers previously
<br /> found during the July 23, 2008, hazardous waste inspection were not found on site
<br /> (manifest for one of the containers was previously submitted).
<br /> On November 17, 2008, a corrective actions statement and return to compliance
<br /> certification was submitted in response to the July 23, 2008, UST inspection (Attachment
<br /> 12). UPCF Facility and Tank forms, financial responsibility documents, and monitoring
<br /> and response plans were still lacking. Also submitted was a corrective actions
<br /> statement, return to compliance certification, and a previously submitted copy of
<br /> manifest 001738275 FLE for the disposal of 55 gallons of liquid waste (Attachment 13).
<br /> On December 2, 2008, Mr. Cacapit sent a follow up letter to the July 23. 2008, routine
<br /> UST inspection (Attachment 14).
<br /> On April 17, 2009, Mr. Cacapit sent a follow up letter to the July 23. 2008, routine UST
<br /> inspection (Attachment 15) and another to the November 17, 2008, hazardous waste
<br /> inspection report (Attachment 16).
<br /> On June 22, 2009, Mr. Cacapit sent a follow up letter to the July 23. 2008, routine UST
<br /> inspection (Attachment 17).
<br /> On July 14, 2009, UPCF Tank forms, monitoring and response plans, financial
<br /> responsibility documents, and a recordable release statement were submitted in
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