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response to the July 23, 2008, UST inspection report (Attachment 18). Mr. Cacapit
<br /> faxed Mr. Kiumars Khajevandi, Partner, and asked him to provide additional information
<br /> on the monitoring plan regarding overfill prevention.
<br /> On July 30, 2009, Mr. Cacapit and Ms. Thuy Tran, Senior REHS, EHD, performed a
<br /> routine UST inspection and witnessed the monitoring system certification, leak detector
<br /> testing, and spill container testing. Secondary containment testing, due once every
<br /> three years, was last performed on July 10, 2006, and has not been completed or
<br /> scheduled. An alarm on August 8, 2008, at the annular sensor for the 87-octane master
<br /> UST was not documented in the facility's alarm log or the designated operator's monthly
<br /> inspection report. The only employee on site, Assistant Manager Sina Khajevandi, was
<br /> not trained by the designated operator (Attachment 19).
<br /> On August 7, 2009, a return to compliance certification, part of a designated operator
<br /> monthly inspection report, designated operator employee training records, and an
<br /> updated page 2 of the monitoring plan were submitted (Attachment 20).
<br /> On September 16, 2009, permit application, SR0058350, was submitted to replace the
<br /> leak detector on the diesel UST. Mr. Cacapit approved the permit on September 21,
<br /> 2009 (Attachment 21).
<br /> On September 17, 2009, Mr. Cacapit sent a fax to Mr. Khajevandi asking for corrective
<br /> actions statements for the last UST and hazardous waste inspections, secondary
<br /> containment test results, return to compliance certification for the hazardous waste
<br /> inspection, valid EPA ID number, and copies of hazardous waste disposal records for
<br /> the past three years. Copies of the last inspection reports and blank forms were
<br /> included (Attachment 22).
<br /> On September 21, 2009, items were submitted in response to the September 17, 2009,
<br /> fax (Attachment 23). A return to compliance certification and a complete corrective
<br /> actions statement for the November 17, 2008, hazardous waste inspection were still
<br /> lacking. Test results for secondary containment testing performed on August 14, 2009,
<br /> were also submitted (Attachment 24). The report indicated that the EHD was notified by
<br /> phone on August 12, 2009, but there was no record of the EHD ever being notified. Mr.
<br /> Cacapit called the tester, Mr. Randy Johnson, regarding the 48-hour testing notification.
<br /> Mr. Johnson stated that he would fax Mr. Cacapit documentation that he notified the
<br /> EHD.
<br /> On September 22, 2009, Mr. Cacapit sent a follow up fax to Mr. Khajevandi asking for a
<br /> return to compliance certification and corrective actions statement for the November 17,
<br /> 2008, hazardous waste inspection report (Attachment 25).
<br /> On October 13, 2009, a monitoring system test report was submitted for testing
<br /> performed on July 30, 2009 (Attachment 26).
<br /> On October 22, 2009, Ms. Tran witnessed the successful testing of the leak detector on
<br /> the diesel UST. Testing was performed at dispenser 9/10 and Ms. Tran noticed a
<br /> continuous stream of diesel leaking from a component of the dispenser (Attachment 27).
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