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Michelle Henry, Environ. Hea'Tth Dept. October 8, 2008 Response to B879 and B882 UST Violations Issued by San Joaquin County Page 2 Environ. Health Dept. to LLNL, Site 300 EPA ID No. CA2890090002 Monitoring & Response plan must be kept current at all times. The response plan for both site 879 & 882 listed employees who no longer work for LLNL as the responsible person. Win 30 days (10-8-08) submit a current copy of the response plan to this department for review & approval. Once the plan has been approved a signed copy will be returned to the facility. Response: The Response Plans for the Building 879 and Building 882 tank systems have been updated with the current employees listed and are enclosed in Attachment 3. Revised Monitoring Plans for the Building 879 and Building 882 tank systems are also enclosed in Attachment 3. Violation: #7. CCR 2712 (b) Maintenance & Monitoring records (879) (#7 refers to the violation number on the Underground Storage Tank Program Inspection Report.) #32. CCR 2661 Permit to repair UST system (#32 refers to the violation number on the Underground Storage Tank Program Inspection Report.) On October 15, 2007 a ECPU board was replaced without a permit from this office. Upon review of the maintenance records there is no record from C Petroleum. A permit was required prior to the installation/replacement of the ECPU board. Maintenance records must also be maintained on site for review. Win 30 days (10-8-08) submit a copy of the maintenance record for the work performed. Take all necessary precautions to avoid work being done w/out approved permits from this department. Response: The maintenance record for installation of an ECPU board on October 15, 2007 by Central Petroleum Maintenance is enclosed as Attachment 4. The maintenance record for installation of the ECPU board by Central Petroleum Maintenance has been placed in the Building 879 maintenance file at the tank site. Program staff have been informed that maintenance, repairs, and upgrades are not to be performed on the Underground Storage Tank systems prior to acquiring an approved permit. Violation: #18. CCR 2635 (b)(1) Spill container (879) (#18 refers to the violation number on the Underground Storage Tank Program Inspection Report.) Spill bucket on 87 tank failed to hold minimum of 5 gallon water during 1 hour hydrostatic or equivalent (Caldwell system) Spill buckets must be capable of holding a minimum of 5 gallons of liquid. Immediately obtain permit from this office to repair / replace spill bucket. NOTE: Onsite Technician believes failure is a result of the cap. Immediately discontinue deposition of petroleum into this tank until the component is repaired/replaced by a properly licensed, trained & certified contractor under permit by this office. PRAD08:125:CSJ: W WS:rtd