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On March 26, 2007, monitoring and response plans were submitted. Mr. Yang approved
<br />the plans and faxed them to the facility on April 20, 2007 (Attachment 6).
<br />On September 6, 2007, Ms. Michelle Henry, Senior RENS, EHD, performed a routine
<br />UST inspection (Attachment 7) and witnessed the annual monitoring system certification,
<br />leak detector testing, and spill container testing (Attachment 8). During the inspection,
<br />Ms. Henry found approximately one inch of liquid in each of the 87 -octane and diesel
<br />piping sumps, the diesel leak detector failed when tested, and the 87 -octane and diesel
<br />spill containers failed when tested. A review of the facility's paperwork showed that Mr.
<br />Heng Chea and Mr. Fong Chea did not have current training by the designated operator.
<br />On September 6, 2007, Ms. Henry also performed a routine hazardous waste inspection
<br />and found that the facility did not have an active Environmental Protection Agency (EPA)
<br />Identification Number to manage hazardous waste (Attachment 9). A hazardous waste
<br />container was also found improperly labeled.
<br />On October 5, 2007, Ms. Henry approved a permit application, SR0051851, submitted
<br />by Elite IV Contractors (Elite IV) on September 6, 2007, for the replacement of the diesel
<br />leak detector and the 87 -octane and diesel spill containers and drop tubes. This permit
<br />application was later amended and approved on November 5, 2007, to include replacing
<br />the 87 -octane piping sump sensor (Attachment 10).
<br />On October 22, 2007, a return to compliance certification and corrective actions
<br />statement addressing all the violations noted in the UST and hazardous waste
<br />inspections were submitted (Attachment 11).
<br />On November 7, 2007, Ms. Henry verified corrosion protection on the diesel spill
<br />container and riser, and that the overfill prevention for the diesel tank was set at 95%
<br />(Attachment 12). The drop tube for the 87 -octane tank was not changed.
<br />On November 13, 2007, Ms. Henry verified the functionality of the diesel leak detector
<br />and the 87 -octane piping sump sensor, the capacity of the diesel and 87 -octane spill
<br />containers, and witnessed a one-hour lake test of the two spill containers (Attachment
<br />13).
<br />On December 3, 2007, a test report was submitted for a tank integrity test on the 87 -
<br />octane and diesel tanks. Both passed on November 19, 2007 (Attachment 14).
<br />On December 28, 2007, a permit application, SR0053021, was submitted by Elite IV to
<br />replace the diesel leak detector. This permit was approved on January 4, 2008
<br />(Attachment 15).
<br />On January 23, 2008, Ms. Henry witnessed testing of the new diesel leak detector
<br />(Attachment 16).
<br />On September 8, 2008, Mr. Aris Cacapit, REHS, EHD, performed a routine LIST
<br />inspection (Attachment 17) and witnessed the annual monitoring system certification,
<br />leak detector testing, and spill container testing (Attachment 18). Mr. Cacapit found that
<br />the sensor in under dispenser containment (UDC) sump 3/4 was not located to detect a
<br />leak at the earliest opportunity, and was placed on a cross bar near the top of the UDC
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