|
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 FILE 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). 1
<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
<br />2
<br />
|