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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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