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On November 4, 2009, Mr. Cacapit attempted to contact Mr. Johnson by phone
<br />regarding the 48-hour notification for the August 14, 2009 secondary containment
<br />testing. There was no answer.
<br />On November 5, 2009, Mr. Cacapit sent another follow up fax to Mr. Khajevandi asking
<br />for a return to compliance certification and corrective actions statement for the
<br />November 17, 2008, hazardous waste inspection report (Attachment 28).
<br />On November 6, 2009, Mr. Cacapit spoke to Mr. Johnson and asked about the 48-hour
<br />notification. Mr. Johnson stated that he remembered that he was supposed to send
<br />documentation that he provided notification for the testing, and that he would send it that
<br />day.
<br />On November 17, 2009, Mr. Cacapit sent a letter to the facility informing Mr. Khajevandi
<br />and Ms. Haleh Amiri, Partner, that the EHD has rejected the August 14, 2009, secondary
<br />containment test results and that testing would have to be immediately scheduled, 48-
<br />hour notification provided to the EHD, and completed (Attachment 29).
<br />On December 3, 2009, notification for secondary containment testing on December 7,
<br />2009, was submitted (Attachment 30).
<br />On December 4, 2009, lab analysis for soil cuttings, disposal receipt for two drums of
<br />soil cuttings, and a disposal receipt for a container of used oil filters was submitted
<br />(Attachment 31). A corrective actions statement for the November 8, 2008, hazardous
<br />waste inspection and disposal receipts for two containers found on site during the July
<br />30, 2008, but not during the November 8, 2008, inspection were still lacking.
<br />On December 29, 2009, a secondary containment test report was submitted for testing
<br />performed on December 7, 2009 (Attachment 32).
<br />On July 26, 2010, Mr. Jeffrey Wong, Senior REHS, EHD, performed a routine hazardous
<br />waste inspection (Attachment 33). A monitoring system certification was also scheduled
<br />for the day, but the testing company called to reschedule after Mr. Wong had arrived on
<br />site. During the inspection, Mr. Wong found a 55 -gallon container labeled "Drained
<br />Used Oil and Gasoline Filters" that contained three filters, a used dispenser nozzle and
<br />hose, and approximately 15-20 gallons of oily liquid. Eight universal waste fluorescent
<br />bulbs were not stored in a closed container and it could not be determined how long the
<br />lamps had been stored. Photos are attached (Attachment 34).
<br />On July 28, 2010, Mr. Cacapit performed a routine UST inspection and witnessed the
<br />monitoring system certification, leak detector testing, and spill container testing. The 91 -
<br />octane fill sump sensor failed when tested (and was replaced on site), leaks were found
<br />in dispensers 5/6 and 9/10, and approximately one quart of liquid was found in the 91 -
<br />octane piping sump and approximately'/2 gallon of liquid was found in the diesel piping
<br />sump. During a review of the facility's paperwork, Mr. Cacapit found that secondary
<br />containment was last performed five months late and financial responsibility documents
<br />were submitted one month late. The UST operating permit and maintenance records for
<br />nine alarms were not found on site. In the designated operator monthly inspection
<br />reports, two alarms were not documented in the monthly inspection reports and
<br />secondary containment test dates were incorrectly noted. Mr. Khajevandi was working
<br />alone and he did not have current training by the designated operator. Mr. Cacapit did
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