Document dY2xXZBa1BDv5MenoR7zRgxDb
August 1, 2024
Via Email: jhrlm@yahoo.com
Alam Jahirul, Operator CONOCO/Yonkers Fuel 380 Riverdale Avenue Yonkers, NY 10705
Subject:
Underground Storage Tank(s) for: Conoco/ Yonkers Fuel, Inc. Located at: 380 Riverdale Avenue, Yonkers, NY 10705 Facility ID Number: 3-800744 ICIS Number: 3601687485
Dear Mr. Jahirul:
Please find enclosed a copy of an inspection report where Mr. Wenjun Liang and Mr. Ron Lockwood of the U.S. Environmental Protection Agency, Region 2 (EPA) conducted an Underground Storage Tank (UST) Inspection on June 27, 2024, in accordance with the Resource Conservation and Recovery Act and Hazardous and Solid Waste Amendments of 1984 ("HSWA"), 42 U.S.C. 6901 et seq. (collectively referred to as "RCRA" or the "Act"). Ranjor Singh/380 Riverdale Reality, LLC owns and/or operates the Underground Storage Tank(s) located at the above-mentioned facility. A "facility" as that term is defined in 40 C.F.R. 280 is subject to the requirements of RCRA Subtitle I regulations.
This letter should not be construed as a compliance determination by the EPA of Ranjor Singh/380 Riverdale Realty, LLC with the UST regulations. However, if areas of concern were identified, please begin rectifying them as soon as possible and make sure to keep records in accordance with the regulations.
Subsequently, my enforcement staff will review the information in our program records and from the inspection determine if further actions are necessary. Once any compliance issues are identified EPA will correspond with you in writing.
If any factual disputes are identified, or you have any questions, please contact Wenjun Liang by email at liang.wenjun@epa.gov or by phone at 212-637-3011.
Thank you for your cooperation.
Sincerely,
GAETANO LAVIGNA
Digitally signed by GAETANO LAVIGNA Date: 2024.08.01 13:49:22 -04'00'
Gaetano LaVigna, Senior Advisor UST Compliance Team Enforcement and Compliance Assurance Division US EPA Region 2
Enclosure EPA Inspection Report
Cc: Ranjor Singh, Owner Manoj Narang 380 Riverdale Realty LLC 2188 Kirby Lane Syosset, NY 11791
2
United
States Environmental Protection Region 2
290 Broadway
New York, NY 10007-1866
Agency (EPA)
Underground Storage Tank (UST) Inspection Form
l'l~w
~
DATE: 1'-1)
ICIS #:
D Tribal
II. Ownership of
D same as location (I.)
Zip Code
EmaillWebsite
D same as location (I.)
Zip Code Fax Number
County
Street Address
County Phone Number: Contact Person(s)
lIe. Own
\ \ '(
Zip Code
EmaillWebsite:
at Other Facilities
D Do you own UST(s) at other UST Facilities Yes /~
If Yes, How many Facilities
_
How many USTs
_
Date Expires:
~-z...'-\
rntiti""ti(1,n noted? (Owner/ Operator/ Substance st~red/ Substance compatibility?) YoN e(
,,,,".,,,~,,,,,""o,p, erators currently trained at each facility? rm,>r,;1""rc training or retraining?
NOD
Yes D No.6
yd Ye~ Nozi NOD
Page 1 of 8
IniUDatetA--- bl<---'/~
01/09/2020
VI. Tank Information
Tank presently in use Ifnot, date last used
Tank No. (see Section XII)
0,)'
00,-
L./' ---
OJ 1
c-:
If empty, verify 1" or less left (see Section XII) Capacity of Tank (gal) Substance Stored Compatibility Records Available?
6 \900 b~~o\:'i'l
bO\9C
'oD':-
G,..~~\..... o ..l~,.(..1
(Compatibility Demonstrated?)
MIY Tank installed/Upgraded
Tank Construction:
Bare Steel, Sti-P3,
Retrofittedsacrificialanode, ImpressedCurrent,
Composite,FRP, Interior lining,Vaulted
Secondary Containment?
Spill Prevention rs 280.20(c)(l)(i),
~ 280.2I(d)1
Double Walled? Y/N
~\~~~
G...",,-tvl
,.)~\
~\,J (A-{'-""
L.,., \.v.,
V;~-try...~ ~'~\","l
(o.)~
~.~pJ
y+-j!<L-1
94\
'0 v.J
Ca-l,-'"
J. .,.",
'()..,J Ce!.f,,1,
._~.'"
If Yes, Last Monthly Check? If No, Last Triennial Containment Integrity Test?
Overfill Prevention (specify type)
rs 280.20(c)(l)(ii), ~ 280.21(d)1
Last Triennial Inspection?
(t/,?Ol-Z-O \"\ '1 H-J /"" ,a, to/,1.:,/ un"
\'I,,~~[e".L\
4\oul"\ 'tf t6l"""'\
H'jh 1(.A-I 00.\ v! '"
q I ~:;,/L-\r''\
H'j\-. 1e,~1
().I~(""
" I so It. ~'\
Seecia/ Contizuration:
Compartmentalized, Manifolded,
Field Constructed,
Airport Hydrant System
VII. Piping Information
'f'(H\~
fr~v'/<"
pr~!"'M-
Pioine Tvoe: Pressure, Suction
Pieing Construction:
Bare Steel, Sacrificial Anode, Impressed Current, Flex,
FRP, Double-walled (DW), Non-corrodible piping
Under Diseenser Containment C'UDC"F YIN If Yes, installation date?
Date oflast visual inspection/periodic monitoring Part of Line RD? Y/N If above Y, UDC Double Walled? Y/N
(:Q. ()
OW
'of
,f(2.p \J~ 'I
f-A P Ow
'(
IfDW, Last Monthly Check of Annular Space? Ifnon-DW or no monthly check ofDW, last 3-Yr
Containment Integrity Test?
Section Continues to Page 3
Page2 of 8 Init/Date \.v.... 6/2. 7 ('Lc2.'1
01/09/2020
V-II. Pi ping Infort nation
Tank No.
(Continued)
Do \
00 2
<?O :1
Secondary Containme t Sump Used for
Re ase Detect on? YIN If Yes, I Containmen Sump Sing elDouble Walled? (SWID\\ ) For SW, prDW w/o m pnthly chec of annular space, last 3- YR integrity bheck/D'W su nps with m nthly monitoring - Last check of Annular spac ?
Tank an d Piping Not s: $..'". i' v~~ i",).1 OPU\ ..J J ~I\J
'f
-t i
I'" \p-t-L..t ,101\ I -I D~' y..,.f "''''''\11101-\ .
VIII. ( orrosion Protee ion ( 280. ;1)
Tank No.
Integrity ssessment con ducted prior o upgrade
nterior Linin
nterior lining inspected
fit uressed Curr nt S crificial Ana ~:
s lining sole protection? Y/N
rp Test Records DO-dayRectifier inspection ecords
rp Test Records
CP Note : (Include n tes of any nterior Lining inspection)
()O \
<?" ?
filM
\../
OJ J
IX.Re ease Detee ion ( 28 l43-Subl'art D)
Y; nk RD Methc 'ds
A.TG
nterstitial Monitoring
-
Groundwater Monitoring*
Vapor Monitoring*
nventory Control wi TIT
-
Manual Tank Gauging
Manual Tank Gauging wi TTT
MO"E 12
Must At,
:,IR
Monitoring Records ( 280.41(a), Available ast 12 Mar. ths
For Corn fiance
280.45(b
* ite assessm nt/installat 'on documentation?
RDE quipment I ast Tested?
I
N/A
v
v-
J
V
VJ
Page 3 of 8 Init/Date \All,. ,'~ 1/'(.,,\
Section Continues on Page 4 01/09/2020
IX. Release Detection
(Continued)
Tank RD Notes: (State What Months Records Were Available, Describe Any Failures and Describe What Investigation Occurred Due to Failure)
Tank No.
tl"'\
Pressurized & Non-Exempt Suction Piping
RD Methods D N/A
O~
ov~
Interstitial Monitoring Groundwater Monitorinz" Vapor Monitoring* Other? (specify)
v
/'
./
OR
Annual Line Tightness Test
AND
Installed? YIN
ALLD Last Annual Test ( 280.44(a)
-
12 Months Monitoring Records ( 280.41 (b)(I)(ii))
*Site assessment/installation documentation?
RD Equipment Last Tested?
Are under Dispenser Containments (UDC) Monitored? via Visual Inspection
via Electronic Monitoring Records of inspections available?
UDC Monitoring Notes: (Records of release: State the past 12 months monitoring records)
Piping RD Notes: (State What Months Records Were Available, Describe Any Failures and Describe What Investigation Occurred Due to Failure)
Page 4 of 8
InitlDatev'l- b{z 71t- 'I.
01109/2020
X. R epairs [ 28( .33 - Subpa 1 C]
N/A I"Y
Repair d tanks and p ping are tig tness tested within 30 days of repair completion CP sy ems are teste linspected ithin 6 months of repair of any cathodically protected UST system Recore s of repairs ar maintained
"OverfiWSpiWSeco hdary Cont inment systems are tested/inspected within 30 days of repair"
XI. '1 emporary Closure B 280.70 - Subpart G]
N/A g"
YoN YoN YoN
0 Unknown 0 0 Unknown 0 0 Unknown 0
CP co tinues to be m aintained
UST s stem contains product and release detection is performed Cap ar ~ secure alllir s, pumps, I anways
YoN YoN YoN
0 Unknown 0 0 Unknown 0 0 Unknown 0
XII. lelease His ory [ 280 50 - Subpart E]
NIA 0
o To \ our knowledge, are there my public or private Drinking Water Wells in the vicinity? Yes I No
,{ Evidence of releas or spills at acility
o Evie ence of releas in the SUITeunding area to the facility
"Reh~ses reporter to implem nting agency; if so, date(s) rll~ I~ Ii'
'9'Rel~ ase confirmec when and ow W:ff'l'-l.",-k' f,.,\ W(, VI' ~I\. -'./'0
0 Greater than 25 gallons (estimate)
I 280.53] (O/ll> /L. o,,~ I/I1/uo-z..
o Initi Iabatement n easures and site characterization
0 Free product removal
~oil br ground wa r contamin tion
0 Corrective action plan submitted
o Rem diation ongo ng
0 Remediation completed, no further action; date(s)
_
rg o Unu ual Operatin Conditions
o Inte stitial Monitor alarms
Notes: N..I.~.. \>~L ~~ ~ t~'U 1'..(~rJ~ ;,\0-{Sf'\\ "''''M\'~/). 02.v'2 \'1 06 O~'\O,
IIrr.fJ ~J dlt~.(J.
,<hJ41..'O
XIll. ~ alkthrou ~h Inspec ions [ 280.36 - Subpart C]
Owne and operato s must cor duct walkthroul}~~of
!!!.H.. have monthl records
Y 0 Nfl?
!;t~l~~~g:
Spill P evention Equ pment - m st be checked for damage, remove liquid or debris, and check fill cap. DW sp I prevention ~quipment WI th interstitial monitoring - must check for leak in interstitial area. Release detection equ pment - mu t check to ensure operating with no alarms and review records of release detection
Yo YoN testing.
Nb
h;I- NI A 0
YoN oJ
!!!.H.. have annual y records
Yo ~
Contai ment sumps must chec for damage, leaks, remove liquid or debris.
DW sumps with inte stitial moni oring - must be checked for leak in interstitial area.
Hand held release de ection equi oment - must check tank gauge sticks or groundwater
bailer.
* Ow ers and ope ators of U~ T system(s) must maintain walkt rouzh ins De tions for one year.
records of operation
and maintenance
Yo N'I2I'
Yo Nil N/Ao
Yo NJ
Page 5 of 8
In it/Date 1IVt.. 617.-? /1- i
01/09/2020
SITE DRAWING
DATE: (o('Z-1/t..{)4 TIME ON SITE: \()._\<;~
TIME OFF SITE: \"'\~'Y"-
WEATHER:
Ii ENVIRONMENTALLY SENSITIVE AREA: YoN 0
I If "Yes", please describe:
CI
o Pictures
Page 6 of 8
IniUOate 6 '2.7(?- i wl.
01/09/2020
..j;'
Facility Name Address UST Reg #
'l",,\(.M") P-l.d
1fo P- ,vl...t",h.. \ J...
)r ~Ov '1'-t~
1-" v
Av-L
'lJlvl.\<--"1
'.'''ROr/
THE UNITED hlK( [)N2USTF
JIIU<
New ~~rk,~~~
~T. TES ENVIRONMENTAL
IROr.RAM
PROTECTION
AGENCY
lage Tank Team ,07-1866
Inspector Observation Report
Inspection of Underground Storage Tanks (USTs)
(EPA)
o No ~reas ' concan observed at ~he conclusion of this inspection.
.." Thl above name facility was inspected by a duly authorized , and/or F"V""""'''U'''' corrective action(s):
representative
of EPA Region 2, and the following
Area! I of Concern Ob ~erved:
RA-n", 6t"l) Citation
I 2~c7', '\. ') i ':l~(), '-t3.
t,~o v( ,
iAre. of Concern
IV'. llA~~\.A tx r;,...)J.
f(.ruQW 01 ~k~ r"l\ *.<Q,.J.,~'\.
./
fif"~
-t.P.(.j \'{l '"
'\1' g-\
f..\ (()JI
LvI. rI~,
...'.\
i
are the inspector's
1STaken: AC;:~:~ Citation; #
o Additional information required 0 On-site request/Due date
.. Com ~.~
e~ .~ (l.!..~vtJ
..~
,'4' >"'- 0.. -I'v~
! (llrJ1
- (+, ", ~I"'~ Pt ('+d.t,..,.. 'i. , , fJ ~''''j - OJ).. ,
-;:1",\,( ,'1-5"' ) ~O"l..."l, )'rI \ \ f f'.L ".v.-.t >'V'\ , ,41' (., I
/Lt-C. .
I
I
I
Title pfUSTOw'le
""'I'" ,'"
M IName lof UST ~:11.
Me141'1
.""''''I'''
M$
~""~f}JiA
(JDY
/rrJ
(Pleas. !~t)_/c2c'
~
~"''''''
19k\t ~elf-wf I~"'''''-""''''1'''''''''''.
(Signa'
,
~
J
Name of EPA Inspector/representative:
"" Q VI.~";"('\ L,,,,,,,,,
t..
/J ~
~?--
J (PleaSep~
~
(Signature)
~l<~J
/~~
r,.,.-z
(Credential Number)
. a " IS' 6/2 Date of Inspection
1 / 7.-0V .~.. r ime
AM/PM
Page 7 of 8
InitlDate "Ir-'l- V Zl( 1-~
01/09/2020
Documents Not Available During the On-Site Inspection Please Provide As Soon As Possible
f Locati.on: io.}.,',.,("("'c '>
A . \
..
7- &,oJ"'14't
V'~
~-----------------------------
Facility ID Number:
_
o Tank Registration Certificate o Operator Training Records (Individuals training or retraining) b"'Demonstrate Financial Responsibility o Automatic Line Leak Detector Test Records - Annual o Line Leak Test Records - Annual o Evidence of Spill Prevention o Evidence of Overfill Prevention
-6'Tank Release Detection Records
o Vapor Monitoring Records - Monthly (12 Most Recent Months) o Under Dispenser Containment (Visual inspection or electronic monitoring) o Site Assessment to Demonstrate Monitor Wells Properly Installed/Located o Documentation of Compatibility for UST Systems o Corrosion Protection Inspection Records s-Documentation of Periodic Walk-through Inspection if'Walkthrough Inspection Records - Monthly and Annually
VOther (specify) 1..t.c{,~ 6r: O.Ju(,I", 5,\\ e"uJ."o,l(,,,,,,
Additional Recommendations:
Page 8 of 8
bI InitlDate Vl,..
'Z-1 IV'\
_
01109/2020
Requin d Fields to )e used to ICIS Only
Comoli: nce Monitoriha Activity: UST Inspec on Insoectibn Conclusich Data ShElet 1) Did you obsen e deficien ies (areas of concern during the on-site inspection?
Deficier cies observe d: (Put an I{ for each observed deficiency)
_ Potential failure 0 cornpletr or submit a notification, report, certification, or manifest _ Potential failure 0 follow or develop a required management practice or procedure ,./' Potential failure 0 maintain a record or failure to disclose a document
.../Pot~ntial failure 0 maintain inspect/repair meters, sensors, and recording equipment _ Potential failure 0 report rebulated events, such as spills, accidents, etc.
2) If yo observed d ~ficiencies, did you communicate the deficiencies to the Facility during the inspection? & I No
3) Did ~ou observe the Facilit take any actions during the inspection to address the deficiencies noted? Yes It)
If yEs, what actic ns were ta en? 4) Did you provide general Compliance Assistance in accordance with the policy on the role of the EPA Inspector
In p oviding Corr pliance As istance during Inspections? "@ I No
5) Did !You provide Isite-specifif. Compliance Assistance in ~<)~rdance with the policy on the role of the EPA Inspector in providing Compliance Assis ance during the inspection? ~I No
This report was reviewed and deerr ed complete by: Reviewer Signature Date
Gaetano LaVigna Digitally signed by GAETANO
GAETANO LAVIGNA LAVIGNA Date: 2024.08.01 13:48:54 -04'00'
Page 1 of 1
Init/Date -\/-L--M-<7(~
01/09/2020
Regulatory Subject Area
Measure #
Release Prevention Compliance Measures Matrix
SOC Measure I Federal Citation
I. Spill Prevention II. Overfill Prevention
III a. Operation and Maintenance III b. Operation and
Maintenance of Corrosion Protection
1
Spill prevention device is present and functional. [280.20(c)(1)(i), 280.21(d)]
2
Overfill prevention device is present and operational. [280.20(c)(1)(ii), 280.21(d)]
o Automatic shutoff is operational (ie., device not tampered with or inoperable)
[280.20(c)(1)(ii)(A),280.21(d)]
~Iarm
is operational. [280.20(c)(1) (ii)(B), 280.21(d)]
~Iarm
is audible or visible to delivery driver. [280.20(c)(1) (ii)(B), 280.21(d)]
o Ball float is operational. [280.20(c)(1)(ii)(B), 280.21(d)]
3
Repaired tanks and piping were tightness tested within 30 days of repair completion (not
required w/internal inspections or if monthly monitoring is in use). [280.33(d)]
4
CP systems were tested/inspected within 6 months of repair of any cathodically protected UST
system. [280.33(e)]
5
Corrosion protection system is properly operated and maintained to provide continuous
protection. [280.31(a)(b), 280.70(a)]
DUST system (Choose one)
DUST in operation
DUST in temporary closure
o CP System is properly operated and maintained
o CP system is performing adequately based on results of testing. [280.31(b)]j - oro CP system tested within required period and operator is conducting or has completed
appropriate repair in response to test results reflecting CP system not providing adequate protection.
In Compliance?
N/A y
N
/
Iv
1-/
v'
./
9/30/03
10f2
' ...
SuhiM't Are.
Mruuure#
Release Prevention Compliance Measures Matrix
snc
./ FII!d", 1
In ~
.,
..
III b. Operation and Maintenance of Corrosion Protection
(Continued)
N/A Y N
6
UST systems with impressed current cathodic protection are inspected every 60 days. [280.31(c)
1/
7
Lined tanks are inspected periodically and lining is in compliance. [280.21(b)(I)(ii)
c/
TV_Tank and Pinine
R
Ruried metal.tank and nininlJlwhi"h in,.llId .~ fittin ~
. '"~ etc_)iSCll,.rn~inn
-'
/
Corrosion Protection
[280.20(a), 280.20(b), 280.21(b), 280.21(c)]
o Buried metal piping components (such as swing joints, flex-connector,
the soil or cathodically protected.
etc.) are isolated from
For new USTs - tanks and piping installed after 12/22/88 [280.20(a),280.20(b)]:
o Steel tank or piping is coated with suitable
(280.20(a)(2),280.20(b)(2)J
dielectric
material
and cathodically
protected.
o Tank is fiberglass, clad, or jacketed and piping is fiberglass
280.20(a)(3), 280.20(a)(5), 280.20(b)(I), 280.20(b)(4)
or flexible plastic.
(280.20(a)(I),
0 Records are available to document that CP is not necessary. [280.20(a)(4)(ii), 280.20(b )(3)(ii) I
For existing USTs - tanks and piping installed on or before 12/22/88 [280.21(b), 280.21(c): 0
Tank and piping meet new UST requirements (280.21(a)(I)
o Steel tank is internally lined. [280.21 (b)( o Metal tank and piping are cathodically protected.
(280.21(b)(2), 280.21(c)J
Notes: N/A - Indicates that the measure is not applicable. Any mark in the "N" (No) column means that the facility is not in Significant Operational Compliance (SOC) with Release Prevention Compliance Measures. In order for a compliance measure to be in SOC, all applicable check-box items must be in compliance.
9/30/03
20f2
Rei -- - D- e-t-e-c-t-'---- C r - ----r-------- M,
Mat'
Instructions - To Determine Compliance Status of Measures #1-7, Work Through the Worksheet "Commonly Used Release Detection Methods"
Below.
Regulatory Subject Area I. Release Detection Method Presence and Performance Requirements
II. Release Detection Testing
III. Hazardous Substance UST Systems IV. Temporary Closure
Measure # 1 2 3 4
5
6 7
SOC Measurel Federal Citation
Release detection method is present. [280.40(a)[ Release detection system is operating properly (i.e., able to detect a release from any portion of the system that routinely contains product). [(280.40(a)(I)]
Release detection system meets the performance [(280.40(a)(3)]
standards
at 280.43 or 280.44.
oImplementing aaencv has been notified of suspected release as required. 1(280.40(b)I Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)]
Tanks and piping are monitored monthly for releases and records are available (must have records for the two most recent consecutive months and for 8 months ofthe last 12 months). 1280.41(a), and 280.45(b)I
Hazardous substance UST system leak detection meets the requirements (i.e., either secondarily contained or otherwise approved by the implementing agency). [280.42(b)]
Release detection requirements are complied with (i.e., method present, operational, releases investigated and reported as required) for UST systems containing product. 1280.70( a) I
I. f'nmnlill n"e"
NIA
Y
N
V
V
V'
V
./
V
V
Tank
(Ch oa.)
0
Pressurize dPipe
(ChoooeTw.)
9/30/03
Worksheet - Commonly Used Release Detection Methods
Non-exempt Suction Pipe
ICh 1
Release Detection Method
A. Inventory Control with Tank Tightness Testing (T.T.T)
o Inventory control is conducted properly. o T.T.T. performed as required (See "D" below). o Inventory volume measurements for inputs, withdrawals, and remaining amounts are recorded each operating
day and reconciled as required. [280.43(a)(I), 280.43(aX3)]
o Equipment is capable of lI8-inch measurement. [280.43(a)(2)] o Product dispensing is metered and recorded within local standards for meter calibration to required accuracy.
[280.43(a)(5)]
o Water is monitored at least monthly. [280.43(a)(6)]
lof3
Release Detection Compliance Measures Matrix
. . Worksbeet (CmilimIed) - Cnmmnnlv Used n.~I. r
..t' . L ..:I
Tank
~
Pressurize dPipe
Cl
Cl
u
o
u
aI
'a'
Non-exempt Suction D'
-eICb_1
o
u
u
Release Detection Method
B. Automatic Tank Gauge (ATG)
o ATG is set up properly. [2S0.40(a)(2)] o ATG can detect a 0.2 gal/hr leak rate from any portion of the tank routinely containing product. [2S0.43(d)(I)] 0
ATG is checking portion of tank that routinely contains product. [2S0.40(a)(I)]
C. Manual Tank Gauging (MTG)
o Tank size is appropriate for using MTG. [2S0.43(b)(5)]
0 Tanks 1001 gals (as per EPA memo) and greater restricted to use with T.T.T. (See "D" below) 0 Method is being conducted correctly. [2S0.43(b)(4)]
o No liquid was added to or taken out of the tank during the test. [2S0.43(b)(1)] 0
Equipment is capable of 1/S-inch measurement. [2S0.43(b)(3)]
D. Tightness Testing (Safe Suction piping does not require testing)
o Testing method is capable of detecting a 0.1 gal/hr leak rate from any portion of tank routinely containing product.
[2S0.43(c)]
o Tightness testing is conducted within specified time frames for method: o Tanks - every 5 years [2S0.41(a)(I)] o Pressurized Piping - annually [2S0.4I(b)(J)(ii)] o Non-exempt suction piping - every 3 years [2S0.41 (b)(2)]
o Tightness testing is conducted following manufacturer's instructions. [2S0.40(a)(3)]
E. Ground Water or Vapor Monitoring
o Ground water in the monitoring well is never more than 20 feet from the ground surface. [2S0.43(t)(2)] 0
Vapor monitoring well is not affected by high ground water. [2S0.43(e)(3)]
o Site assessment has been done for vapor or ground water monitoring. [2S0.43(e)(6), 2S0.43(t)(7)] 0
Wells are properly designed and positioned. [2S0.43(e)(6), 2S0.43(f)(7)]
F. Interstitial Monitoring
o Secondary containment can be used to detect a release o Sensor properly positioned. [2S0.40(a)(2)]
[2S0.43(g)( I)], 2S0.43(g)(2)]
9/30/03
2of3
Release Detection Compliance Measures Matrix Worksheet (Continued) - Commonly Used Release Detection Methods
Tank
Pressurize
Non-exempt
dPipe
Suction
(Ch )
(a. ,...)
-
Pipe
(Ch )
Release Detection Method
D
G. Automatic Line Leak Detector (ALLD)
o ALLD is present and operational. [280.44(a)]
o Annual function test of the ALLD has been conducted and records are available. [280.44(a)]
D
D
D
H. Other Methods [e.g., Statistical Inventory Reconciliation (S.I.R.))
o The method can detect a 0.2 gal/hr leak rate or a release of 150 gal within a month and meet the 95/5 requirement
[280.43(h)(I)]; or
o The implementing agency has approved the method as being as effective as tank tightness testing, automatic tank
gauging, vapor monitoring, ground water monitoring, or interstitial monitoring and the operator complies with any conditions imposed by agency. [280.43(h)(2)]
o S.I.R. - Results are received within time frame established by implementing agency. [280.4 I(a) & 280.43(h)]
Notes:
N/A - Indicates that the measure is not applicable. Any mark in the "N" (No) column means that the facility is not in Significant Operational Compliance Measures. In order for a compliance measure to be in SOC, all applicable check-box items must be in compliance.
(SOC) with Release Detection
Compliance
9/30/03
30f3
Called Suleyman Issi (Operator listed on the registration) on 7/10/2024 to ask about documents held offsite which has not been emailed yet. Mr. Issi informed me that he has not worked at that location for 2 years and his information should not be posted at the facility. Mr. Issi then provided me with a number to Alam (516-960-8333), who he says works at the facility. Both Suleyman Issi and Alam Jahirul's Class A/B Operator Authorization are posted on-site.
7/11/2024: Called 914-423-8896 (number listed on Google Map for the facility), no one answered the phone.
Called Alam Jahirul and he provided his email (jhrllm@yahoo.com) to follow up on. Requested a list of documents we requested at inspection: insurance (only expired quotation available at inspection), list of operators, 30 day and annual walkthrough records, pictures of sump (tool for opening sumps not available at inspection), and testing for; overfill prevention, spill prevention, piping, under-dispenser containment, release detection.