On November 28, 2003, Posen Oil reported a release of diesel fuel additive at their facility at 2739 West 139th Street. Based on this release, the facility was selected for an inspection. Further investigation revealed that the diesel fuel additive spill occurred on a concrete floor inside a building and thus was not a release to the environment. However, it was also discovered that Posen Oil had not submitted a TIER Form since March 15, 2001 for the calendar year 2000, which reported diesel fuel and gasohol in excess of 10,000 pounds. During conversation with facility personnel at Posen Oil, it was revealed that a second location at 14200 Division contained large storage tanks. An inspection was scheduled for both locations on February 4, 2004. George Rancich and Ginger Jager conducted the inspection.
The location at 2739 West 139th Street was determined to be company offices and a small storage area for �consumer level� containers of motor oil, windshield washer fluid, etc. The inspection at 14200 Division revealed two large above ground storage tanks containing diesel fuel, an underground tank containing gasohol, and two underground tanks containing diesel fuel. At the time of the inspection, Posen Oil provided us with the maximum values for gasohol, #2 diesel, and #1 diesel.
Gasohol, #2 diesel, and #1 diesel were found to be above the 10,000 lb threshold, and #1 diesel was 588 times the threshold. Posen Oil violated EPRCA 312 by not submitting TIER fo