ALTOGETHER, THERE WERE TWO TYPES OF VIOLATIONS AT THE FACILITIES, DESCRIBED AS FOLLOWS: AT ITS FIFTEEN FACILITIES, THE RESPONDENT HAD AUTOMATIC LINE LEAK DETECTORS (ALLD) IN PLACE THAT COULD HAVE BEEN UTILIZED FOR PIPING RELEASE DETECTION FROM ITS PRESSURIZED LINES. IN ADDITION, AT THIRTEEN OF THE FACILITIES, THE RESPONDENT HAD SUMP SENSORS FOR THE LINES THAT COULD DETECT LEAKS AND SERVE A SUBSTITUTE FOR THE ALLDS. THE UST PROGRAM REQUIRES OWNERS/OPERATORS OF UST SYSTEMS TO ANNUAL TEST THEIR LLDS. FOR THE TWO FACILITIES THAT DID NOT HAVE SUMP SENSORS, THE RESPONDENT DID NOT TEST THE ALLDS FOR ABOUT TWO YEARS, PLUS AN ADDITIONAL PERIOD OF FIVE MONTHS FOR ONE FACILITY. FOR ONE OF THE FACILITIES WITH ALLDS AND SUMP SENSORS, THE RESPONDENT DID NOT TEST THE ALLDS AND SUMP SENSORS FOR ABOUT TWO YEARS, PLUS AN ADDITIONAL PERIOD OF FIVE MONTHS. AT THE OTHER TWELVE FACILITIES FOR AT LEAST A YEAR, THE RESPONDENT DID NOT TEST THE SUMP SENSORS, WHICH WERE BEING USED TO ACT AS THE FACILITIES' LINELEAK DETECTORS.
FOR THE OTHER TYPE OF VIOLATION, ALL OWNERS AND OPERATORS OF PETROLEUM UST SYSTEMS WITH PRESSURIZED PIPING MUST HAVE AN ANNUAL LINE TIGHTNESS TEST OR HAVE MONTHLY MONITORING OF HTE PIPING. (THE REQUIREMENT TO HAVE EITHER IS KNOWN AS THE REQUIREMENT TO HAVE SECONDARY PIPING RELEASE DETECTION.) AT TWO FACILITY FOR VARYING PERIOD OF TIME BUT FOR ALMOST TWO YEARS AT BOTH, THE RESPONDENT DID NOT CONDUCT SECONDARY PIPING RELEASE DETECTION.