Document 0LJQq24B402EREQmzNj4VG2dO

COMPLIANCE EVALUATION INSPECTION REPORT FOR UNDERGROUND STORAGE TANKS EPA Region 6 Federal Form FID #: 0157NM FACILITY NAME: TEWA Market and Fuel at Totavi INSPECTION DATE(S): 9-26-23 Tribal Land: Pueblo of San Ildefonso Physical Address: City, State, Zip: Mailing Address: Facility Representative Title and E-mail: 2007 Highway 502 Santa Fe, NM 87506 same (Address) (City) Mark Crim Mcrim@sanisvcs.com Phone: County 505-455-1940 Santa Fe (State) (Zip) UST Operator: Pueblo de San Ildefonso Phone: 505-455-4123 Fax: Mailing Address: 02 Tunyo Po Santa Fe NM 87506 (Address) (City) (State) (Zip) UST Contact: Mailing Address: Mark Crim 02 Tunyo Po Phone: 803-476-6878 Santa Fe Fax: NM 87506 (Address) (City) (State) (Zip) UST Owner: Pueblo de San Ildefonso Phone: 505-455-4123 Fax: Mailing Address: 02 Tunyo Po Santa Fe NM 87506 (Address) Contact Name and E-mail: Mark Crim Mcrim@sanisvcs.com (City) (State) (Zip) Phone Number: 803-476-6878 Facility Land Tribally Owned: Yes No Facility Privately Owned/Leased on Tribal Land: Yes No Lead Inspector: Joshua Ridley Additional Inspector(s) and Others present: Leonard Sabatino Summary of Findings and Facility Comments: Facility clean and dry. Numerous potential violations pertaining to testing and document retention. EPA REGION 6 UST CEI CHECKLIST 1/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Start Time (miltary time): 1130 End Time (miltary time): 120 Compliance Performance Measures (CPM) in TCR Overall (TCR): YES NO Spill Prevention: YES NO Overfill Prevention: YES NO Corrosion Protection: YES NO Release Detection: YES NO Type of Inspection: CEI Follow Up Compliance Assistance Compliance Performance Measures (CPM) Not in TCR Operator Training: YES NO Financial Responsibility: YES NO Walkthroughs: YES NO Comments: Numerous potential violations pertaining to testing and document retention. Facility given 30 days to provide testing and documentation. Printed Name, Title Joshua Ridley, Inspector Inspector Signature JOSHUA RIDLEY Digitally signed by JOSHUA RIDLEY Date: 2023.11.08 12:56:43 -06'00' Peer Review by: Ruben Moya (Date) 11/3/23 Supervisors Name, Title Robert Snowbarger, Section Chief Supervisors Signature ROBERT SNOWBARGER Date: 2023.11.13 11:34:24 -06'00' Digitally signed by ROBERT SNOWBARGER EPA REGION 6 UST CEI CHECKLIST 2/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Section A Registration Requirements 1. Are all New and Existing Petroleum UST systems registered? ( 280.22(a) TANK SIZE of TANK PRODUCT NO. (GALLONS) STORED 1a 20,000 Reg TANK TYPE SW / DW DW FRP STATUS Active or TC A Compartment or Manifold Compartment Manifold 1b 10,000 Prem DW FRP A Compartment Manifold 2a 8000 Reg DW FRP A Compartment Manifold 2b 4000 Diesel DW FRP A Compartment Manifold 3 12000 Diesel DW FRP A Compartment Manifold Compartment Manifold Further Explanation Attached Yes No N/A INSTALL DATE 11/28/2007 UPGRADE DATE 11/28/2007 11/28/2007 11/28/2007 11/28/2007 Compartment Manifold Latitude: 35 52' 27.84" Longitude: -106 10' 42.96" Compartment Manifold Compartment Manifold Compartment Manifold Number of Dispenser's: See Below GPS Measured At: Input Tank # fill- port. 1a Section A Comments: GPS measurement in Decimal Degrees: 35.8744 -106.1786 Tanks 1A and 1B are compartments Tanks 1A and 2A are manifolds Tanks 1B and 3 are compartments Tanks 2B and 3 are manifolds Dispensers: 8 X 2 auto side 3 X 1 truck side EPA REGION 6 UST CEI CHECKLIST 3/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Compliance Performance Measures (CPM) in Technical Compliance Rate (TCR) CPM - Corrosion Protection Section B Standards for New Underground Storage Tanks (Tanks installed after 12/22/88) Further Explanation in Narrative Section B Not Applicable 1. Tank Construction: UST- 9c.a SW DW a. Is each tank properly designed and constructed to prevent corrosion in any portion of the Yes No N/A tank that routinely contains product?(280.20(a)) b. If installed after 4/11/16 is tank secondarily contained? 280.20 Yes No N/A 2. What is the corrosion protection method for the tanks? UST- 9c.a a. Fiberglass reinforced plastic-FRP (280.20(a)(1)) Yes No N/A b. Tank constructed of metal and cathodically protected e.g. galvantic - STI-P3, metal tank with impressed current system (280.20(a)(2)) Specify: Yes No N/A c. Metal-fiberglass-reinforced-plastic composite (ACT-100) (280.20(a)(3)) Yes No N/A d. Records available to document that Corrosion Protection is not necessary. (280.20(a)(4)) Yes No N/A e. Other corrosion protection (280.20(a)(5)) Specify: 3. Have repairs been conducted on any tank? Yes No Tank #: Repair Date: a. Were repairs to tanks conducted in accordance with accepted codes and standards? (280.33(a)) b. Were repairs to fiberglass-reinforced tanks conducted by manufacturer's authorized representatives or in accordance with accepted codes and standards? (280.33(b)) Yes No N/A Yes No N/A c. Were the repaired tanks tightness tested within 30 days of the completion of the repair (280.33(d)) unless inspected, monitored or otherwise tested? (280.33(d)(1, 2, 3)) Yes No N/A Section B Comments: Section C Upgrading Existing Tanks to New System Standards Further Explanation in Narrative (Tanks installed on or before 12/22/88) Section C Not Applicable 1 Do the Existing Tank(s) comply with one of the following requirements: UST- 9c.a a. Are all existing tanks upgraded to meet the standards or do they already meet the stardards for New UST systems?(280.21) Yes No N/A If yes, specify tank type: b. Are all existing tanks upgraded with cathodic protection?(280.21(b))If yes, complete 2. What method of corrosion protection is used for each tank? UST- 9c.e a. Metal tank retrofitted with interior lining (280.21(b)(1)) Date Lining Installed: Yes No N/A Yes No N/A b. Is lining inspected periodically? (280.21(b)(1)(ii)) Date of Last Lining Inspection: Metal tank retrofitted with cathodic protection (280.21(b)(2)) c. Type of CP: If tank >10 years old when CP was added, was a tank integrity test performed? d. (280.21(b)(2)(i) UST- 9c.e Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 4/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Type of integrity test performed: Date: e. Internal Lining combined with cathodic protection (280.21(b)(3)) If CP was not installed at same time as the lining, complete section C.2.d above. f. Other corrosion protection. Specify: Section C Comments: Yes No N/A Yes No N/A Section D Standards for New/Existing UST Piping System (Piping installed after 04/11/2016 must be secondarily contained) (Piping installed after 12/22/88) 1a. For piping installed after 04/11/2016, is it secondarily contained?(280.20) 1b. For piping installed before 04/11/2016 indicate double / single wall Further Explanation in Narrative Section D Not Applicable Yes No N/A Double Wall Single Wall 2. Is piping that routinely contains regulated substances and is in contact with the ground or water Yes No N/A designed, constructed, and protected to prevent corrosion? (280.20(b) new/ 280.21(c) existing) UST-9c.a 3. What method of corrosion protection is used for the piping? UST-9c.a a. Fiberglass-reinforced plastic piping -FRP (280.20(b)(1)) Yes No N/A b. Non-metallic flexible piping (280.20(b)(4)) Type: Unknown Yes No N/A c. Constructed of metal and cathodically protected e.g. coated w/dielectric material, metal piping with anodes, or metal piping with impressed current system. (280.20(b)(2)) Specify: Yes No N/A d. Metal piping without additional corrosion protection measures. (280.20(b)(3)) Specify: Yes No N/A e. Records available to document Corrosion Protection is not necessary. (280.20(b)(3)(ii)) Yes No N/A 4. Are all metal components (flexible connectors, submersible turbine pumps) that routinely contain regulated substances and are in contact with the ground or water designed, constructed, and protected to prevent corrosion? UST-9c.a a. Constructed of metal and cathodically protected e.g. coated w/dielectric material, Yes No N/A metal componets protected with anodes or an impressed current system, contained in dry sumps. (280.20(b)) Specify: Dry Sumps Yes No N/A b. Metal piping components without additional corrosion protection measures. (280.20(b)(3)(ii)) Specify: Yes No N/A 5. Are all impact valves (shear valves) properly installed (moving parts unobstructed, shear valve properly anchored)? (NFPA 30A Chapter 6 Paragraph 3.9) Yes No N/A 6. Have repairs been made to any piping? Yes No Associated tank # ________ Date of repair ____________ a. Were any metal pipe sections or fittings that released product replaced? (280.22(c)) Yes No N/A c. Was the repaired piping tightness tested within 30 days of the completion of the repair (280.33(d)) unless inspected, monitored or otherwise tested? (290.33(d)(1, 2, 3)) Yes No N/A Section D Comments: b. Were fiberglass pipes and fittings repaired in accordance with manufacturer's specifications? (280.33(c)) Yes No N/A d. Was 50 percent or more of the piping replaced with DW piping during the repair? Yes No N/A EPA REGION 6 UST CEI CHECKLIST 5/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Section E Spill and Overfill for New/Existing UST Systems Further Explanation in (UST systems installed after 12/22/88 are considered new) Narrative Section E Not Applicable 1. Is each tank equipped with Spill Prevention Equipment to prevent a release of product when the transfer hose is detached from the fill pipe? (280.20(c)(1)(i); 280.20(d)) 9a.a Yes No N/A a. Does the spill prevention equipment have liquid tight sides and bottom (not cracked or broken)? (280.20(c)(1)(i)) UST 9a.a Yes No N/A b. Spill equipment construction c. For double walled spill buckets, is the spill prevention equipment interstitially DW SW monitored? UST 9a.b Yes No N/A d. If not interstitially monitored or if single wall, has the spill prevention equipment been tested within the last 3 years? (Required after 10/13/15 for new/replaced; by 10/13/18 for existing. (280.35) Date: Method: TBD Yes No N/A e. Is the spill bucket free of liquids, so that it will contain any overfill? Yes No N/A f. Has the spill bucket check been conducted every 30 days? (280.36(a)(1)(i) Required by 10/13/2018 Unless exception used, explain in comments UST 9a.b g. Has the spill prevention equipment been repaired/replaced since the previous inspection? Replace / Repair/ Test Date: TBD 2. Is each tank equipped with Overfill Prevention Equipment? (280.20(c)(1)(ii)). UST-9b.a 3. Is the Overfill Prevention Equipment designed to: UST-9b.a a. Automatically shut off flow to the tank when the tank is no more than 95% full? e.g. butterfly valve (280.20(c)(1)(ii)(A)) (device not tampered with or inoperable) b. Alert transfer operator when tank is no more than 90 % full by restricting flow into the tank (ball float valve) or triggering a high-level alarm (overfill alarm)? (Is the alarm near the fill port? Does it work? If No, explain in Comments) (280.20(c)(1)(ii)(B)) c. Restrict the flow 30 minutes prior to overfilling or alert the operator one minute before overfilling? (280.20(c)(1)(ii)(C)) d. If ball float valves are used, is the piping system pressurized. Ball float valves are not allowed for use on suction piping delivery systems (PEI/RP100-2005, Chapter 7.3.3 for New Systems; PEI/RP100-2005, Chapter 7.3.3 for Existing Systems) 4. Alternative type of Spill or Overfill Prevention Equipment being used? (280.20(c)(2)ii)) Specify: 5. Has overfill equipment been inspected within the past 3 years? Required after 10/13/15 for new/ replacement installation, 10/13/18 for existing installations (280.35) Date: TBD Section E Comments: Yes No N/A Yes No N/A Yes No N/A Yes No N/A Ball Float Alarm Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A SECTION F (installed after 4/11/2016) Section F Under-Dispenser Containment ) (UDC) (Dispensers installed after 4/11/2016) UST-9d.a Further Explanation in Narrative Section F Not Applicable 1. For dispensers installed after 4/11/2016 (280.20(f)) or those installed after 10/18/15with IM: a. Is each new dispenser at a new facility equipped with UDC? b. Is each new dispenser at an existing facility where new pipe (50% or greater) was added to connect the new dispenser to the existing system equipped with UDC? Yes No N/A Yes No N/A C. Is each replacement dispenser at an existing facility where piping (50% or greater) that connects the dispenser to the existing piping is replaced equipped with UDC? Yes No N/A EPA REGION 6 UST CEI CHECKLIST 6/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso 2. Does each UDC sump subject to the 4/11/2016 UDC requirements or installed utilizing IM after 10/13/15 have liquid-tight sides and bottom, and is it maintained free of storm water, debris and regulated substances? (280.20(f)) Yes No N/A 3. If UDC is being used for IM, have the UDC's been tested within 3 (three) years? (Effective for new UDC 4/11/2016 and existing UDC's No Later Than 10/13/18) Yes No N/A Section F Comments: SECTION G (installed after 4-11-2016) Section G Submersible Turbine Pump (STP) Secondary Containment UST 9d.a Further Explanation in Narrative Section G Not Applicable 1. For submersible turbine pumps installed after 4/11/16 (280.20) a. Is each new STP at a new facility equipped with liquid tight containment? b. Is each new STP at an existing facility where a new pipe run was added to connect the new STP to the system equipped with liquid tight containment? (280.35(a)(1)) c. Is each replacement STP at an existing facility, where 50% or more of the piping is replaced that connects the STP to the system, equipped with liquid tight containment? (280.35(a)(1)) Yes No N/A Yes No N/A Yes No N/A 2. Does each STP containment sump subject to the 10/13/2015 STP Secondary Containment requirements have liquid-tight sides and bottom, and maintained free of storm water, debris, and regulated substances? (303.D.5.b) Yes No N/A 3. Are the STP sumps used for piping Interstitial Monitoring? 4. Have STP containment sumps used for IM been tightness tested in the last 3 years (10/13/15 new, No Later Than 10/13/18 existing) UST-9d.d Section G Comments: Yes No N/A Yes No N/A Section H Operation and Maintenance of Corrosion Protection Systems Further Explanation in Narrative Section H Not Applicable 1. Is the corrosion protection system continuously operated and maintained to provide corrosion protection to metal components of external portions of the tanks and piping that routinely contain regulated substance and are in contact with the ground or water? Yes No N/A (280.31(a)) UST - 9c.c 2. Are the cathodic protection systems inspected by qualified testers?(280.31(b)) Yes No N/A 3. (280.31(b)(1)) Date: UST-9c.b Was the cathodic protection system tested within six months after installation? Yes No N/A 4. Is the system tested at least every three years? (280.31(b)(1)) Date: UST-9c.c and 9c.d Yes No N/A 5. Does the inspection meet the requirements of a code of practice developed by a nationally recognized association? (280.31(b)(2)) Yes No N/A 6. As outlined in 280.31(b), does the facility have copies of the last two CP inspections? (280.31(d)(2)) Yes No N/A 7. If the UST system has an impressed current, is the rectifier inspected every 60 days (280.31c) UST-9c.d Yes No N/A 8. As outlined in EPA regulations, does the facility have copies of the last three rectifier inspections? ((280.31(d)(1)) (CPM requires 2, must have last 2: UST-9c.d) Yes No N/A EPA REGION 6 UST CEI CHECKLIST 7/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso 9. Was the cathodic protection system tested within six months of a repair?(280.33(e)) 9c.b Section H Comments: Yes No N/A SOC - Release Detection Section I Release Detection Requirements for UST System 9d.a & 9d.b (Must have records 10 of 12 months, which incliudes 2 most current months) Further Explanation in Narrative Section I Not Applicable 1. Does the facility perform a method of release detection? Check "No" if no release detection conducted (280.40(a)) 2. Is the method of release detection capable of detecting a release from any portion of the tank that routinely contains product? (280.40(a)(1)) Yes No N/A Yes No N/A 3. with the manufacturer's instructions including routine maintenance, etc.?(280.40(a)(2)) Is the release detection system installed, calibrated, operated, and maintained in accordance Yes No N/A Does the release detection system meet the performance standards outlined in 280.43 or 4. 280.44? (Check third party certification against equipment or method present)((280.40(a)(3)) Yes No N/A 5. Are all USTs monitored at least every 30 days for releases? (280.41 (a)). Yes No N/A Is UST systems subject to the 4/11/16 Secondary Containment Requirements: 6. (Interstitial Montoring) a. Portions of UST system using IM: Tanks Piping Spill Buckets Yes No b. Are monthly records available to verify no leaks to interstice or the environment from tanks? Yes No N/A c. Are monthly records available to verify no leaks to interstice, sump or the environment from piping? 9d.d Yes No N/A 7. Has Annual testing/inspection of release detection equipment (ATG, probes/sensors, ALLD - simulating lead, vacuum/pressure guages, hand held equipment) been Yes No N/A conducted? (280.40(a)(3) required No Later Than 10/13/18 (UST9d.c 3yr records: RD Ck& ALLD simulating leak) Section I Comments: Section J Release Detection Record Keeping Further Explanation in Narrative Section J Not Applicable 1. As outlined in 280.34 does the facility maintain all written performance claims and documentation provided by the release detection vendor for 5 years? (280.45(a)) Yes No N/A 2. As outlined in 280.34, does the facility maintain all monitoring results, sampling records, UST-9d.a equipment testing, calibration and maintenance records, or leak detection equipment repair Yes No N/A records for at least one year? (280.45(b) and (c)) Specify: 3. As outlined in 280.43(c), are all tank tightness-testing records retained until the next test is conducted? ((280.45(b)) 4. As outlined in 280.34, are schedules of required calibration and maintenance for release detection equipment retained for 5 years from date of installation? ((280.45(c)) 5. Are records available to verify water levels in the tanks are checked monthly to 1/8th inch? (280.43(a)(6) 9d.a Section J Comments: Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 8/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Section K Release Reporting Suspected Releases UST 9d.e Further Explanation in Narrative Section K Not Applicable When a release detection method indicates that a release may have occurred; has the 1. facility notified EPA/State of a suspected release? (280.40(b) and 280.50(c)) S-D4 Yes No N/A Has the facility notified the department of any other suspected release (regulated 2. substance discovered, unusual operating conditions)? (280.50(a) or (b)) Yes No N/A Facility has resolved suspected releases in accordance with procedures outlined in 3. 280.52? S-D4 Yes No N/A Spills and Overfills Has the facility reported, investigated, and cleaned-up any spills and overfills as 1. required by 280.52 through 280.67 Yes No N/A Section K Comments: Section L Release Detection Methods for Tanks 9d.a (Fill out only the applicable sections, all others can remain blank) Further Explanation in Narrative Section L Not Applicable Inventory Control with Tank Tightness Testing (280.41(a)(1)) UST 9d.a 1. INSTALLED ON or BEFORE 4/11/16 a. Are inputs, withdrawals, amounts in tank recorded daily or on each operating day? (280.43(a)(1)) Yes No N/A b. Is the measuring equipment capable of measuring the level of the product over the full range of the tank's height to the nearest one-eighth of an inch? (280.43(a)(2)) Yes No N/A c. Are inputs reconciled with delivery receipts? (280.43(a)(3)) Yes No N/A d. Are deliveries made through a drop tube which extends to within 1foot of bottom? (280.43(a)(4)) Yes No N/A e. Are measurements of water level made to the nearest 1/8 inch at least once a month?(280.43(a)(6)) Yes No N/A f. Is the TTT conducted every 5 years as required and is TTT method capable of detecting a 0.1 gal/hr leak rate from any portion of the tank routinely containing product? (280.41(a)(1)) Yes No N/A Date of Last Tank Tightness Test: g. TTT conducted following the manufacturer's instructions or third party certification. (280.43(c)) Yes No N/A h. Within the 10 year time frame for using IC/TTT? (280.41(a)(1)) Expiration Date: Yes No N/A 2. Manual Tank Gauging (MTG) (tanks <2000 gal) (281.43(b)) 9d.a Deadline date: a. If tank is >550 gal and < 2000 gal, is tank tightness being conducted every 5 years? (280.41(a)(1)) Date of last tank tightness test: b. Tank size is appropriate for using MTG (280.43(b)) c. Method is being conducted properly (280.43(b)(1) through (5)) d. No liquid is added to or taken out of tank during test. (280.43(b)(1)) e. Equipment is capable of 1/8-in measurement (280.43(b)(3)) f. Within the 10 year time frame for using MTG/TTT for tanks between 550 and 2000 gallons? (280.41(a)(1)) Expiration Date: Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 9/17 March 9th 2017 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso 3. Automatic Tank Gauging (ATG) (280.40(a)&280.43(d)) 9d.a INSTALLED ON or BEFORE 4/11/16 Make and Model: Veeder-Root TLS 350+ Probe Type: Magneto a. Is the ATG capable of detecting a leak of 0.2 gal/hr leak rate? (280.43(d)(1)) S-D3 Yes No N/A b. As the sole method of release detection, the ATG must test the tank at least once per Yes No N/A month in a manner that can detect a 0.2 gal/hr release with a pd > 0.95 and a pfa < 0.05 (280.40(a)(3)) c. The ATG will generate a hard copy which contains the following: S-D3 i. the time and date of the test Yes No N/A ii. the tank identification Yes No N/A iii. the qualitative result either "pass" or "fail" Yes No N/A d. Type of test conducted CSLD 4. External Release Detection Devices a. General Requirements for Release Detection Devices 9d.a INSTALLED ON or BEFORE 4/11/16 i. Do the RDDs meet the general requirements for construction? (280.43(e)(1) &(6) and (f)(7)-(8) ii. RDDs screened from 1 ft below the surface throughout the entire excavation zone? Yes No N/A (280.43(e) & (f)) Yes No N/A iii. Are the RDDs sealed and locked? (280.43(e)(7) and (f)(8)) iv.Are the RDDs installed in backfill? (280.43(e)(1) and 280.43(f)(2)) Type of backfill: Yes No N/A Yes No N/A v. Are RDDs in the correct number and properly positioned? (280.43(e)(6) and (f)(7)) Yes No N/A vi. Does the facility have the paperwork to confirm that the release detection method was properly assessed? (280.45(a) Required After Oct 13, 2018 Yes No N/A b. Vapor Monitoring (280.43(e)) 9d.a INSTALLED ON or BEFORE 4/11/16 i. Is the regulated substance (or tracer) sufficiently volatile to allow vapors to be detected by the monitoring device? (280.43(e)(2)) ii. Vapor monitoring is not affected by high ground water, rainfall, etc. (280.43(e)(3) iii. Does background concentration in excavation zone interfere with method used? (280.43(e)(4)) iv. Is the monitoring device designed and operated to detect any significant increase in concentration above background? (280.43(e)(5)) Yes No N/A Yes No N/A Yes No N/A Yes No N/A c. Groundwater Monitoring (280.43(f)) 9d.a INSTALLED ON or BEFORE 4/11/16 i. Is regulated substance immiscible in water and have a specific gravity less than one? (280.43(f)(1) Yes No N/A ii. Water in the monitoring well is never more than 20 feet from the ground surface? (280.43(f)(2)) Yes No N/A iii. Does RDD prevent migration of soils into RDD, and can regulated substance enter RDD in both low and high water conditions? (280.43(f)(3)) Yes No N/A iv. If RDD installed in native soil, is hydraulic conductivity greater than 0.01 cm/sec? (280.43(f)(2) Yes No N/A EPA REGION 6 UST CEI CHECKLIST 10/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso v. Can continuous monitoring device or manual method detect 1/8-in of free product? (280.43(f)(6)) Yes No N/A 5. Interstitial Monitoring (280.43(g) 9d.a REQUIRED FOR TANKS INSTALLED AFTER 4/11/16 a. Describe the UST system which uses IM e.g. double walled tank, secondary barrier: Explain: DW Tanks Yes No N/A b. Can the method detect a release through the inner wall of the tank? (280.43(g)(1) or (3) S-D2 Yes No N/A c. Continuous interstitial monitoring by an automatic leak sensing device that signals to the operator the presence of any regulated substance in the space or sump (701.A.6.a) Yes No N/A Method: ATG; interstice sensors OR ii. Manual interstitial monitoring every 30 days by means of a procedure capable of detecting the presence of any regulated substance in the interstitial space or sump (701.A.6.a) Specify Method: Yes No N/A 6. Statistical Inventory Reconciliation(SIR)(280.43(h)) 9d.a For Tanks INSTALLED ON OR BEFORE 4/11/16 a. Can the SIR method detect a release of 0.2gal/hr from any portion of the UST System that routinely contains product with a pd > 0.95 and a pfa < 0.05? (280.43(h)(1)) Did the owner/operator receive the monthly report(s) from the SIR provider/ b. vendor within the 30 day monitoring period? (280.43(h)) c. Did the SIR analysis report include the following information: i. the name of the SIR provider and the name and version of the SIR method; ii the name and address of the facility at which the analysis was performed; iii. a description of the UST system for which the analysis was performed; iv. a quantitative statement, in gallons/hr, for each UST system monitored for the month, of the leak threshold, minimum detectable leak rate, and the indicated leak rate; v. a qualitative statement of "pass," "fail," or "inconclusive" for each UST system monitored Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A d. Method Name: Version: 7. Other Method: (280.43(h)) Specify Method: a. Method can detect 0.2 gal/hr leak rate or a release of 150 gal within a month; & meet the 95/5 probability requirement. (280.43(h)) OR b. EPA has approved the method as being as effective as Tank Tightness testing, ATG, vapor monitoring, ground water monitoring, or interstitial monitoring and operator complies with any conditions imposed by the agency. (280.43(h)) Section L Comments: Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 11/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Section M Methods of Release Detection for Piping Section M Not Applicable Further Explanation in Narrative Is release detection performed on the UST system's piping? (280.41(b)) Check Box to the right and the appropriate piping system below: pressurized or suction. Yes No N/A 1. Pressurized Piping 9d.a a. Which of the following methods of leak detection does the facility use for pressurized piping? (280.41(b)(1)) i. Automatic Line Leak Detectors (ALLD) installed (one of the following methods is required on all pressurized lines, regardless of line leak detection method used) (280.41(b)(1)(ii)) Yes No N/A MODEL: Red jacket vaporless Fe Petro 1. Automatic flow restrictor, or 2. Automatic shutoff, or MECHANICAL ELECTRONIC Yes No N/A Yes No N/A 3. Continuous audible or visual alarm Yes No N/A 4. Is a test conducted every 12 months on the line leak detector which simulates a leak according to manufacturer's requirements? (280.44(a)) Date of last test: TBD Yes No N/A 5. Are records available for performance test for previous 2 years. (starting 10/13/18, AND 3 years of records required, which includes current test.) 9d.c 6. If Electronic, a 3gal/hr test with a PASS or other rate as specified by Manufacturer annually. (Not acceptable after 10/13/2018) Yes No N/A Yes No N/A ii. One other method (280.44(b)) (Only appliable if installed on or before 4/11/2016, must use IM afterwards.) 1. A line tightness test conducted every 12 months (280.44(b)); Date of last test: 9d.b TBD 2. Is LTT method capable of detecting a 0.1 gal/hr leak rate from any portion of the piping routinely containing product? (280.44(b)) Yes No N/A Yes No N/A 3. If Electronic, is a 0.1 test with PASS conducted annually (280.44(b)) Yes No N/A OR 4. Monthly monitoring? (280.44(c)) Specify Type: Yes No N/A 5. If Electronic, is a 0.2 test with PASS conducted monthly (280.44(b)) Yes No N/A REQUIRED FOR Piping INSTALLED or REPLACED (>50% TOTAL) AFTER 4/11/16 b. Is Interstitial Monitoring Secondary Containment requirements used (303.D.2.f.i), by either: i. Continuous interstitial monitoring by an automatic leak sensing device that signals to the operator the presence of any regulated substance in the interstitial space or sump Yes No N/A (701.B.4) Must have monthly documentation. Specify Method: OR ii. Manual interstitial monitoring every 30 days by means of a procedure capable of detecting the presence of any regulated substance in the interstitial space or sump (701.B.4) Yes No N/A Specify Method: c. For piping subject to the 4/11/16 Secondary Containment requirements, is all piping interstitial space and/or are all sumps maintained free of water, debris, or anything that could interfere with the leak detection capabilities? (701.B.4.a) Yes No N/A 2. Suction Piping a. Which of the following leak detection methods does the facility use for suction piping? (280.44(b)) i. (Safe Suction) No release detection is required if piping is sloped to drain product back into tank and only one check valve is present and located directly below or as Yes No N/A close as practicable to the suction pump (280.41(b)(2) - must have documentation OR ii. Line tightness test every 3 years? (280.41(b)(2)) Date of last test: Yes No N/A OR iii. Monthly monitoring? (280.41(b)(2)) Specify Type: Yes No N/A EPA REGION 6 UST CEI CHECKLIST 12/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Section M Comments: Section N Requirements for Temporary Closure (280.70) Further Explanation in Narrative 1. For UST systems in temporary closure; has the facility: a. If greater than 1 inch of liquids remain, is monthly release (280.70(a)) Specify Type of RD performed tanks and piping: b. If applicable, is the Cathodic Protection being maintained? (280.70(a)) Section N Comments: detection Section N Not conducted? 9d.a Yes 9c.c Yes Applicable No N/A No N/A NON-Significant Operational Compliance Components Section O Temporary Closure Continued Further Explanation in Narrative 1. For UST systems temporarily closed for 3 months or more, did the owner/operator: Not Applicable a. Leave vent line open and functional? (280.70(b)(1)) Yes No N/A b. Cap and secure all other lines, pump, manways, and ancillary equipment? (280.70(b)(2)) Yes No N/A c. Notify the E.P.A of the temporary closure status (UST-REG-01 form)? (280.70(b)(1)) Yes No N/A d. Perform a tank tightness test within five days after the system was brought back into service after being in temporary closure 3 months or more? (903.E) Yes No N/A 2. For any non-upgraded UST system that has been temporarily closed for more than 12 months, has the owner/operator permanently closed the system? ((280.70(c)) Yes No N/A Section O Comments: Section P Additional Paperwork Requirements Not Applicable Further Explanation in Narrative 1. Is the information on the Notice of Registration form current and accurate? (280.22)) 2. Has an amended Registration form been submitted within 30 days of acquiring a UST? (280.22)) 3. Is a copy of the current registration form kept on-site or at the nearest staffed facility? (Not Required.) 4. Has the owner/operator submitted the following information to the department: a. Registration form for all UST systems, including installation certification and installer verification for new tank systems (280.22) b. Reports of all releases, suspected releases, spills and overfills, and confirmed releases (280.34(a)(2)) 9c.e Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 13/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso c. Descriptions of corrective action plans, site characterizations, free product removal investigation of soil and groundwater cleanup, and corrective action plan Yes No N/A (280.34(a)(3)) d. Notification before permanent closure or change-in-service (280.34(a)(5) & .71(a) Yes No N/A e. If new ownership, has a notification of ownership change been submitted within 30 days of acquiring a UST? (280.22(b)) Yes No N/A f. Has notification of a change of storage to regulated substances blended wih greater than 10% ethanol or greater than 20% biodiesel been provided to agency 30 days Yes No N/A before beginning storage? (280.32(b)) 5. Has the owner/operator maintained the following documents: a. Results of site assessment conducted at permanent closure (280.34(a)(5) Yes No N/A b. Documentation of UST system repairs (280.34(b)(3)) Yes No N/A c. Documentation of the type and construction of the tanks, piping, leak detection equipment, corrosion protection equipment, and spill and overfill protection Yes No N/A equipment? d. Assessment of suitability for groundwater or vapor monitoring as release detection method. Retain while in use. (Copy of assessment must be available as of 10/13/18) Yes No N/A (280.45(a)) e. Three year testing of release prevention equipment and containment sumps, and inspection and/or testing (Overfill protection devices). Retain for three years. Yes No N/A (280.35(c)(1) UST-/9a.b/9b.b/9d.c/9d.d f. Annual testing of release detection equipment. Retain for 3 years. (280.45(b)(1) 9d.a Yes No N/A g. Checklists for Monthly walk thru inspections. Checklists contain dates, findings and actions taken. Retain for 1 year. 280.36(b) UST `12 h. Annual walk thru insp. checklists for sumps/equip. Retain 1 year.280.36(b) UST-12 6. Was the facility able to provide the records in a timely fashion as required by the inspector? (280.34(c) Yes No N/A Yes No N/A Yes No N/A Section P Comments: Section Q General Requirements Not Applicable Further Explanation in Narrative 1. Are the products being stored compatible with the materials or liner in the UST system? (280.32) Yes No N/A 2. Documentation of compatibility for fuel with >10% ethanol, >20% biodiesel, or another fuel designation by implementing agency. Retain as long as fuel is used. (280.32(b)(2)) Yes No N/A Section Q Comments: Section R Financial Responsibility UST- 11 Not Applicable Further Explanation in Narrative 1. Can the owner/operators demonstrate financial responsibility for taking corrective action, including 3rd party liability? i.e: how is he going to pay for the cleanup of a release? Yes No N/A (280.94 -280.99)Records - 280.111 What type of financial responsibility is used? Explain: 2. If Insurance, list company and contact: Policy Number: TBD 3. Insurance Mailing Address: Contact Number: E-mail: Effective Date of Coverage: Expiration Date on Policy: Retroactive Date: Confirmed Released Policy: Suspected Release Policy: EPA REGION 6 UST CEI CHECKLIST 14/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso 4. Financial Assurance Documentaion a. Copy of Signed Certification of Financial Responsibility available and current. b. Copy of signed Certitficate of Insurance or Endorsement. Yes No N/A Yes No N/A Section R Comments: Section S Physical Documents Obtained Not Applicable Further Explanation in Narrative If any documents, printouts or other materials were obtained from the facility, owner or operator explain below what was obtained and add to Inspection Packect and document in attachments. Section S Comments: Section T Additional Comments Not Applicable EPA REGION 6 UST CEI CHECKLIST 15/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Operator Training Tribal Land: Pueblo of San Ildefonso DESIGNATED CLASS A AND CLASS B UST OPERATORS FOR THIS FACILITY: UST -10 N/A Class A UST Operator: Trainer Contact Information TBD Date Certified: Class B UST Operator: Trainer Contact Information Date Certified: Class C UST Operator: Trainer Contact Information Date Certified: Class C UST Operator: Trainer Contact Information Comments on Operator Training: Date Certified: EPA REGION 6 UST CEI CHECKLIST 16/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 Digital Image Log FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Camera type and ID Image File Date # # ##/##/#### Time 1 2 3 AM / PM AM PM AM PM AM PM Orientation Photographer N/E/S/W/Down Description None Taken 4 AM PM 5 AM PM 6 AM PM 7 AM PM 8 AM PM 9 AM PM 10 AM PM 11 AM PM AM 12 PM 13 AM PM 14 AM PM I certify that the digital images for this inspection were taken and archived according to EPA standard operating procedures and protocols. The digital images have not been altered and are a fair and accurate representation of observations made during the inspection. I certify that the digital media has been in my possession throughout the inspection trip and that I transferred the digital images to a CD-R. Yes No Inspector: Inspector Signature:__________________________________________ EPA REGION 6 UST CEI CHECKLIST 17/17 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R04 FID #: 0157NM INSPECTION DATE(S): 9-26-23 FACILITY NAME: TEWA Market and Fuel at Totavi Tribal Land: Pueblo of San Ildefonso Inspection Packet A0: Final Inspection Report A1: Facility Diagram Attachment A2: Digital Images Attachment A3: Observation Report A4: R6USTCEIForm-001-R04 Revision History This table shows changes to this controlled document over time. The most recent version is presented in the top row of the table. Current and archived versions of the document are located on the Region 6 Document Control Database and maintained by the Region 6 Document Control Coordinator. History Effective Date Merged EPA Federal OR Revision 5: 10/01/2016 to current document. July 11, 2017 R6USTCEIForm-001-R0 Orginal. Added signature line for supervisor to page 2 removed section S, and revised attachment page. R1 Added Section S detailing documents obtained during inspection. R2 Revised form to remove the SOC references and replaced adding the new CPM requirements (R3) Revised form to correct errors/issues, moved all of Section M, but Comments to same page, bold text for Section M, 1st question. (R4) November 18, 2016 March 13, 2018 May 8 2018 October 24, 2018 April 8, 2019 R6USTCEIForm-001-R04