Document 15kmveRkdNG6YNgoj0YvjZ5bK

Compliance Evaluation Inspection Report Navajo State Park Marina July 2024 Submitted to: U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop St. Denver, CO 80202 Submitted by: Eastern Research Group. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 EPA Contract No. 68HERC21D0007 Task Order 68HERC23F0460 COMPLIANCE EVALUATION INSPECTION REPORT Date of Report: July 23, 2024 Date and Time of Inspection: June 19, 2024, at 8:50 am MST Weather: Sunny, 65 Fahrenheit Facility Contact/Owner: / Navajo State Park Owner Address: 1526 County Road 982 Arboles, CO 81121 Facility Address: 1526 County Road 982 Arboles, CO 81121 Facility Phone: Facility ID Number: 1010038 Reason for Inspection: Compliance Inspection Inspector(s): , ERG (Lead) Navajo State Park Marina CEI Report ii July 2024 TABLE OF CONTENTS 1. NARRATIVE ..................................................................................................................... 1 2. SUMMARY ........................................................................................................................ 4 ATTACHMENTS ATTACHMENT A: ATTACHMENT B: ATTACHMENT C: ATTACHMENT D: ATTACHMENT E: ATTACHMENT F: ATTACHMENT G: ATTACHMENT H: ATTACHMENT I: ATTACHMENT J: EPA REGION 8 UST COMPLIANCE CHECKLIST PHOTOGRAPH LOG TANK LEAK DETECTION RECORDS & INVENTORY ATG CERTIFICATION LLD TESTING RECORDS PIPING TESTING RECORDS SPILL PREVENTION TESTING RECORDS NAVAJO STATE PARK UST SYSTEM HANDOUT ANNUAL COMPLIANCE INSPECTION DOCUMENTATION NOTICE OF INSPECTION Navajo State Park Marina CEI Report iii July 2024 1. NARRATIVE The Region 8 (R8) office of the Environmental Protection Agency (EPA) requested multiple facilities be inspected on tribal lands. Eastern Research Group (ERG) under EPA's Contract No. 68HERC21D0007, Task Order 68HERC23F0460, provided assistance to EPA in preparing for, conducting the inspection, and preparing this inspection report. ERG inspected the Navajo State Park Marina in Arboles, Colorado on June 19, 2024. The facility was last inspected on November 3, 2021. Mr. , contract inspector, contacted Mr. , Manager, on May 29, 2024, via telephone to notify the facility about the inspection. The inspection verified compliance with the federal underground storage tank (UST) requirements of Resource Conservation and Recovery Act (RCRA) Subtitle I under 40 CFR Part 280. Upon arrival at the facility, Mr. introduced himself as a contract inspector for EPA, presented his credentials, and provided an in-brief to facility personnel to explain the purpose of the inspection. Mr. gathered records, interviewed Mr. , and conducted a walkthrough of the site including access ports and dispensers. Mr. concluded with an exit brief and had Mr. sign the Notice of Inspection. Mr. took photographs during the inspection. UST System Description The Navajo State Park Marina, located at 1526 County Road 982 in Arboles, CO, has one UST installed in 2005. According to the previous EPA inspection report and observations made during the inspection, Tank 1 has a 12,000-gallon capacity and contains regular unleaded gasoline. The tank is fiberglass-reinforced plastic (FRP) jacketed steel construction. The dispensing system for each tank is pressurized piping with double-walled flex plastic construction. Mr. completed an EPA Region 8 UST Compliance Inspection Checklist for the UST while on site which is included in Attachment A. Photograph #2 in Attachment B shows an overview of the UST system. UST System Records The listing of documents reviewed for the Navajo State Park Marina inspection included the following: 1. UST Leak Detection Records and Inventory 2. Automatic Tank Gauge and Line Leak Detector Test Records 3. Spill and Overfill Protection Test Records 4. Insurance Coverage Certification 5. Operator Training Records The facility maintains all records off site. Mr. during the inspection. provided the records for the UST Navajo State Park Marina CEI Report 1 July 2024 Tank Release Detection Releases from the tank is detected by a Veeder-Root TLS-350 monitoring system and associated in-tank probes that conduct automatic tank gauging (ATG) of the tank. Attachment C contains a compilation of the ATG continuous statistical leak detection test results for January, May, and June 2024. Photograph #1 in Attachment B shows the monitoring system interface, and Attachment C also includes a current system status report printed on the day of the inspection. Mr. also provided a passing test record for the ATG system performed by a contractor in June 2023 (see Attachment D). Piping Release Detection The tank was installed with pressurized double-walled flex plastic piping. The piping is attached to a submersible turbine pump (STP), which is equipped with an electronic line leak detector (LLD). The LLD was observed on the STP and had a passing test record based on contractor testing in June 2023 (see Attachment E). The shear valves, liquid sensors, and E-stop at the tank and shed were tested in June 2023 and passed. These results are included in Attachment F. A 0.1 gph annual line tightness test was conducted by the Veeder-Root in March 2024 and passed. The line tests for the UST are included in Attachment C. Photograph #3 in Attachment B shows the STP. Spill/Overfill Prevention The fill pipe for the UST has a spill bucket surrounding the pipe. Photograph #2 in Attachment B shows the fill port for the UST. The spill bucket was dry and in good condition. There is an external audible overfill alarm on the outside of the shed in close proximity to the fill port. The overfill alarm was tested as part of the ATG certification in June 2023 and is included in Attachment D. Mr. tested the overfill alarm during the inspection and an audible alarm sounded. Testing was conducted on the spill bucket in June 2023. Attachment G includes the passing test record for the spill bucket. Corrosion Protection The tanks are FRP jacketed steel tank construction with flexible plastic piping. They do not require cathodic protection. Operator Training Operator training records were provided for who is a Class A and Class B operator. There are no designated Class C operators. not provided during the inspection. The certificates are included in the Navajo State Park UST Fuel System handout included in Attachment H. Walkthrough Inspections Walkthrough inspection records were not provided during the inspection. The annual compliance inspection from June 2023 is included in Attachment I. Navajo State Park Marina CEI Report 2 July 2024 Financial Assurance The State of Colorado Petroleum Tank Fund invoice for the UST is included in Attachment H. The facility is self-insured for the deductible. Physical Inspection During the site visit, the Mr. reviewed documents on site and observed the fill port, The STP access port, two dispensers, and the ATG monitoring interface for the UST on site. Photograph #1 in Attachment B shows the interface for the Veeder-Root TLS-350 ATG system, which did not have any monitoring or leak alarms at the time of the inspection. Mr. also observed the spill bucket and fill pipe for the UST. The drop tube and spill bucket were in good condition. Mr. also observed the STP sump. The sump was dry and appeared in good condition. The access port for ATG probe was also present, and no issues were noted for these during the inspection. There were two dispensers on site, one at the marina and one by the shed. The dispenser at the marina was opened as part of the inspection. There were three transition sumps observed on land and two transition sumps observed on the dock. The dispenser had sump containment and a liquid sump sensor present. The marina dispenser and transition sumps appeared in good condition and no issues were noted at the time of the inspection (see Photograph #10, Attachment B). One monitoring well was observed at the tank field during the inspection. The vent line is located north of the UST, and no obstructions or concerns were noted for the vent line at the time of the inspection. Navajo State Park Marina CEI Report 3 July 2024