Document 15raOq39apqQ4rgrjRnOxbg6m

NPDES Inspection Report - Wastewater National Database Information Inspection Date: July 13, 2022 Inspection Type: CEI - Wastewater Treatment Facility Entry/Exit Time: 12:00 pm / 12:26 pm NPDES ID Number: NDG589310 NAICS Code: 221320 Inspection ID: 202207_NDG589310 Lead inspector and affiliation: Stephanie Meyers / EPA Region 8 Inspector and affiliation: Emilio Llamozas / EPA Region 8 Facility Location Information (Name/Location/ Mailing Address) Site/Facility Name & Location: Little Eagle Community Lagoon (Also known as Running Antelope) S1 T8N R27E Fort Yates, North Dakota 58538 Mail Report to: Randez Bailey rbailey@standingrock.org Leon Spotted Bull leon.spottedbull@standingrock.org Contact Information Facility Contacts: (indicate primary lead and present during inspection) Person/Company meeting definition of "Operator" Authorized Official(s) (Per NOI) Name(s)/Title Randez Bailey / Rural Water System Director / Standing Rock Municipal, Rural, and Industrial (MR&I) Program / present during opening and closing conferences Leon Spotted Bull / Wastewater Supervisor / Standing Rock MR&I Program / primary lead during the inspection Wyatt Red Tomahawk / Wastewater Operator / Standing Rock MR&I Program / present during the inspection Jake Luger / Acting Environmental Director / Standing Rock Sioux Tribe Environmental Program / present during opening conference Tyler Timmons / Tribal Utility Consultant / Indian Health Service (IHS) / present during the inspection Standing Rock Sioux Tribe Randez Bailey / Rural Water System Director / Standing Rock MR&I Program Permit Information Is the permit on site and available? Yes Lagoon Category: No Discharge Monitoring Frequency: N/A Effective Date: February 8, 2016 Expiration Date: December 31, Is the Facility under a 2020 (Administratively Continued) compliance schedule? No Is correct contact information indicated on ICIS? Yes Indicate correct contact information: N/A Receiving Water(s): Grand River Discharge point location (longitude, latitude): There is one emergency outfall at the northern edge of cell 3. Lat. 45.682691 N, Long. -100.794354 W. Facility representatives indicated the construction of the discharge pipe was never completed; therefore, the facility cannot discharge (photo 125). Regulatory Inspector's source of information: Notice of Intent for the permit, permit, facility representatives and facility observations. Inspection based upon 2016 Lagoon General permit Page 1 of 7 Areas Evaluated During Inspection Permit Self-Monitoring Program Records Compliance Schedule Facility Site Review Laboratory Effluent/Receiving Waters Operations and Maintenance Flow Measurement Sludge Handling/Disposal Report Review and Signature Drafter Name Stephanie Meyers Reviewer Name Emilio Llamozas Supervisor Signature/Name Boeglin, Michael Digitally signed by Boeglin, Michael Date: 2022.08.09 12:11:01 -06'00' Michael Boeglin Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6938 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6407 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6250 Pretreatment Pollution Prevention Stormwater Combined Sewer Overflow Sanitary Sewer Overflow Date 08/03/2022 Date 08/04/2022 Date 08/09/2022 Inspection based upon 2016 Lagoon General permit Page 2 of 7 Inspection Narrative and Site Description The inspection was conducted at the Little Eagle Community Lagoon (facility) also known as Running Antelope located on the Standing Rock Sioux Reservation, in Little Eagle, South Dakota to evaluate compliance with its National Pollutant Discharge Elimination System (NPDES) permit. The EPA is responsible for implementing the NPDES program in Indian Country within the State of South Dakota. The inspection was announced approximately one month prior to the inspection, to coordinate logistics for the inspection. On July 13, 2022, U.S. Environmental Protection Agency (EPA) inspectors Emilio Llamozas and Stephanie Meyers met with Leon Spotted Bull and Wyatt Red Tomahawk with the MR&I Program in Little Eagle. The EPA inspectors had previous presented their credentials and had an opening conference to explain the purpose of the inspection on July 12, 2022 at the MR&I's main office for all the MR&I facilities that were inspected during this inspection trip. The inspectors proceeded to inspect the facility and asked questions to the facility representatives to help the inspectors evaluate compliance with the facility's permit. Throughout the inspection, the inspectors noted their observations in a checklist. Photographs taken during the inspection are included in the attached photo log. The Little Eagle Lagoon System serves the Little Eagle Community located on the Standing Rock Sioux Reservation. The facility serves approximately 480 people. The facility is permitted as a no discharge facility, under the Lagoon General Permit for the Standing Rock Reservation. Any discharge from the facility is expected to be under emergency circumstances. The lagoon system was originally constructed in 1970, and in 1997 the system was renovated, and two cells were added. The average design flow to the facility is 0.04 million gallons per day (MGD) and the peak design flow is 0.05 MGD. The average design organic treatment capacity is 150 lbs BOD5 per day and the peak design organic treatment capacity is 188 lbs BOD5 per day. The facility does not accept hauled septic waste. The wastewater from the Little Eagle Community (northwest of the lagoon) is collected in the lift station and pumped to cell 1. Wastewater then flows from cell 1 to cell 2, and then from cell 2 to cell 3. During the inspection, wastewater was being sent to cell 1. Cells 1 and 2 were in service. Cell 3 was not being used at the time of the inspection because they were installing riprap on the berms of cell 3 (See the enclosed facility schematic and flow diagram). The inspectors first inspected the Little Eagle Lift Station (photo 120). The trash basket inside of the wet well of the lift station was full at the time of the inspection (photo 119). The operators were keeping track of the lift station's pump hours. Below are the coordinates for the Little Eagle Lift Station. Lift Station Name Little Eagle Lift Station Latitude 45.681518 N Longitude -100.798929 W The inspectors then went to inspect the lagoon cells. The facility is a three-cell lagoon system, and the table below has the operating volume for the three cells. Cell ID Cell 1 Cell 2 Cell 3 Area (acres) 3.2 2.9 2.9 Operating Volume (MG) 5.2 4.7 4.7 Inspection based upon 2016 Lagoon General permit Page 3 of 7 Total 9.0 14.6 The inspectors and facility representatives then drove around the lagoons to evaluate berm integrity and the facility's discharge status. During the inspection, wastewater was flowing into cell 1 for treatment (photo 121). The wastewater flows from cell 1 to cell 2 (photo 122) and then from cell 2 to cell 3 (photos 123 and 124). There is a discharge pipe inside of cell 3 (photo 125). Facility representatives indicated the construction of the discharge pipe was never completed; therefore, the facility cannot discharge. Facility representatives also informed inspectors that they have not had to discharge from the facility. Vegetation had reached a height greater than six inches around the berms and inside of each of the three cells (photos 121-124). At the time of the inspection, riprap was being installed at cell 3 (photos 123 and 124), and the facility has plans to install riprap at the remaining two cells. At the end of the day on July 13, 2022, the inspectors returned to the MR&I office and held a closing conference with Ms. Bailey, Mr. Spotted Bull, and Mr. Red Tomahawk where they discussed preliminary findings. On July 22, 2022, the EPA sent an email to Ms. Bailey, Mr. Spotted Bull, and Mr. Red Tomahawk with the preliminary findings from the inspection. Inspection based upon 2016 Lagoon General permit Page 4 of 7 Findings, Corrective Actions and Recommendations Finding #1: Weekly lagoon inspections were not being conducted. Weekly lagoon inspections were not being conducted. The inspectors provided the facility representatives with a lagoon inspection report template form that the facility representatives could use to document the weekly lagoon inspections. Permit requirement: Part 4.3.1 of the Lagoon General Permit (Permit) states, "On at least a weekly basis, unless otherwise modified by written approval from the EPA, the permittee shall inspect its wastewater treatment facility. The permittee shall maintain a notebook recording all information obtained during the inspection. At a minimum, the notebook shall include the following: 4.3.1.1. Name of facility and permit number; 4.3.1.2. Date and time of the inspection; 4.3.1.3. Name of the inspector(s); 4.3.1.4. The facility's discharge status; 4.3.1.5. The flow rate of the discharge if occurring; 4.3.1.6. If a discharge is occurring, has occurred since the previous inspection, and/or if a discharge is likely to occur before the next inspection. (Note: If a discharge has occurred or is likely to occur before the next inspection, perform the appropriate monitoring and reporting requirements in Parts 3.2 and 5.4 of this permit if not already done.); 4.3.1.7. Is there is any leakage through the dikes; 4.3.1.8. Are there are any animal burrows in the dike; 4.3.1.9. Is there any erosion of the dikes (e.g., rills, cracks or other structural indications of erosion); 4.3.1.10. Are there are any rooted plants, including weeds growing in the water; 4.3.1.11. Does the vegetation growth on the dikes needs mowing (e.g. greater than 6" tall); 4.3.1.12. List the date scheduled for operation and maintenance procedures to be undertaken at the wastewater treatment facility. 4.3.1.13. Identification of operational problems and/or maintenance problems; 4.3.1.14. Recommendations, as appropriate, to remedy identified problems; 4.3.1.15. A brief description of any actions taken with regard to problems identified; and, 4.3.1.16. Other information, as appropriate. The permittee shall maintain the notebook in accordance with required record-keeping items listed above and shall make the log available for inspection, upon request, by authorized representatives of the U.S. Environmental Protection Agency or the applicable Tribe (see Part 5.10 of this permit)." Part 5.7 of the Permit states, "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, inspection records, notifications to the EPA per this permit, and DMRs, for a period of at least five years from the date of the sample, measurement, report, application or submittal. Records of monitoring required by this permit related to sludge use and disposal activities must be kept at least five years (or longer as required by 40 C.F.R. Part 503). This period may be extended by request of the Director at any time. Data collected on site, data used to prepare the DMR, copies of DMRs, a copy of this NPDES permit, and the notice of intent for permit coverage, must be maintained on site." Inspection based upon 2016 Lagoon General permit Page 5 of 7 Corrective Action: Ensure that inspections are conducted on a weekly basis and documented in accordance with the permit. Ensure that inspection reports are kept in accordance with the recordkeeping requirements of the permit. Provide the EPA, the Standing Rock Sioux Tribe Environmental Program (Tribe) and Indian Health Service (IHS) with a description of the corrective actions taken to address this finding. Finding #2: There were cattails growing around and inside of all three cells. There was heavy vegetation over six inches in height growing in and around cells 1, 2, and 3 that needed to be cut (photos 121-125). There were cattails in cells 2 and 3. Permit requirement: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: 6.5.1. Take necessary action to promptly correct the problem of leakage through the dikes; 6.5.2. Take necessary action to promptly remove burrowing animals from the dikes; 6.5.3. Promptly repair damage to dikes caused by burrowing animals and/or erosion; 6.5.4. Remove rooted plants, including weeds, from the water on a regular basis or as needed; and 6.5.5. Keep the dikes mowed on a regular basis during the growing season or as needed (e.g., keep growth below 6" in height)." Corrective Action: Remove the overgrown vegetation and cattails inside and around cells 1, 2, and 3. Submit to the EPA, the Tribe, and IHS photos of the cells after the vegetation has been removed. Finding 3: The lift station's trash basket was full at the time of the inspection. The trash basket inside of the lift station wet well was full and needed to be cleaned out (photo 119). Permit requirement: Part 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance." Inspection based upon 2016 Lagoon General permit Page 6 of 7 Corrective Action: Clean and remove trash and debris from the trash basket inside the wet well at the Little Eagle lift station. Properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) including the lift station, which are installed or used by the permittee to achieve compliance with the conditions of the permit. Provide the EPA, the Tribe, and IHS with photos and a description of the corrective actions taken to address this finding. Inspection based upon 2016 Lagoon General permit Page 7 of 7 hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez Z'/KE Z^KhZKE^Zsd/KEEZKsZzd ^//E&KZDd/KE &E><Z>> &>ZZ ZZ/EZ &Z^< ZZ EZZ^EZZ Z/Z^ d d >/ZDh^W K ^<><Z>> ><Z>> ^> d,h^W :Eh^W :ZDh^W ZZh^W ^Zh^W WZ:ZZddZZdd dDZdd EZZ'WZZ ZdZ' ^Z' dWZZ/ZZZ/Z &dKtZ& ^Z/ZZZ^Z /ZdZ/Z dZZZZZZZ ZZdZZZZZZZZZ ZZZZZZZ ZZ &E><Z &>ZZ Z/Z^ &/>/dz/E&KZDd/KE ZKZ><Z>> '&WZZd><Z>>>< ZZZZZZ^ WZZZKZZZZ ZZZ Z ZWKZd^KW dZZZZZZZZZZ ZZZZZ^ZZZ Z^ZZZ^ZZ ZZZZZ&Z ZZWZ dKhZ/E&KZDd/KE ZZ/ZD< Z,ZZZZZZZ Z ZZ x d x x ^ZZ x Z ^DWZZZZZ WZZ>Z Z dZZZZZZD< tdZZ &ZZZ'ZZDZZ ZtZZ><ZEZZZDZ ZdZZEKZZDdEKZD dZZdZZZ WZ &E><Z &>ZZ Z/Z^ dEKZD ZDZ &ZZZZ Z tZZZ WdZZZ dZZZZ ZZZZdZZ ZZZZdZZ dZZ /ZZZZZZZ dZ ZZZZZ ZdZZZKt>ZKt> dZZZ ZZZZ KZ Z/ZZZZZZZZZZZ ZZZ/ZZZZZ >K^/E'KE&ZE ZZZD<ZZZ ZZ/ZZZZZ^Z /d/KE>/E&KZDd/KE &ZZZdEKZD ZZZZZZ Z WZ &E><Z &>ZZ Z/Z^ ^/'EdhZ Digitally signed by ANNETTE ANNETTE MAXWELL MAXWELL /ZDate: 2025.01.2810:41:05 -07'00' DZZ/Z Digitally signed by KRISTIN KRISTIN MCNEILL MCNEILL ^ZDate: 2025.01.2908:45:07-07'00' <DE^Z ZZZ^Z ZZZ dd,DEd^ ^D WZZ>Z WZ Attachment 1 - Site Map ><Z sZZ ^ d ^Z Z Z Z ^ZWZ ZZ EZZ Z>< Z h ^ &Z d Z Attachment 2 - Photo Log &E><Z &>ZZ Z/Z^ dd,DEdW,KdK>K' WZZD DZ/W^^ WZZ/D'ZZZZ ZZZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZ ZZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZZZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZZZZ ZZ &E><Z &>ZZ Z/Z^ WZZ/D'ZZZZ ZZZZZZZZZZ ZZ INSPECTION REPORT NESHAP 6C: Gasoline Dispensing Facility Inspection Attached please find the United States Environmental Protection Agency's (EPA's) inspection report of your inspected facility and/or any related fuel delivery inspections identified therein. EPA is providing this report as a matter of agency policy and will contact you again only if needed. Without making a determination that your business or organization is a small business, EPA is also providing you with a link to this Small Business Resources Information Sheet (https://www.epa.gov/compliance/small-business-resources-information-sheet) which provides an array of resources to help small businesses understand and comply with federal and state environmental laws. Inspection Information Inspection Number: R8_CAA_2024_0912_01 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): September 12, 2024 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C) EPA Region 8, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch EG America, LLC / Mini Mart, Inc. d/b/a "Loaf N Jug" ("Loaf N Jug") Loaf N Jug #078 2120 Oakshire Ln Pueblo, CO 81001 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Name of Approving Official Inspector Title Branch Manager Title KATELYN BERGL Date: 2024.11.19 17:41:43 -07'00' Digitally signed by KATELYN BERGL Signature SCOTT PATEFIELD Date: 2024.11.19 16:18:22 -07'00' Digitally signed by SCOTT PATEFIELD Signature FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Loaf N Jug #078 AIRS-ID: Primary Facility Representative & Title: 101-0227-001 Theodore Bezel, Tanknology Compliance Manager Martin Hilfinger, EG America, LLC. Vice President Environmental Affairs Parent Company Name: CAA Permit (if any): On-site Facility Representative & Title: Facility Contact tbezel@tanknology.com Phone/Email: Martin.Hilfinger@eg-america.com On-site Contact Phone/Email: Loaf N Jug Permit Exempt Number 96PB1047S.XP Alison Mustard Store Manager N/A Facility Address: 2120 Oakshire Ln, Pueblo, CO 81001 Enforcement and Compliance History: None Fuel Delivery Company Company Name: Fuel Supply Groendyke Transport Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 8527 Chris Pape Vice President of Safety Cpape@groendyke.com Trucking Company Name (if different): Trailer Identifier: Suncor Energy 14-0576 Driver Name: Aviv Ifrah Company Address: Fuel Supply 1833 E Platteville Blvd, Pueblo West, CO 81007 Enforcement and Compliance History: None Page 2 of 9 Inspection Number/ID: Inspector(s): Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. Photographer Name: General Inspection Information R8_CAA_2024_0912_01 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 9:50 AM Yes No Alison Mustard Administrative Inspection Items: Katelyn Bergl Photograph Range: 9/12/2024 9:45 AM 11:20 AM Announced Unannounced CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): MOV_3542 - 3546; IMG_0128 - 0148 Weather & Other General Site Observations: Sunny, 80 deg F, winds 12 mph SW Inspection Narrative: The facility was inspected under the Clean Air Act (CAA) for compliance with 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C). Inspection activities included observation of a fuel delivery event by the EPA inspector and a request for records required to be maintained under NESHAP 6C. The following are areas of concern identified during the inspection or records review: 1. For gasoline dispensing facilities with gasoline throughput greater than 100,000 gallons per month, Item 1(g) of Table 1 of NESHAP 6C applies: Areas of Concern: 1(g) Pressure/vacuum (PV) vent valves shall be installed on the storage tank vent pipes. The pressure specifications for PV vent valves shall be: a positive pressure setting of 2.5 to 6.0 inches of water and a negative pressure setting of 6.0 to 10.0 inches of water. The total leak rate of all PV vent valves at an affected facility, including connections, shall not exceed 0.17 cubic foot per hour at a pressure of 2.0 inches of water and 0.63 cubic foot per hour at a vacuum of 4 inches of water. To demonstrate compliance with Item 1(g) of Table 1 of NESHAP 6C, 40 CFR 63.11120(a) requires that a performance test using Test Procedure TP-201.1E is conducted initially and every three years thereafter. The facility most recently conducted a TP-201.1E performance test on April 26, 2022. The test report indicates that the tested components initially failed the test, stating that the tester "replaced existing OPW 623V vent caps, was having difficulties getting S1PD to pass, so vent caps were replaced/retested." The component was replaced and retested the same day as the initial test and subsequently passed the performance test. The initial failing results indicate that the facility may not have been continuously Page 3 of 9 complying with Item 1(g) of Table 1 of NESHAP 6C. 2. Components of the tank and associated vapor balance system were not vapor tight during the fuel delivery event, as required by Item 1(b) of Table 1 of NESHAP 6C. The following emissions were observed during the fuel delivery portion of EPA's inspection: a. There are 2 separate regular unleaded (RUL) tanks with separate fill and vapor recovery equipment at this facility. Vapors were observed from both RUL fuel fill spill buckets prior to the caps being removed for fueling. The spill bucket for RUL #1 (RUL E) had some liquid in the bucket. The spill bucket for RUL #2 (RUL W) was completely dry. b. Vapors were observed from the RUL #2 fill spill bucket during fueling. c. Vapors were observed from the RUL #1 coaxial fill & vapor spill bucket during RUL fueling. The RUL #1 tank equipment is a coaxial design, where the fill and vapor recovery pipes are co-located. d. A small vapor leak was observed coming from the loading head of compartment 3 on the truck. A small amount of liquid fuel was also leaking into the spill bucket during fueling. Page 4 of 9 Gasoline Throughput and Testing Records Applicable Throughput Category: Calculated based on volume of gasoline Calculated based on volume of gasoline loaded into all storage tanks dispensed from all storage tanks <10,000 gallons per month 10,000 gallons per month and < 100,000 gallons per month 100,000 gallons per month Date Applicable Throughput Category Was Exceeded: Based on records provided since 2019, the facility exceeded the 100,000 gallons per month throughput threshold on or before October 2019. Records: All Facilities regardless of throughput Notes 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Last 12-month rolling throughput calculation available Records: Facilities 100,000 gallons per month 3 -year Leak Rate and Cracking Pressure Test (CARB Test Procedure TP-201.1E, - Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, or equivalent) Static Pressure Test (CARB Test Procedure TP-201.3, - Determination of 2-Inch WC Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, or equivalent) Throughput records for this facility from October 2019 - September 2024 were provided via email by Theodore Bezel on September 11, 2024. Provided along with 5-year throughput records Notes Date of Last Test: 4/26/2022 Results of Last Test: Pass / Fail Report Provided: Yes / No The report indicates that the components initially failed the performance test. The components were replaced and retested the same day as the initial test and subsequently passed the performance test. This performance test was conducted within the past three years. Date of Last Test: 4/26/2022 Results of Last Test: Pass / Fail Report Provided: Yes / No Report indicates passing performance test. Performance test conducted within the past three years. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) RUL 2) Diesel Amount of Fuel Delivered: 1) 6,000 gallons 2) 2,000 gallons Annual Certification Test - Vapor Tightness Testing - EPA Method 27 of appendix A-8 to part 60 of CAA Available with truck Date of Last Test: 11/06/2023 5-Year Test Record Availability: Available at office or central loc. Not Available Other: Results of Test: Pass Page 5 of 9 Fuel Delivery Event Observation: A fuel delivery event was observed by the EPA inspector. The inspector used a forward-looking infrared (FLIR) camera to record optical gas imaging (OGI) videos of gasoline vapors. Any auditory, visual, and olfactory (AVO) observations were also recorded. See Appendix A for a list of photographs and videos recorded during the fuel delivery inspection. Components of the refueling activity which Description/Observations (including any OGI or AVO observations) were observed: There are 2 separate RUL tanks with separate fill and vapor Conditions of recovery equipment at this facility. Vapors were observed from Equipment prior to both RUL fuel fill spill buckets prior to the caps being removed refueling event for fueling. The spill bucket for RUL #1 (RUL E) had some liquid in the bucket. The spill bucket for RUL #2 (RUL W) was completely dry. Connection of fuel and vapor lines prior to fuel transfer Vapors were observed from diesel vapor vent while diesel fuel being loaded. Diesel tank vapors are not required to be controlled under NESHAP 6C. Vapors were observed from the RUL #2 fill spill bucket during fueling. Vapors were observed from the RUL #1 coaxial fill & vapor Maintenance of fuel spill bucket during RUL fueling. The RUL #1 tank equipment and vapor line is a coaxial design, where the fill and vapor recovery pipes are connections during co-located. fueling event A small vapor leak was observed coming from the loading head of compartment 3 on the truck. A small amount of liquid fuel was also leaking into the spill bucket during fueling. A small vapor plume was observed from both the loading head and from the bucket. See IMG_0147 - 0148 for condition of the hose gasket. The rubber o-ring felt soft and looked in new condition, but the driver replaced the part anyway due to the observations and said he would keep an eye on the hose and loading head. Disconnection of fuel and vapor lines after fuel transfer Conditions of Equipment after refueling event Page 6 of 9 Documents Requested Document(s) 5-year fuel throughput records including previous 12-month fuel throughput calculation EPA Method 27 for the fuel delivery truck Most recent NESHAP 6C Performance Tests Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Status Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Notes/Comments Page 7 of 9 APPENDIX A: Photograph and Video Log File Name Description MOV_3542.mp4 MOV_3543.mp4 MOV_3544.mp4 MOV_3545.mp4 MOV_3546.mp4 IMG_0128.JPG IMG_0129.JPG IMG_0130.JPG IMG_0131.JPG IMG_0132.JPG IMG_0133.JPG IMG_0134.JPG IMG_0135.JPG IMG_0136.JPG IMG_0137.JPG Vapors were observed from diesel vapor vent while diesel fuel being loaded. Diesel tank vapors are not required to be controlled under NESHAP 6C. There are 2 separate RUL tanks with separate fill and vapor recovery equipment at this facility. Vapors were observed from both RUL fuel fill spill buckets prior to the caps being removed for fueling. The spill bucket for RUL #1 (RUL E) had some liquid in the bucket. The spill bucket for RUL #2 (RUL W) was completely dry. Vapors were observed from the RUL #2 fill spill bucket during fueling. Vapors were observed from the RUL #1 coaxial fill & vapor spill bucket during RUL fueling. The RUL #1 tank equipment is a coaxial design, where the fill and vapor recovery pipes are co-located. A small vapor leak was observed coming from the loading head of compartment 3 on the truck. A small amount of liquid fuel was also leaking into the spill bucket during fueling. A small vapor plume was observed from both the loading head and from the bucket. See IMG_0147 - 0148 for condition of the hose gasket. The rubber o-ring felt soft and looked in new condition, but the driver replaced the part anyway due to the observations and said he would keep an eye on the hose and loading head. Vapor vent stacks for the RUL #1, RUL #2, and premium storage tanks located on top of the canopy structure. According to the facility, the vapor lines for RUL #2 and the premium storage tanks are manifolded together and tied in to one single pressure/vacuum vent. Vapor vent stacks for the RUL #1, RUL #2, and premium storage tanks located on top of the canopy structure. Single vapor vent stack for the diesel storage tank. General refueling area prior to fuel delivery. General refueling area prior to fuel delivery. Diesel fuel tank fill and vapor recovery equipment capped and covered prior to fueling. Premium fuel tank fill and vapor recovery equipment capped and covered prior to fueling. RUL #2 fuel tank fill and vapor recovery equipment capped and covered prior to fueling. RUL #1 fuel tank fill and vapor recovery equipment capped and covered prior to fueling. Automatic tank gauging (ATG) systems and fuel pump equipment, capped and covered, prior to fueling. This Photographe r K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 8 of 9 IMG_0138.JPG IMG_0139.JPG IMG_0140.JPG IMG_0141.JPG IMG_0142.JPG IMG_0143.JPG IMG_0144.JPG IMG_0145.JPG IMG_0146.JPG IMG_0147.JPG IMG_0148.MO V equipment appears to have recently undergone construction. Fuel truck: Trailer identifier Fuel truck: Truck identifier EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. RUL #2 fill spill bucket and pipe capped prior to fueling. Vapors were visible from this equipment prior to fueling. RUL #1 fill spill bucket and fill/vapor recovery pipe capped prior to fueling. Vapors were visible from this equipment prior to fueling. There was some liquid observed in the spill bucket. RUL #2 fill spill bucket and pipe uncapped prior to fueling. Vapors were visible from this equipment prior to fueling. RUL #1 fill spill bucket and fill/vapor recovery pipe uncapped prior to fueling. Vapors were visible from this equipment prior to fueling. There was some liquid observed in the spill bucket. Picture to demonstrate the coaxial fill and vapor recovery hose needed for RUL #1. In this image, the vapor recovery hose had been connected, while the fuel hose had not. Condition of the fuel hose gasket for the hose that was observed to be leaking during fuel delivery. Condition of the fuel hose gasket for the hose that was observed to be leaking during fuel delivery. K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 9 of 9 INSPECTION REPORT Attached please find the United States Environmental Protection Agency's (EPA's) inspection report of your inspected facility and/or any related fuel delivery inspections identified therein. EPA is providing this report as a matter of agency policy and will contact you again only if needed. Without making a determination that your business or organization is a small business, EPA is also providing you with a link to this Small Business Resources Information Sheet (https://www.epa.gov/compliance/small-business-resources-information-sheet) which provides an array of resources to help small businesses understand and comply with federal and state environmental laws. Inspection Information Inspection Number: R8_CAA_2024_0911_01 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): September 11, 2024 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C) EPA Region 8, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch EG America, LLC / Mini Mart, Inc. d/b/a "Loaf N Jug" ("Loaf N Jug") Loaf N Jug #084 1104 Pueblo Blvd Way Pueblo, CO 81005 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Inspector Title Branch Manager KATELYN BERGL Date: 2024.11.19 17:36:08 -07'00' Digitally signed by KATELYN BERGL Signature Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2024.11.19 16:03:57 -07'00'  FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Loaf N Jug #084 Parent Company Name: AIRS-ID: Primary Facility Representative & Title: Facility Contact Phone/Email: 101-1145 -001 Theodore Bezel, Tanknology Compliance Manager Martin Hilfinger, EG America, LLC. Vice President Environmental Affairs tbezel@tanknology.com Martin.Hilfinger@egamerica.com CAA Permit (if any): On-site Facility Representative & Title: On-site Contact Phone/Email: Loaf N Jug Permit Exempt Number 08PB0753S.XP Benjamin Olivarez, Assistant Manager N/A Facility Address: 1104 Pueblo Blvd Way, Pueblo, CO 81005 Enforcement and Compliance History: None Fuel Delivery Company Fuel Supply Company Name: Groendyke Transport Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 8501 Chris Pape Vice President of Safety Cpape@groendyke.com Trucking Company Name (if different): Suncor Energy Trailer Identifier: 14-1338 Driver Name: Thomas Sharp Company Address: Fuel Supply 1833 E Platteville Blvd, Pueblo West, CO 81007 Enforcement and Compliance History: None WZ  Inspection Number/ID: Inspector(s): Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. Photographer Name: General Inspection Information R8_CAA_2024_0911_01 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 12:42 PM Yes No Benjamin Olivarez Administrative Inspection Items: Katelyn Bergl Photograph Range: 9/11/2024 12:40 PM 1:28 PM Announced Unannounced CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): MOV_3533 - 3534; IMG_0072 - 0086 Weather & Other General Site Observations: Mostly sunny, 90 deg F, winds 8 mph SE Inspection Narrative: The facility was inspected under the Clean Air Act (CAA) for compliance with 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C). Inspection activities included observation of a fuel delivery event by the EPA inspector and a request for records required to be maintained under NESHAP 6C. The following are areas of concern identified during the inspection or records review: For gasoline dispensing facilities with gasoline throughput greater than 100,000 gallons per month, Item 1(g) of Table 1 of NESHAP 6C applies: Areas of Concern: 1(g) Pressure/vacuum (PV) vent valves shall be installed on the storage tank vent pipes. The pressure specifications for PV vent valves shall be: a positive pressure setting of 2.5 to 6.0 inches of water and a negative pressure setting of 6.0 to 10.0 inches of water. The total leak rate of all PV vent valves at an affected facility, including connections, shall not exceed 0.17 cubic foot per hour at a pressure of 2.0 inches of water and 0.63 cubic foot per hour at a vacuum of 4 inches of water. To demonstrate compliance with Item 1(g) of Table 1 of NESHAP 6C, 40 CFR 63.11120(a) requires that a performance test using Test Procedure TP-201.1E is conducted initially and every three years thereafter. The facility most recently conducted a TP-201.1E performance test on June 25, 2024. The test report indicates that the tested component initially failed the negative leak rate and cracking pressure test. The component was replaced and retested the same day as the initial test and subsequently passed the performance test. The initial failing results WZ indicate that the facility may not have been continuously complying with Item 1(g) of Table 1 of NESHAP 6C. Gasoline Throughput and Testing Records Applicable Throughput Category: Calculated based on volume of gasoline Calculated based on volume of gasoline loaded into all storage tanks dispensed from all storage tanks <10,000 gallons per 10,000 gallons per month and < 100,000 gallons month 100,000 gallons per month per month Based on records provided since 2019, the Date Applicable Throughput Category facility exceeded the 100,000 gallons per month Was Exceeded: throughput threshold on or before October 2019. Records: All Facilities regardless of throughput Notes 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Throughput records for this facility from October 2019 - September 2024 were provided via email by Theodore Bezel on September 11, 2024. Last 12-month rolling throughput calculation available Records: Facilities 100,000 gallons per month 3 -year Leak Rate and Cracking Pressure Test (CARB Test Procedure TP-201.1E, - Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, or equivalent) Static Pressure Test (CARB Test Procedure TP-201.3, - Determination of 2-Inch WC Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, or equivalent) Provided along with 5-year throughput records Notes Date of Last Test: 6/25/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No The report indicates that the component initially failed the negative leak rate and cracking pressure test. The component was replaced and retested the same day as the initial test and subsequently passed the performance test. This performance test was conducted within the past three years. Date of Last Test: 5/22/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No Report indicates passing performance test. This performance test was conducted within the past three years. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Amount of Fuel Delivered: 1) 3,000 gallons 2) 1,000 gallons Annual Certification Test - Vapor Tightness Testing - EPA Method 27 of appendix A-8 to part 60 of CAA Date of Last 04/01/2024 Test: 5-Year Test Record Availability: Available with truck Available at office or central loc. W Z  Not Available Other: Results of Test: Pass Fuel Delivery Event Observation: A fuel delivery event was observed by the EPA inspector. The inspector used a forward-looking infrared (FLIR) camera to record optical gas imaging (OGI) videos of gasoline vapors. Any auditory, visual, and olfactory (AVO) observations were also recorded. See Appendix A for a list of photographs and videos recorded during the fuel delivery inspection. Components of the refueling Description/Observations (including any OGI or AVO activity which were observed: observations) Vapors visible from regular unleaded (RUL) fueling spill Conditions of Equipment bucket prior to cap removal or fueling. Liquid was visible in prior to refueling event the spill bucket prior to fueling and could have been the source of vapors. Connection of fuel and vapor lines prior to fuel transfer Maintenance of fuel and A small amount of vapors was observed from RUL fueling vapor line connections spill bucket during RUL fueling. These vapors could have during fueling event come from leftover liquid/gasoline in the spill bucket present prior to fueling. Disconnection of fuel and vapor lines after fuel transfer Conditions of Equipment after refueling event Documents Requested Document(s) 5-year fuel throughput records including previous 12-month fuel throughput calculation EPA Method 27 for the fuel delivery truck Most recent NESHAP 6C Performance Tests Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Status Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) APPENDIX A: Photograph and Video Log Notes/Comments WZ  File Name Description MOV_3533.mp4 MOV_3534.mp4 IMG_0072.JPG IMG_0074.JPG IMG_0075.JPG IMG_0076.JPG IMG_0077.JPG IMG_0078.JPG IMG_0079.JPG IMG_0080.JPG IMG_0081.JPG IMG_0082.JPG IMG_0083.JPG IMG_0084.JPG IMG_0085.JPG IMG_0086.JPG Vapors visible from RUL fueling spill bucket prior to cap removal or fueling. Liquid was visible in the spill bucket prior to fueling and could have been the source of vapors. Small amount of vapors observed from RUL fueling spill bucket during RUL fueling. Possibly from leftover liquid/gasoline in the spill bucket present prior to fueling. Vapor vent stacks for the RUL, premium, and diesel storage tanks located on top of the canopy structure, as well as the general refueling area. Regular unleaded (RUL) and premium fuel tank fill and vapor recovery equipment. Regular unleaded (RUL), premium, and diesel fuel tank fill and vapor recovery equipment. Regular unleaded (RUL) fuel tank fill and vapor recovery equipment. Premium tank fill and vapor recovery equipment. Diesel tank fill and vapor recovery equipment. General refueling area prior to fuel delivery. General refueling area prior to fuel delivery. Fuel truck fuel delivery header system. Fuel truck: Trailer identifier Fuel truck: Truck identifier EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. Photographe r K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl WZ INSPECTION REPORT NESHAP 6C: Gasoline Dispensing Facility Inspection Attached please find the United States Environmental Protection Agency's (EPA's) inspection report of your inspected facility and/or any related fuel delivery inspections identified therein. EPA is providing this report as a matter of agency policy and will contact you again only if needed. Without making a determination that your business or organization is a small business, EPA is also providing you with a link to this Small Business Resources Information Sheet (https://www.epa.gov/compliance/small-business-resources-information-sheet) which provides an array of resources to help small businesses understand and comply with federal and state environmental laws. Inspection Information Inspection Number: R8_CAA_2024_0911_04 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): September 11, 2024 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C) EPA Region 8, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch EG America, LLC / Mini Mart, Inc. d/b/a "Loaf N Jug" ("Loaf N Jug") Loaf N Jug #085 136 South Purcell Blvd Pueblo West, CO 81007 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Name of Approving Official Inspector Title Branch Manager Title KATELYN BERGL Date: 2024.11.19 17:39:50 -07'00' Digitally signed by KATELYN BERGL Signature Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2024.11.19 16:16:36 -07'00' Signature FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Loaf N Jug #085 AIRS-ID: Primary Facility Representative & Title: Facility Contact Phone/Email: 101-1146 -001 Theodore Bezel, Tanknology Compliance Manager Martin Hilfinger, EG America, LLC. Vice President Environmental Affairs tbezel@tanknology.com Martin.Hilfinger@egamerica.com Parent Company Name: CAA Permit (if any): On-site Facility Representative & Title: On-site Contact Phone/Email: Loaf N Jug Permit Exempt Number 08PB0754S.XP Sue Bilger, Manager N/A Facility Address: 136 South Purcell Blvd, Pueblo West, CO 81007 Enforcement and Compliance History: None Fuel Delivery Company Company Name: Fuel Supply Groendyke Transport Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 8527 Chris Pape Vice President of Safety Cpape@groendyke.com Name (if different): Trucking Company Suncor Energy Trailer Identifier: 14-0576 Driver Name: Ray Evans Company Address: Fuel Supply 1833 E Platteville Blvd, Pueblo West, CO 81007 Enforcement and Compliance History: None Page 2 of 6 Inspection Number/ID: Inspector(s): Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. Photographer Name: General Inspection Information R8_CAA_2024_0911_04 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 5:30 PM Yes No Sue Bilger Administrative Inspection Items: Katelyn Bergl Photograph Range: 9/11/2024 5:25 PM 6:23 PM Announced Unannounced CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): IMG_0115 - 0127 Weather & Other General Site Observations: Inspection Narrative: Mostly Clear, 75 deg F, winds 11 mph NE The facility was inspected under the Clean Air Act (CAA) for compliance with 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C). Inspection activities included observation of a fuel delivery event by the EPA inspector and a request for records required to be maintained under NESHAP 6C. Areas of Concern: None Gasoline Throughput and Testing Records Applicable Throughput Category: Calculated based on volume of gasoline Calculated based on volume of gasoline loaded into all storage tanks dispensed from all storage tanks <10,000 gallons per month JDOORQVSHUPRQWKDQG< 100,000 gallons per month 100,000 gallons per month Date Applicable Throughput Category Was Exceeded: Based on records provided since 2019, the facility exceeded the 100,000 gallons per month throughput threshold on or before October 2019. Records: All Facilities regardless of throughput Notes 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Throughput records for this facility from October 2019 - September 2024 were provided via email by Theodore Bezel on September 11, 2024. Last 12-month rolling throughput calculation Provided along with 5-year throughput records Page 3 of 6 Records: Facilities 100,000 gallons per month 3 -year Leak Rate and Cracking Pressure Test (CARB Test Procedure TP-201.1E, - Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, or equivalent) Static Pressure Test (CARB Test Procedure TP-201.3, - Determination of 2-Inch WC Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, or equivalent) Notes Date of Last Test: 5/22/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No Report indicates passing performance test. Performance test conducted within the past three years. Date of Last Test: 5/22/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No Report indicates passing performance test. Performance test conducted within the past three years. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Diesel Amount of Fuel Delivered: 1) 6,000 gallons 2) 1,000 gallons Annual Certification Test - Vapor Tightness Testing - EPA Method 27 of appendix A-8 to part 60 of CAA Available with truck Date of Last 11/06/2023 Test: 5-Year Test Record Availability: Available at office or central location Not Available Other: Results of Test: Pass Fuel Delivery Event Observation: A fuel delivery event was observed by the EPA inspector. The inspector used a forward-looking infrared (FLIR) camera to record optical gas imaging (OGI) videos of gasoline vapors. Any auditory, visual, and olfactory (AVO) observations were also recorded. See Appendix A for a list of photographs and videos recorded during the fuel delivery inspection. Description/Observations Components of the refueling activity which were observed: (including any OGI or AVO observations) Conditions of Equipment prior to refueling event Connection of fuel and vapor lines prior to fuel transfer Maintenance of fuel and vapor line connections during fueling event Disconnection of fuel and vapor lines after fuel transfer Conditions of Equipment after refueling event Page 4 of 6 Documents Requested Document(s) 5-year fuel throughput records including previous 12-month fuel throughput calculation EPA Method 27 for the fuel delivery truck Most recent NESHAP 6C Performance Tests Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Status Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Notes/Comments Page 5 of 6 APPENDIX A: Photograph and Video Log File Name Description IMG_0115.JPG IMG_0116.JPG IMG_0117.JPG IMG_0118.JPG IMG_0119.JPG IMG_0120.JPG IMG_0121.JPG IMG_0122.JPG IMG_0123.JPG IMG_0124.JPG IMG_0125.JPG IMG_0126.JPG IMG_0127.JPG Condition of the general fueling area prior to fuel delivery. Tank vent stacks. Two appear to be pressure/vacuum (P/V) vent types, while the third appears to be an open vent. The open vent is likely connected to the diesel tank, which does not require vapor control. Diesel fuel pump manhole cover. Diesel fuel tank fill area covered with a manhole cover. The diesel tank is not equipped with a vapor recovery system. Diesel fuel automatic tank gauging (ATG) system manhole cover. Premium fuel tank fill and vapor recovery equipment. Premium fuel pump manhole cover. Premium fuel ATG system manhole cover. Regular unleaded (RUL) fuel tank fill and vapor recovery equipment. RUL fuel pump manhole cover. Fuel truck: Trailer identifier EPA Method 27 Certificate for truck. Fuel truck: Truck identifier Photographe r K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 6 of 6 INSPECTION REPORT NESHAP 6C: Gasoline Dispensing Facility Inspection Attached please find the United States Environmental Protection Agency's (EPA's) inspection report of your inspected facility and/or any related fuel delivery inspections identified therein. EPA is providing this report as a matter of agency policy and will contact you again only if needed. Without making a determination that your business or organization is a small business, EPA is also providing you with a link to this Small Business Resources Information Sheet (https://www.epa.gov/compliance/small-business-resources-information-sheet) which provides an array of resources to help small businesses understand and comply with federal and state environmental laws. Inspection Information Inspection Number: R8_CAA_2024_0911_02 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): September 11, 2024 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C) EPA Region 8, Enforcement and Compliance Assurance Division, Air and Toxics Enforcement Branch EG America, LLC / Mini Mart, Inc. d/b/a "Loaf N Jug" ("Loaf N Jug") Loaf N Jug #087 4125 W Northern Ave Pueblo, CO 81005 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Inspector Title Branch Manager KATELYN BERGL Date: 2024.11.19 17:37:16 -07'00' Digitally signed by KATELYN BERGL Signature SCOTT PATEFIELD Date: 2024.11.19 16:09:42 -07'00' Digitally signed by SCOTT PATEFIELD FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Loaf N Jug #087 AIRS-ID: Primary Facility Representative & Title: Facility Contact Phone/Email: 101-1148-001 Theodore Bezel, Tanknology Compliance Manager Martin Hilfinger, EG America, LLC. Vice President Environmental Affairs tbezel@tanknology.com Martin.Hilfinger@egamerica.com Parent Company Name: CAA Permit (if any): On-site Facility Representative & Title: On-site Contact Phone/Email: Loaf N Jug Permit Exempt Number 08PB0756S.XP Talia Mauro Employee N/A Facility Address: 4125 W Northern Ave, Pueblo, CO 81005 Enforcement and Compliance History: None Fuel Delivery Company Company Name: Fuel Supply Groendyke Transport Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 8501 Chris Pape Vice President of Safety Cpape@groendyke.com Name (if different): Trucking Company Suncor Energy Trailer Identifier: 14-1338 Driver Name: Thomas Sharp Company Address: Fuel Supply 1833 E Platteville Blvd, Pueblo West, CO 81007 Enforcement and Compliance History: None General Inspection Information Number/ID: Inspection R8_CAA_2024_0911_02 Page 2 of 8 Inspection Date 9/11/2024 Inspector(s): Katelyn Bergl (EPA) Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. 1:34 PM Yes No Talia Mauro Photographer Name: Katelyn Bergl Time Arrival/Departure 1:34 PM 2:05 PM Announced Unannounced Administrative Inspection Items: Photograph Range: CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): MOV_3535 - 3537; IMG_0081 - 0086; IMG_0088 - 0098 Weather & Other General Site Observations: Mostly Clear, 90 deg F, winds 8 mph SE Inspection Narrative: The facility was inspected under the Clean Air Act (CAA) for compliance with 40 C.F.R. Part 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (NESHAP 6C). Inspection activities included observation of a fuel delivery event by the EPA inspector and a request for records required to be maintained under NESHAP 6C. The following are areas of concern identified during the inspection or records review: 1. For gasoline dispensing facilities with gasoline throughput greater than 100,000 gallons per month, Items 1(g) and 1(h) of Table 1 of NESHAP 6C applies: Areas of Concern: 1(g) Pressure/vacuum (PV) vent valves shall be installed on the storage tank vent pipes. The pressure specifications for PV vent valves shall be: a positive pressure setting of 2.5 to 6.0 inches of water and a negative pressure setting of 6.0 to 10.0 inches of water. The total leak rate of all PV vent valves at an affected facility, including connections, shall not exceed 0.17 cubic foot per hour at a pressure of 2.0 inches of water and 0.63 cubic foot per hour at a vacuum of 4 inches of water. 1(h) The vapor balance system shall be capable of meeting the static pressure performance requirement of the following equation: Pf = 2e-500.887/v Where: Pf = Minimum allowable final pressure, inches of water. v = Total ullage affected by the test, gallons. e = Dimensionless constant equal to approximately 2.718. 2 = The initial pressure, inches water. Page 3 of 8 To demonstrate compliance with Items 1(g) and 1(h) of Table 1 of NESHAP 6C, 40 CFR 63.11120(a) requires that a performance test using Test Procedure TP-201.1E and Test Procedure TP-201.3 is conducted initially and every three years thereafter. The facility most recently conducted both performance tests on April 17, 2024. The TP-201.1E test report indicates that the tested components initially failed the positive and negative leak rate and cracking pressure test. The components were replaced and retested the same day as the initial test and subsequently passed the performance test. The initial failing results indicate that the facility may not have been continuously complying with Item 1(g) of Table 1 of NESHAP 6C. The TP-201.3 test report indicates that the premium unleaded (PUL) gasoline vapor recovery system failed the static pressure test due to the "drop tube leaking vapor." The report does not document any corrective actions or additional testing. The failing results indicate that the facility may not be continuously complying with Item 1(h) of Table 1 of NESHAP 6C. 2. Components of the tank and associated vapor balance system were not vapor tight during the fuel delivery event, as required by Item 1(b) of Table 1 of NESHAP 6C. The following emissions were observed during the fuel delivery portion of EPA's inspection: a. Vapors were observed from PUL spill bucket during fueling. Several inches of liquid were accumulated in the spill bucket, which could have contributed to the vapors observed. However, the amount of vapors observed indicate that the standing liquid was likely not the only source of the vapors. Vapors may have also been coming from the premium vapor recovery spill bucket as well, but it was difficult to discern due to the fill bucket emission plume. b. Vapors were observed from the vapor recovery still bucket during RUL fueling. Note that the vapor recovery hose used during this fuel delivery had been observed during an EPA inspection at another Loaf N Jug immediately prior to this delivery, and no emissions were observed during that delivery. Gasoline Throughput and Testing Records Applicable Throughput Category: Page 4 of 8  Calculated based on volume of gasoline Calculated based on volume of gasoline loaded into all storage tanks dispensed from all storage tanks <10,000 gallons per month 10,000 gallons per month and < 100,000 gallons per month 100,000 gallons per month Date Applicable Throughput Category Was Exceeded: Records: All Facilities regardless of throughput Based on records provided since 2019, the facility exceeded the 100,000 gallons per month throughput threshold on or before October 2019. Notes 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Last 12-month rolling throughput calculation available Records: Facilities 100,000 gallons per month 3 -year Leak Rate and Cracking Pressure Test (CARB Test Procedure TP-201.1E, - Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, or equivalent) Static Pressure Test (CARB Test Procedure TP-201.3, - Determination of 2-Inch WC Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, or equivalent) Throughput records for this facility from October 2019 - September 2024 were provided via email by Theodore Bezel on September 11, 2024. Provided along with 5-year throughput records Notes Date of Last Test: 4/17/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No The report indicates that the premium unleaded (PUL) and regular unleaded (RUL) components both initially failed the positive and negative leak rate and cracking pressure tests. The PUL and RUL components were both replaced and retested the same day as the initial test and subsequently passed the performance test. This performance test was conducted within the past three years. Date of Last Test: 4/17/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No The report indicates that the PUL gasoline vapor recovery system failed the static pressure test due to the "drop tube leaking vapor." The report does not document any corrective actions or additional testing. The RUL gasoline vapor recovery system passed the static pressure test. This performance test was conducted within the past three years. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Unleaded (PUL) Amount of Fuel Delivered: 1) 3,000 gallons 2) 1,500 gallons Annual Certification Test - Vapor Tightness Testing - EPA Method 27 of appendix A-8 to part 60 of CAA Date of Last 04/01/2024 Test: 5-Year Test Record Available with truck Availability: Available at office or central Page 5 of 8 loc. Not Available Other: Results of Pass Test: Fuel Delivery Event Observation: A fuel delivery event was observed by the EPA inspector. The inspector used a forward-looking infrared (FLIR) camera to record optical gas imaging (OGI) videos of gasoline vapors. Any auditory, visual, and olfactory (AVO) observations were also recorded. See Appendix A for a list of photographs and videos recorded during the fuel delivery inspection. Components of the refueling activity which were observed: Description/Observations (including any OGI or AVO observations) Conditions of Liquid was observed in the PUL spill bucket prior to fuel Equipment prior to delivery. refueling event Connection of fuel and vapor lines prior to fuel transfer Vapors were observed from PUL spill bucket during fueling. Several inches of liquid were accumulated in the spill bucket, which could have contributed to the vapors observed. However, the amount of vapors observed indicate that the standing liquid was likely not the only source of the vapors. Maintenance of fuel Vapors may have also been coming from the premium vapor and vapor line recovery spill bucket as well, but it was difficult to discern due connections during to the fill bucket emission plume. fueling event Vapors were observed from the vapor recovery still bucket during RUL fueling. Note that this vapor recovery hose had been observed during an EPA inspection at another Loaf N Jug immediately prior to this delivery, and no emissions were observed during that delivery. Disconnection of fuel No vapors were observed from the RUL vapor spill bucket and vapor lines after after the vapor recovery hose was disconnected and prior to fuel transfer capping the pipe. This suggests that the vapor pipe to vapor recovery hose connection was likely not vapor tight. Conditions of Equipment after refueling event Documents Requested Document(s) 5-year fuel throughput records including previous 12-month fuel Document(s) Provided Status Document(s) Denied Page 6 of 8 Notes/Comments Documents Requested Document(s) throughput calculation EPA Method 27 for the fuel delivery truck Most recent NESHAP 6C Performance Tests Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Status Other (see notes) Document(s) Denied Other (see notes) Document(s) Denied Other (see notes) Notes/Comments APPENDIX A: Photograph and Video Log File Name Description MOV_3535.mp4 MOV_3536.mp4 MOV_3537.mp4 IMG_0081.JPG IMG_0082.JPG IMG_0083.JPG IMG_0084.JPG IMG_0085.JPG IMG_0086.JPG IMG_0088.JPG Vapors were observed from PUL spill bucket during fueling. Several inches of liquid were accumulated in the spill bucket, which could have contributed to the vapors observed. However, the amount of vapors observed indicate that the standing liquid was likely not the only source of the vapors. Vapors may have also been coming from the premium vapor recovery spill bucket as well, but it was difficult to discern due to the fill bucket emission plume. Vapors were observed from the vapor recovery still bucket during RUL fueling. Note that this vapor recovery hose had been observed during an EPA inspection at another Loaf N Jug immediately prior to this delivery, and no emissions were observed during that delivery. No vapors were observed from the RUL vapor spill bucket after the vapor recovery hose was disconnected and prior to capping the pipe. This suggests that the vapor pipe to vapor recovery hose connection was likely not vapor tight. Fuel truck fuel delivery header system. Fuel truck: Trailer identifier Fuel truck: Truck identifier EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. Vapor vent stacks for the RUL, PUL, and diesel storage tanks, as well as the general refueling area prior to fuel delivery. Page 7 of 8 Photographer K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl IMG_0089.JPG IMG_0090.JPG IMG_0091.JPG IMG_0092.JPG IMG_0093.JPG IMG_0094.JPG IMG_0095.JPG IMG_0096.JPG IMG_0097.JPG IMG_0098.JPG RUL fuel tank fill, vapor recovery, and automatic tank gauging (ATG) equipment. PUL fuel tank fill, vapor recovery, and automatic tank gauging (ATG) equipment. Diesel fuel tank fill, vapor recovery, and automatic tank gauging (ATG) equipment. Vapor vent stacks for the RUL, PUL, and diesel storage tanks. Vapor vent stacks for the RUL, PUL, and diesel storage tanks. Vapor vent stacks for the RUL, PUL, and diesel storage tanks. Condition of the PUL fuel tank fill and vapor recovery spill buckets prior to refueling, after the covers and caps had been removed and the vapor recovery hose had been connected. Liquid was observed in the PUL fuel tank spill bucket. Vapors were observed from the liquid in the spill bucket. Condition of the PUL fuel tank spill bucket prior to refueling, after the covers and caps had been removed and the fuel hose had been connected. Liquid was observed in the PUL fuel tank spill bucket. Vapors were observed from the liquid in the spill bucket. Condition of the vapor recovery hose elbow connector which connects the hose to the tank's vapor recovery pipe. Condition of the RUL vapor recovery pipe and spill bucket after fuel delivery. Extensive rust throughout the spill bucket was observed. K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 8 of 8 July 1, 2024 Ref: 8ECA-W-NW SENT BY EMAIL DIGITAL READ RECEIPT REQUESTED Utah County Government Public Works Richard Nielson, Director 2855 South State Street Provo, Utah 84606 richardjn@utahcounty.gov Re: Clean Water Act, Section 404 Inspection Report Loafer Mountain Parkway, Utah County, Utah Dear Mr. Nielson: On May 2, 2024, the U.S. Environmental Protection Agency (EPA), Region 8, conducted a Clean Water Act (CWA) Section 404 Inspection (Inspection) of Loafer Mountain Parkway, near 40.0674 north latitude and -111.6884 west longitude (Site). The purpose of the Inspection was to evaluate compliance with the requirements of Sections 301 and 404 of the CWA, 33 U.S.C. 1311 and 1344. The inspection was conducted under the authority of Section 308 of the CWA. Enclosed is a copy of the EPA's Inspection Report. If you have any questions, please contact Zach Schlachter at (303) 312-6896 or via email at schlachter.zachary@epa.gov. Sincerely, EMILIO LLAMOZAS Digitally signed by EMILIO LLAMOZAS Date: 2024.07.01 13:59:49 -06'00' Emilio Llamozas, Section Supervisor NPDES & Wetlands Enforcement Section Enforcement and Compliance Assurance Division Enclosures Inspection Report Attachments A-C electronic cc: Cynthia Ovdenk, US Army Corps of Engineers Jason Gipson, US Army Corps of Engineers Mike Pectol, US Army Corps of Engineers 2 Clean Water Act Section 404: Site Visit/Case Development For inspections authorized pursuant to Clean Water Act sections 308 and 404 (33 U.S.C. 1318 and 1344) This report includes only factual information gained by documentation, onsite observations, and/or onsite interviews. Inspector Name(s) Zach Schlachter, Rebecca Little Owl - EPA R8 Scott McWhorter, Andy Zellinger - EPA R9 Time In 9:30am Time Out 11:45am Start Date May 2, 2024 End Date May 2, 2024 Inspector's Organization Enforcement and Compliance Assurance Division/NPDES & Wetlands Enforcement Section Organization Requesting Inspection (if different) Inspection Type Evaluation Inspection Status Original Site Name Loafer Mountain Parkway Site Address* Loafer Mountain Parkway alignment between 8000 South and SR-198, and between I-15 and Beet Road City* Salem County* Utah State* UT Zip Code* 84653 Mailing Address* 2855 South State Street City* Provo County* Utah State* UT Zip Code* 84606 Latitude* 40.0674N Estimated Size of Site (acres) 1000 Inspector Signature Supervisor Signature Longitude* -111.6884W Is there a home on the site? Yes No Date 06/27/2024 Date 06/27/2024 Effective August 2020 Page 1 of 5 Clean Water Act Section 404: Site Visit/Case Develoment For inspections authorized pursuant to Clean Water Act sections 308 and 404 (33 U.S.C. 1318 and 1344) Site Name Loafer Mountain Parkway Start Date May 2, 2024 End Date May 2, 2024 Inspection Purpose Initial site visit Presentation of Inspector Credentials Opening Conference Name and Title (Use N/A if owner/operator not available to join the inspection) Credentials were presented to Mr. Richard Nielson. Opening Conference Name of person authorizing access if applicable All portions of the property inspected were accessed via public right-of-way. Notes from Opening Conference Brief introductions, review of site maps, background information of the site, and objectives for the day were discussed. Access Issues if Any Describe No site access issues. Inspection Observations and Sample Collection Site Owner/Site Operator/Responsible Party (Name, title and contact information) Utah County Government Public Works Richard Nielson, Director 2855 South State Street Provo, Utah 84606 801-420-7619 richardjn@utahcounty.gov Additional Persons Present at Inspection See Attachment A - Meeting Sign-In Sheet General Site Characteristics (layout of property, etc.) The Site has been impacted by heavy machinery for the construction of the Loafer Mountain Parkway. Heavy machinery was used to import and spread a large amount of fill material within wetlands and channels for the construction of the Parkway. Impacts include, but are not limited to, culverts, side casted material and placement of water control structures for the construction of irrigation ditches, and fill material to expand the roadway width. The Loafer Mountain Parkway alignment is complete and open to the public. Purpose and Need for Discharge of Dredged and/or Fill Material Construction of a new roadway, Loafer Mountain Parkway. The purpose of the Parkway is to improve mobility and alleviate current and future traffic delays and congestion in the Elk Ridge and Salem areas. Effective August 2020 Page 2 of 5 Clean Water Act Section 404: Site Visit/Case Develoment For inspections authorized pursuant to Clean Water Act sections 308 and 404 (33 U.S.C. 1318 and 1344) Site Name Loafer Mountain Parkway Start Date May 2, 2024 End Date May 2, 2024 Site Overview (Past inspections, site description, permits, etc.) The approximate 1000-acre Site is located between Elk Ridge Drive and Interstate15, northwest of Salem in Sections 2, 3, 10, 11, 34, and 35, Township 8 South and 9 South, Range 2 East, Salt Lake Meridian, Latitude 40.0666N, Longitude -111.6857W, Salem, Utah County, Utah. On August 22, 2017, a section 404 Corps Individual Permit was issued for the road construction project, which authorized the loss of 3.4 acres of wet meadow wetland and 0.34 acre of emergent marsh wetland, as well as permanent impacts to 1,224 linear feet of channel/ditch features. The observed impact areas are generally consistent with the Individual Permit, but the fill footprint width exceeded the authorized acreage. The permit also required retaining walls within wetland crossing areas to reduce the width to 64 feet. However, the completed roadway width did not incorporate retaining walls and fill slopes were constructed instead, in excess of 64 feet. In addition, a ditch has been constructed parallel to the road through a large portion of wetland crossing, which was not part of the original authorization. The work authorized by the August 22, 2017 Individual Permit did not begin until November 2022, after the 5-year permit authorization expired. The Army Corps of Engineers (Corps) conducted a site visit on August 30, 2023. During the August 30 inspection, Corps personnel explained that the reason for the site visit was to: (1) discuss project history and permitting to bring all parties up to speed; (2) gather information and better understand what work had already occurred within jurisdictional waters; (3) get clarification on the PCN submittal for NWP 14 regarding the ditch construction; (4) discuss next steps and potential paths forward. On October 12, 2023, the Corps sent a letter to the Utah County Government Public Works Department, indicating that one or more of the terms and conditions of the Individual Permit were not in compliance. The Corps determined that the activities in wetlands had exceeded the authorized impact acreage by at least 2 acres and that the work appeared to have occurred after the permit expired. In the Spring of 2023, irrigation ditches were constructed as shown in Attachment B, photograph 7 and 8. The pre-construction notice and nationwide permit application was submitted in August 2023. The impacts associated with the construction of the irrigation ditches have not been authorized. Scope of Inspection (Areas inspected or not inspected) Inspected all areas on the Site documented in Attachment B. Effective August 2020 Page 3 of 5 Clean Water Act Section 404: Site Visit/Case Develoment For inspections authorized pursuant to Clean Water Act sections 308 and 404 (33 U.S.C. 1318 and 1344) Site Name Loafer Mountain Parkway Environmental Conditions (e.g., wind, rain, smoke, dust, temperature, snow) Sunny with a high of 64 degrees. Field Work Conducted Observations and photographs were taken of the current Site conditions. Closing Conference Documents Received and/or Requested During the Inspection Documents requested during the inspection and received on May 5, 2024: Loafer Mountain Parkway (SPK-2009-01357) Timeline 2017 Approved 404 Permit (SPK-2009-01357) 2016 Approved Mitigation Plan 2020 SPK-2009-01357 Modification Submission 2021 Emails RE 404 Wetland Modification 2023 NWP14 for Irrigation Ditch Impacts 2023 November Response to USACE 2023 Emails between Consor & USACE Impacted Areas Roadway Design Plans Culvert Design Plans along Beer Creek Start Date May 2, 2024 End Date May 2, 2024 Compliance Assistance Provided (If any) All areas identified in the potential issues of concern section below were discussed during the inspection. Observations Relayed to Site Owner/Operator All areas identified in the potential issues of concern section below were discussed during the inspection. Actions Taken by Owner/Operator During the Inspection (If any) N/A Potential Issues of Concern Including Regulatory Citations The following list outlines observations documented during the site visit: 1. Berm and culvert installed that was not in the original permit (Photos 1 and 2). 2. Spoil pad that has spilled into the riparian and wetland area along Beer Creek. (Photo 4). 3. Culvert was originally designed to be 10ft x 3ft but was extended to 10ft x 4ft (Photos 5 and 6). 4. Construction of Irrigation ditch adjacent to the roadway (Photos 7 and 8). 5. Culverts and fill slope impacts where retaining walls were to be installed (Photos 11, 12, 14 and 15). Maps and Sketches Photographs (including location) and Photo Log Attachments* Effective August 2020 Page 4 of 5 Clean Water Act Section 404: Site Visit/Case Develoment For inspections authorized pursuant to Clean Water Act sections 308 and 404 (33 U.S.C. 1318 and 1344) Site Name Loafer Mountain Parkway Other Attachment A - Meeting Sign-In Sheet Attachment B - Photolog Attachment C - Antecedent Precipitation vs Normal Range Rainfall Data Additional Notes None. Start Date May 2, 2024 End Date May 2, 2024 Effective August 2020 Page 5 of 5 Attachment B Loafer Mountain Parkway May 2, 2024 Photolog U.S. Environmental Protection Agency Region 8 1595 Wynkoop St Denver, CO 80202 Page 2 of 17 Photo #: 1 Site Name Photographer Date Camera Model Comments IMG_20240502 _100500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.06103313888889 May 2, 2024 10:12 AM Longitude -111.6839690138889 iPhone 13 Direction N Berm in foreground with a culvert installed that was not in the original permit. Page 3 of 17 Photo #: 2 Site Name Photographer Date Camera Model Comments IMG_20240502 _100500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.060911472222216 May 2, 2024 10:14 AM Longitude -111.68416338055556 iPhone 13 Direction S Southern portion of the berm and culvert identified in photograph 1. Page 4 of 17 Photo #: 3 Site Name Photographer Date Camera Model Comments IMG_20240502 _100500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.06143340277777 May 2, 2024 10:34 AM Longitude -111.68724331111112 iPhone 13 Direction WNW Approximate 16ft Box culvert on Beer Creek. Page 5 of 17 Photo #: 4 Site Name Photographer Date Camera Model Comments IMG_20240502 _100500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.06145758333333 May 2, 2024 10:35 AM Longitude -111.68728914444445 iPhone 13 Direction NW Spoil pad that has spilled into the riparian and wetland area along Beer Creek. The fence was installed to keep cattle and people out. Page 6 of 17 Photo #: 5 Site Name Photographer Date Camera Model Comments IMG_20240502 _100500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.061602416666666 May 2, 2024 10:42 AM Longitude -111.68732452777778 iPhone 13 Direction S Approximate 4ft x 10ft box culvert intentionally built below grade along Beer Creek. The culvert is approximately 10ft from bank to bank and was originally designed to be 10ft x 3ft but was extended to 4ft. The culvert installed on the side functions as a storm drain. Page 7 of 17 Photo #: 6 Site Name Photographer Date Camera Model Comments IMG_20240502 _100500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.06133480555555 May 2, 2024 10:50 AM Longitude -111.68703629444445 iPhone 13 Direction E Striking east over the boxed culvert identified in photograph 5. Page 8 of 17 Photo #: 7 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.0586285 May 2, 2024 11:00 AM Longitude -111.68903990555556 iPhone 13 Direction SW In 2023, to appease a landowner, irrigation ditches were constructed along the roadway. Impacts occurred in Spring of 2023; the pre- construction notice and nationwide permit application was submitted in August 2023. Page 9 of 17 Photo #: 8 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.05865872222222 May 2, 2024 11:01 AM Longitude -111.68900001388889 iPhone 13 Direction NE In 2023, to appease a landowner, irrigation ditches were constructed along the roadway. Impacts occurred in Spring of 2023; the pre- construction notice and nationwide permit application was submitted in August 2023. Page 10 of 17 Photo #: 9 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.068757294444445 May 2, 2024 11:12 AM Longitude -111.68829813333333 iPhone 13 Direction E Mitigation area is approximately 59.3 acres with room to expand total to 75 acres. Page 11 of 17 Photo #: 10 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.068741888888894 May 2, 2024 11:13 AM Longitude -111.6883124888889 iPhone 13 Direction W West side of mitigation area in photograph 9. Page 12 of 17 Photo #: 11 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.06873405277778 May 2, 2024 11:18 AM Longitude -111.68829161111111 iPhone 13 Direction S The individual permit required retaining walls within wetland crossing areas to reduce the width to 64 feet. However, the completed roadway width did not incorporate retaining walls and fill slopes were constructed instead, in excess of 64 feet. Page 13 of 17 Photo #: 12 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Zach Schlachter Latitude May 2, 2024 11:21 AM Longitude iPhone 13 Direction Same as photograph 11 but striking north. Yes 40.06873216666667 -111.68828590555556 N Page 14 of 17 Photo #: 13 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Yes Zach Schlachter Latitude 40.06875973333334 May 2, 2024 11:23 AM Longitude -111.68829556666667 iPhone 13 Direction N/A 2023 as built design. The orange line is the retaining wall, the red line is the fill slopes, which is what was constructed in place of the retaining wall. The approximate distance is 86ft from fence to fence. Page 15 of 17 Photo #: 14 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway Zach Schlachter May 2, 2024 11:27 AM iPhone 13 Constructed 3:1 fill slopes. GNSS Used Latitude Longitude Direction Yes 40.068791983333334 -111.6885815888889 S Page 16 of 17 Photo #: 15 Site Name Photographer Date Camera Model Comments IMG_20240502 _110500 Loafer Mtn Parkway GNSS Used Zach Schlachter Latitude May 2, 2024 11:28 AM Longitude iPhone 13 Direction Same as photograph 14 but striking north. Yes 40.06881925555556 -111.68857620833333 N Page 17 of 17