Document 1QypneL7kzOb5a2343GqRp6Rd

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_0910_03 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: September 10, 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 United Pacific / CF Altitude LLC Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): Alta Convenience #3106 2805 N Elizabeth St Pueblo, CO 81003 Katelyn Bergl Field Inspector Name Scott Patefield Inspector and Approval Inspector Title Branch Manager KATELYN BERGL Date: 2024.11.19 17:30:29 -07'00' Digitally signed by KATELYN BERGL Signature Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2024.11.19 15:57:39 -07'00'  FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Alta Convenience #3106 Parent Company Name: AIRS-ID: 101-0189-001 CAA Permit (if any): Primary Facility Representative & Title: ODeana Wilson Corporate Environmental Manager On-site Facility Representative & Title: CF Altitude LLC Permit Exempt Number 02PB0393S.XP Lola Baca, Manager Phone/Email: Facility Contact Odeana.Wilson@unitedpacific.com On-site Contact N/A Phone/Email: Facility Address: 2805 N Elizabeth St, Pueblo, CO 81003 Enforcement and Compliance History: None Fuel Delivery Company Fuel Supply Company Name: World Kinect Corporation Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 8381 (VIN NJ163032) Ron Browning Operations Manager Ronbrowning@wfscorp.com Name (if different): Trucking Company Same Trailer Identifier: 0791 Driver Name: Brian Langley Company Address: Fuel Supply 1739 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: Weather & Other General Site Observations: Inspection Narrative: General Inspection Information R8_CAA_2024_0910_03 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 9/10/2024 3:15 PM 4:11 PM 3:15 PM Yes No Lola Baca Katelyn Bergl Announced Unannounced Administrative Inspection Items: Photograph Range: CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): IMG_0040 - IMG_0046; IMG_0048 - 0049 MOV_3526 - 3527 Partly cloudy, 80 deg F, winds 7 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. The following are areas of concern identified during the inspection or records review: 1. According to records submitted by the company, this facility had a 12- month gasoline throughput in excess of 1,200,000 gallons in October 2021 for the 12-month period from November 2020 through October 2021, resulting in a monthly throughput of gasoline greater than 100,000 gallons per month. Therefore, in October 2021, the facility became subject to the control requirements of 40 CFR 63.11118 - Requirements for facilities with monthly throughput of 100,000 gallons of gasoline or more. Areas of Concern: NESHAP 6C at 40 CFR 63.11113(c) clarifies that existing sources which become subject to the control requirements of 40 CFR 63.11118 due to an increase in the monthly throughput must comply with the additional requirements, including installation of a vapor balance system and initial performance testing to demonstrate compliance, no later than three years after the source becomes subject. In this case, the facility appears to have triggered the control requirements in October 2021, and must have complied with 40 CFR 63.11118 by October 2024. In an email exchange regarding inspection records, a facility representative stated on September 24, 2024 that this facility has WZ  "not had the NESHAP testing based on their current throughputs and are outside the Non-Attainment Zone." However, this facility's throughput exceeds the trigger which requires the NESHAP testing described at 40 CFR 63.11120(a)(1) and (2). Although CDPHE imposes more stringent requirements for gasoline dispensing facilities within the ozone non-attainment Denver Metro area, the NESHAP 6C testing is required nationwide for facilities that exceed the 100,000 gallon per month threshold. 2. Components of the tank and associated vapor equipment 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 the RUL spill bucket prior to pipe cap removal and prior to fueling. The components were inspected after fueling and the driver stated that the tank-side gasket was in poor condition, likely causing vapor leak. b. Vapors were observed from the vapor vent and from the RUL spill bucket area during RUL fueling. According to the driver, there is no vapor recovery system at this facility to connect to, so vapor was not recovered by the truck. 3. The facility has not conducted initial performance tests to demonstrate compliance with the leak rate and cracking pressure requirements specified in item 1(g) of Table 1 of NESHAP 6C, and the static pressure performance requirement specified in item 1(h) of Table 1 of NESHAP 6C, as required by 40 CFR 63.11120(a)(1) and (2). Based on the emission observations recorded during the inspection (described in Area of Concern #2), in conjunction with the driver's confirmation that there was no vapor recovery system for the truck's vapor recovery hose to connect to, the existing system is not compliant with 40 CFR 63.11118. 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 in October 2021. Records: All Facilities regardless of throughput Notes WZ  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 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 ODeana Wilson on September 24, 2024. The spreadsheet indicates that the records are for the product "gasoline", and Ms. Wilson clarified that "gasoline" includes unleaded, midgrade, premium, and E-85 blends. Provided along with 5-year throughput records Notes Date of Last Test: Never Results of Last Test: Pass / Fail Report Provided: Yes / No This NESHAP 6C performance test was required no later than October 2024, but has not been completed. Date of Last Test: Never Results of Last Test: Pass / Fail Report Provided: Yes / No This NESHAP 6C performance test was required no later than October 2024, but has not been completed. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Amount of Fuel Delivered: 1) 6,000 gallons 2) 1,800 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 11/19/2023 Test: 5-Year Test Record Availability: Available at office or central loc. 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 WZ  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 Vapors were observed from the RUL fill spill bucket prior to pipe cap Equipment removal and prior to fueling. The components were inspected after prior to fueling and driver stated that the tank-side gasket was in poor refueling condition, likely causing vapor leak (MOV_3526). event Connection of According to the driver, the gasoline storage tanks at this facility are fuel and vapor not designed with a vapor recovery system. Consequently, the driver lines prior to did not connect the vapor recovery hoses during refueling, and vapors fuel transfer were observed from the tank vapor vents and from the RUL spill bucket area during RUL fueling. Maintenance The gasket on the top of the RUL fill pipe was in poor condition, of fuel and causing liquid and vapor fuel leak during refueling of the RUL tank. vapor line The driver switched out the fuel hose elbow connections to attempt to fix the problem but was not able to prevent the leak. These same connections elbow connections did not leak fuel or vapors when connected to the during fueling premium fill pipe, which indicates that there is an issue with the event tank-side gasket on the RUL fill pipe. Disconnection of fuel and vapor lines after fuel transfer Conditions of Equipment after refueling event WZ  Facility Design Notes Component Vapor Recovery system Vapor Vents Tanks Automatic Tank Gauging (ATG) System Design No vapor recovery system installed It appears that 3 pressure/vacuum (P/V) type vents are installed at the facility, likely associated with the RUL, premium, and E-85 tanks. There is one additional vent, likely for the diesel tank, which is a direct-vent type vent. 1 RUL tank; 1 premium tank; 1 E-85 tank; 1 diesel tank 1 for each tank type Quantity/ Capacity 0 4 Observations (disrepair, unsealed connections, signs of spills, etc) No vapor recovery system installed to recover vapors from the RUL, premium, or E-85 gasoline storage tanks. Due to the absence of a vapor recovery system, the P/V vents do not prevent vapors from being emitted during refueling events, since the large pressure increase in the tanks during a refueling event exceeds the maximum pressure setting of the P/V vents. 4 4 Documents Requested Document(s) 5-year fuel throughput records including previous 12-month fuel throughput calculation EPA Method 27 for the fuel delivery truck NESHAP 6C Initial 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 Performance tests not conducted; records not available. WZ  APPENDIX A: Photograph and Video Log File Name Description MOV_3526.mp4 MOV_3527.mp4 IMG_0040.JPG Vapors were observed from the RUL fill spill bucket prior to pipe cap removal and prior to fueling. Vapor were observed from the vapor vent and from the RUL spill bucket area during RUL fueling. According to the driver, there is no vapor recovery equipment at this facility to connect to, so vapor was not recovered by the truck. Condition of premium tank cover prior to fuel delivery. IMG_0041.JPG Condition of RUL tank cover prior to fuel delivery. IMG_0042.JPG Condition of E-85 tank cover prior to fuel delivery. IMG_0043.JPG Condition of diesel tank cover prior to fuel delivery. IMG_0044.JPG Tank vent stacks. IMG_0045.JPG Tank vent stacks and tank covers prior to fuel delivery. IMG_0046.JPG Fuel truck: Trailer identifier IMG_0048.JPG IMG_0049.MOV RUL tank spill bucket and fill pipe gasket after refueling to demonstrate the condition of the gasket. RUL tank spill bucket and fill pipe gasket after refueling to demonstrate the condition of the gasket. Photographer K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl WZ