Document 3NGDaM60V3QM5J7zoxJ7axyma

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: Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: Facility Name: Facility Physical Location: R8_CAA_2025_0626_002 6/26/2025 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 Maverik, Inc. Maverik #5295 525 Wooten Road, Colorado Springs, CO, 80815 Alyson Skeens Field Inspector Name Inspector and Approval Inspector Title ALYSON SKEENS Digitally signed by ALYSON SKEENS Date: 2025.09.10 13:54:22 -06'00' Signature Scott Patefield Name of Approving Official Branch Manager Title Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2025.09.05 11:28:32 -06'00' Signature FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Maverik #5295 Parent Company Name: AIRS-ID: None CAA Permit (if any): Primary Facility Representative & Title: Facility Contact Phone/Email: Mark Stewart Sr. Environmental Engineer 801-438-4884 Mark.Stewart@maverik.com On-site Facility Representative & Title: Maverik, Inc. This facility does not have a CAA permit, APEN, or APEN Exempt memo on file Terri Howells, Store Manager Facility Address: 525 Wooten Rd, Colorado Springs, CO 80915 Enforcement and Compliance History: None Fuel Delivery Company Company Name: Trucking Solar Transport Company Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: USDOT 231451 Tyler DePhillips Senior Director of Operations 515-706-3408 tyler.dephillips@solartransport.com Trailer Identifier: 257250 Driver Name: Brendan Walter Fuel Supply Company 1150 Locust Street, Sute 301, Des Moines, IA 50309 Address: 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: Inspection Narrative: Areas of Concern: General Inspection Information R8_CAA_2025_0626_002 Inspection Date Katelyn Bergl (EPA) Alyson Skeens (EPA) Chris Andrade (EPA) Arrival/Departure Time 6/26/2025 8:30 AM 9:20 AM 8:30 AM Announced Unannounced Yes No Terri Howells, Store manager Administrative Inspection Items: CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): Katelyn Bergl (EPA) Alyson Skeens (EPA) Chris Andrade (EPA) Photograph Range: See APPENDIX A: Photograph and Video Log 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 inspectors 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. An Air Pollutant Emissions Notice, or APEN, has not been submitted to the Colorado Department of Public Health and Environment's (CDPHE) Air Pollution Control Division (APCD). Typically, APENs are required upon startup and must be updated every 5 years for this source category. 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. During simultaneous regular unleaded fuel (RUL) and diesel fuel tank filling, vapors were observed from the RUL tank's pressure/vacuum-style (P/V) vent. Page 3 of 6 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 July 2020, the facility exceeded the 100,000 gallons per month throughput threshold on or before June 2021. Records: All Facilities regardless of throughput 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Notes Throughput records for this facility from July 2020 - June 2025 were provided via email by Mark Stewart on June 26, 2025. Last 12-month rolling throughput calculation Provided along with 5-year throughput records Records: Facilities 100,000 gallons per month Notes 3 -year Leak Rate and Cracking Pressure Test (CARB Date of Last Test: 4/2/2024 Results of Last Test: Fail Report Provided: No Test Procedure TP-201.1E, - Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, or Tests were performed within the last 3 years. equivalent) Static Pressure Test (CARB Test Procedure TP-201.3, - Determination Date of Last Test: 4/2/2024 Results of Last Test: Fail Report Provided: No of 2-Inch WC Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, or equivalent) Tests were performed within the last 3 years. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Unleaded (PUL) 3) Diesel Amount of Fuel Delivered: 1) 3,700 gallons 2) 2,000 gallons 3) 2,300 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: March 12, 2025 5-Year Test Record Availability: Available at office or central loc. Not Available Other: Results of Test: Pass Pressure Change, p: Vacuum Change, v: Pass, 0.0 Pass, 0.0 Page 4 of 6 Fuel Delivery Event Observation: A fuel delivery event was observed by the EPA inspectors. The inspectors used a forward-looking infrared (FLIR) camera to record optical gas imaging (OGI) videos of gasoline vapors, and a toxic vapor analyzer (TVA) to measure gasoline vapor concentrations1. 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: Conditions of Equipment prior to Equipment was observed to be capped and covered prior to refueling event fueling. Connection of fuel The vapor recovery hose was first connected to the vapor recovery tank and truck header. Next, the fuel hose was and vapor lines prior connected to the fuel pipe of the tank, and finally the fuel hose to fuel transfer was connected to the truck header. During simultaneous fueling of the RUL and diesel tanks, vapors were observed with the FLIR from the vapor vents. See Maintenance of fuel FLIR0049. Specifically, emissions were observed from the and vapor line northern cluster of vapor vents, closest to the store building. connections during There were two vents in this cluster; one was equipped with a fueling event P/V-style vent, and the other was not. Based on this observation, the P/V-style vent was likely connected to the RUL tank. Emissions were observed from both vents. See FLIR0051. Disconnection of fuel and vapor lines after Hoses were disconnected in the opposite order for which they fuel transfer were connected. Conditions of Equipment after Caps and covers were returned after fueling. 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 Status Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Provided Will Provide After Inspection Document(s) Denied Other Document(s) Denied Other Document(s) Denied Other Notes 1 The TVA was calibrated using 500 parts per million (ppm) and 10,000 ppm methane gas standards. The methane concentrations recorded on the TVA were then converted to a ppm concentration as propane using a conversion factor of 3. This provides a conservative conversion to propane, using the guidance put forth in EPA's "Frequently Asked Questions (FAQ) for Method 25A". See https://www.epa.gov/sites/default/files/2016-08/documents/method25a_faq.pdf. Page 5 of 6 APPENDIX A: Photograph and Video Log File Name Description FLIR0049.mp4 FLIR0050.mp4 Emissions from vapor vents during simultaneous fueling of diesel and RUL tanks. Vapor vents. FLIR0051.mp4 20250626_1444 43365_iOS.heic Emissions from vapor vents from the northern-most cluster of vapor vents Cargo Tank Vapor Integrity Test (EPA Method 27) - Tank Unit #257250 for Solar Transport Inc. Photographer C. Andrade C. Andrade C. Andrade K. Bergl Page 6 of 6