Document 6wzv0Z8zvaG04qJYbn0NxqX7m

Compliance Evaluation Inspection Report South Dakota Department of Transportation Eagle Butte May 2024 Submitted to: U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop St. Denver, CO 80202 Submitted by: Eastern Research Group. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 EPA Contract No. 68HERC21D0007 Task Order 68HERC22F0492 COMPLIANCE EVALUATION INSPECTION REPORT Date of Report: June 14, 2024 Date and Time of Inspection: May 14, 2024 at 7:50 am MST Weather: Rainy, 55 Fahrenheit Facility Contact/Owner: Andrew Schuler Owner Address: 700 East Broadway Avenue Pierre, SD 57501 Facility Address: 24155 US Highway 212 Eagle Butte, South Dakota 57625 Facility Phone: (605) 964-4361 Facility ID Number: 4020005 Reason for Inspection: Compliance Inspection Inspector(s): , ERG (Lead) SDDOT Eagle Butte CEI Report ii May 2024 TABLE OF CONTENTS 1. NARRATIVE ..................................................................................................................... 1 2. SUMMARY ........................................................................................................................ 3 ATTACHMENTS Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: Attachment F: Attachment G: Attachment H: EPA Region 8 UST Compliance Checklist Photograph Log Tank Leak Detection Records Equipment Testing Records Monthly and Annual Walkthrough Inspections Commercial Insurance Certification Notification for Underground Storage Tanks Notice Of Inspection SDDOT Eagle Butte CEI Report iii May 2024 6. Class A/B Operator Training Certificates The facility maintains all records on site. Mr. the USTs during the inspection. and Mr. provided the records for Tank Release Detection Releases from the tanks are detected by a Veeder Root TLS-450 monitoring system and associated in-tank probes that conduct automatic tank gauging (ATG) of the tanks. Continuous statistical leak detection (CSLD) tests passed for Tank 1 and Tank 2 during the previous 12 months. Photograph #2 in Attachment B shows the monitoring system interface. Attachment C contains a compilation of the ATG CSLD leak test results for the last 12 months. Attachment D contains a passing test record for the ATG system performed by a contractor in October 2023. The submersible turbine pump (STP) sumps, dispenser sumps, and interstitial space of both Tank 1 and Tank 2 are equipped with liquid sump sensors. A liquid sensor functionality test was performed in October 2023 and showed that the sensors for the STP sumps, dispenser sumps, and interstitial space for both Tank 1 and Tank 2 are in good operating condition. The liquid sump sensors for the USTs were observed at the base of each STP sump and dispenser sump. The liquid sump sensor status for each tank is included in attachment C for the past 12 months which showed the status was normal except for October 2023 which was not provided during the inspection. Photographs #4 and #6 show the STP sumps for Tank 1 and Tank 2 with liquid sump sensors. The tanks were installed in October 2022 and integrity tests of the STP and dispenser containment sumps have not yet been conducted. Piping Release Detection All tanks were installed with pressurized double-walled flexible plastic piping. Ms. Forsmark observed electronic automatic line leak detectors (ALLDs) on the STPs during the inspection. American Electric performed a line leak detector performance test in October 2023. Attachment D includes the passing testing records for the leak detectors. Spill/Overfill Prevention Spill and overfill prevention equipment tests were not provided. The tanks were installed in October 2022 and spill bucket tests have not yet been conducted. Photographs #3 and #5 in Attachment B show the fill ports for Tank 1 and Tank 2. During the physical inspection, butterfly valves were noted in the fill pipes. Corrosion Protection According to facility documentation and observations, both tanks are jacketed with FRP and the piping is flexible plastic; therefore, corrosion protection is not required. Operator Training Certificates for the Class A and B operator were available during the inspection. Mr. is SDDOT Eagle Butte CEI Report 2 May 2024 designated as both Class A and Class B operator with a certificate dated March 30, 2016. Additionally, other employees' certificates were available for review. There are no other attendants that require training at the Facility. Walkthrough Inspections Records of the monthly and annual walkthrough inspections were available and completed. The monthly and annual walkthrough inspections are included in Attachment E. Financial Assurance In South Dakota, financial coverage for owners/operators of regulated USTs is provided through the South Dakota Petroleum Release Compensation Fund. Mr. had a copy of the letter from the state indicating facility coverage. They are self-insured for the deductible. Attachment F includes the letter indicating financial coverage and self-insurance for SD DOT Eagle Butte. Physical Inspection During the site visit, Ms. reviewed documents onsite and observed the fill ports, STP sumps, both of the dispensers and associated dispenser sumps, and the ATG monitoring interface for the two USTs onsite. Photograph #2 in Attachment B shows the interface for Veeder Root TLS-450 Plus ATG system. Ms. observed the spill bucket and fill pipe for the two USTs. The spill buckets for Tank 1 and Tank 2 were dry and in good condition at the time of the inspection. Ms. also observed the STP sumps for each of the two USTs. Both STP sumps were dry, ALLDs were observed on the STPs, and the sump sensors were observed at the bottom of the sumps. Photographs #4 and #6 in Attachment B show the STP sumps and associated components for Tanks 1 and 2. The facility has two double-sided pump dispensers, and both were opened as part of the inspection. The dispensers are equipped with sumps dispenser liquid sump sensors were observed within each dispenser sump. Ms. did not observe signs of leaks at the time of the inspection. Photographs #7 through #10 in Attachment B show the piping and sumps beneath each dispenser. No monitoring wells were observed at the tank field during the inspection. Vent lines are located north of the USTs against one of the garages. No obstructions or concerns were noted for the vent lines at the time of the inspection. SDDOT Eagle Butte CEI Report 3 May 2024 2. SUMMARY The facility has two USTs installed in October 2022. Tank 1 has a 2,500-gallon capacity, contains unleaded gasoline fuel, and is double-walled composite (steel with FRP jacket) construction. Tank 2 has a 3,000-gallon capacity, contains diesel fuel, and is double-walled composite (steel with FRP jacket) construction. Passing monthly monitoring leak detection test records were available for the previous 12 months for Tank 1 and Tank 2, except for October 2023 which was missing. The facility representative provided the Notification for Underground Storage Tanks installed following the previous EPA Inspection, included as Attachment G. The annual certification for the ATG system was provided during the inspection. There are two double-sided dispensers on site that operate with pressurized flexible plastic piping, and each dispenser has a containment sump. The STPs had ALLDs and the STP sumps were equipped with liquid sump sensors which were observed at the bottom of each sump. The liquid sump sensor status for each tank was not provided for October 2023 during the inspection. The fill port for each UST is equipped with a spill bucket and a butterfly valve in the drop tube as the spill and overfill prevention equipment. Testing records were not provided for the spill buckets or butterfly valves during the inspection. Cathodic protection testing records were not required as the tanks are composite steel with FRP jacket and the piping was flexible plastic. The facility has Class A and B certified operators and certifications were provided for review during the inspection. There are no other attendants that require training at the Facility. Monthly and annual walkthrough inspection records were provided during the inspection. The SD DOT Eagle Butte has financial coverage through the South Dakota Petroleum Release Compensation Fund and the facility has general liability insurance to cover the deductible. Attachment H contains the NOI signed by Mr. at the end of the inspection. Ms. provided a copy to Mr. and left the premises. Inspector Signature Date: _June 14, 2024____ SDDOT Eagle Butte CEI Report 4 May 2024