Document G6gEKY9xrBV1rDeV1aXG89117

Compliance Evaluation Inspection Report South Dakota Department of Transportation Isabel July 2024 Submitted to: U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop St. Denver, CO 80202 Submitted by: Eastern Research Group. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 EPA Contract No. 68HERC21D0007 Task Order 68HERC22F0492 COMPLIANCE EVALUATION INSPECTION REPORT Date of Report: July 8, 2024 Date and Time of Inspection: May 15, 2024 at 9:35 AM MST Weather: Cloudy, 55 Fahrenheit Facility Contact/Owner: Owner Address: 700 East Broadway Avenue Pierre, South Dakota 57501 Facility Address: 201 Hillview Road Isabel, South Dakota 57633 Facility Phone: Facility ID Number: 4020025 Reason for Inspection: Compliance Inspection Inspector(s): , ERG (Lead) SD DOT Isabel CEI Report ii July 2024 TABLE OF CONTENTS 1. NARRATIVE ..................................................................................................................... 1 2. SUMMARY ........................................................................................................................ 4 ATTACHMENTS Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: Attachment F: Attachment G: EPA Region 8 UST Compliance Checklist Photograph Log Tank Leak Detection Records Equipment Testing Records Monthly and Annual Walkthrough Inspections Commercial Insurance Certification Notice Of Inspection SD DOT Isabel CEI Report iii July 2024 1. NARRATIVE The Region 8 (R8) office of the Environmental Protection Agency (EPA) requested multiple facilities be inspected on tribal lands. Eastern Research Group (ERG) under EPA's Contract No. 68HERC21D0007, Task Order 68HERC22F0492, provided assistance to EPA in preparing for, conducting the inspection, and preparing this inspection report. ERG inspected the South Dakota Department of Transportation (SD DOT) Isabel located in Isabel, South Dakota on May 15, 2024. The facility was last inspected on June 29, 2021. , contract inspector for EPA, contacted Mr. , representative of SD DOT, to notify the facility about the inspection on April 26, 2024, prior to the inspection. The inspection verified compliance with the federal underground storage tank (UST) requirements of Resource Conservation and Recovery Act (RCRA) Subtitle I under 40 CFR Part 280. Upon arrival at the facility, Ms. introduced herself as a contract inspector for EPA, presented her credentials, and provided an in-brief to Mr. and Mr. . Ms. concluded with an exit brief to inform the facility of preliminary observations identified during the inspection and had Mr. sign the Notice of Inspection. Ms. took photographs during the inspection. UST System Description SD DOT Isabel (facility) is a highway maintenance shop and depot, located immediately north of Isabel, SD, along County Road 1D, about 500 feet west of State Highway 65. Fuel stored at this facility is used to operate highway maintenance vehicles. The facility is located on the Cheyenne River Indian Reservation. According to the previous EPA inspection report and observations made during the inspection, the facility has two fiberglass-reinforced plastic (FRP) installed in October 2006. Tank 1 has a capacity of 3,000 gallons and contains diesel. Tank 2 has a capacity of 1,000 gallons and contains unleaded gasoline. The dispensing system for each of the tanks is European Safe Suction and is constructed using FRP. Ms. completed an EPA Region 8 UST Compliance Inspection Checklist for the USTs while on site which is included in Attachment A. Photograph #1 in Attachment B shows the dispensers and an overview of the UST system. UST System Records The listing of documents reviewed for the SD DOT Isabel inspection included the following: 1. UST Leak Detection Records 2. South Dakota Certificate of Financial Assurance 3. Facility Monthly and Annual Walkthrough Inspections The facility maintains all records on site. Mr. the inspection. provided the records for the UST during SD DOT Isabel CEI Report 1 July 2024 Tank Release Detection The facility uses a Veeder Root TLS-450 monitoring system and associated in-tank probes that conduct automatic tank gauging (ATG) of the tanks. Mr. provided the last 12 months of passing leak detection results. Attachment C contains a compilation of the ATG leak test results for the last 12 months. Photograph #2 in Attachment B shows the monitoring system interface. The annual ATG certification was conducted in October 2023 and the system passed. Attachment D includes the ATG certification. Piping Release Detection Piping leak detection is not required because this facility has safe suction piping. This was confirmed during the physical site inspection. Spill/Overfill Prevention Spill and overfill prevention equipment tests were provided for review during the inspection. The spill buckets were replaced in October 2021 and tested subsequently after the replacement. Both spill buckets passed the integrity test. Overfill prevention is conducted by an overfill alarm that was lasted tested in June 2021 and passed. The overfill alarm was observed and passed the inspection. Photographs #3 and #4 in Attachment B show the fill ports for the two USTs. Attachment D includes the spill and overfill prevention test results. Corrosion Protection Cathodic Protection (CP) is not required as the tanks and piping are constructed of FRP. Operator Training Certificates for the Class A and Class B operator were presented during the inspection. and are the Class A and Class B designated operators. There are no designated Class C operators. Walkthrough Inspections Records of the monthly and annual walkthrough inspections were available for review during the inspection. Attachment E includes the monthly and annual walkthrough inspection records. 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 South Dakota certificate of financial assurance for the facility. Physical Inspection During the site visit, Ms. reviewed documents on site and observed the fill ports, both dispensers, and the ATG monitoring interface for the two USTs on site. Photograph #2 in Attachment B shows the interface for Veeder Root TLS-450 ATG system. Ms. also SD DOT Isabel CEI Report 2 July 2024 observed the spill bucket and fill pipe for the two USTs. The spill buckets for Tank 1 and Tank 2 were clean and in good condition at the time of the inspection. The access ports for ATG probes were also present for each of the tanks, and no issues were noted for these during the inspection. There were two double-sided pump dispensers on site, one for diesel and one for gasoline, and both dispensers were opened as part of the inspection. The safe suction system was observed, and Ms. did not observe signs of leaks at the time of the inspection. Photographs #5 through #8 in Attachment B show the safe suction systems and piping in each dispenser. No monitoring wells were observed at the tank field during the inspection. Vent lines are located east of the USTs against the main garage, and no obstructions or concerns were noted for the vent lines at the time of the inspection. The external overfill alarm was observed. SD DOT Isabel CEI Report 3 July 2024