Document QQKR53xzk50DZyGmG5Qbqa7v

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_004 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 #5242 8050 Fountain Mesa Road, Fountain, CO, 80817 Alyson Skeens Field Inspector Name Scott Patefield Name of Approving Official Inspector and Approval Inspector Title ALYSON SKEENS Digitally signed by ALYSON SKEENS Date: 2025.09.10 13:52:52 -06'00' Signature Branch Manager Title Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2025.09.05 11:32:50 -06'00' Signature FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Maverik #5242 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 Arden Acierdo, Lead Facility Address: 8050 Fountain Mesa Rd, Fountain, CO 80817 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: 251265 Tyler DePhillips Senior Director of Operations 515-706-3408 tyler.dephillips@solartransport.com Trailer Identifier: 257254 Driver Name: Mario Robinson Fuel Supply Company 1150 Locust Street, Sute 301, Des Moines, IA 50309 Address: Enforcement and Compliance History: None Page 2 of 8 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: General Inspection Information R8_CAA_2025_0626_004 Inspection Date Katelyn Bergl (EPA) Alyson Skeens (EPA) Chris Andrade (EPA) Arrival/Departure Time 6/26/2025 1:00 PM 2:55 PM 1:00 PM Announced Unannounced Yes No Arden Acierdo, Lead 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. 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 apply: 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 Page 3 of 8 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. 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 September 21, 2024. In an email from Mark Stewart of Maverik on August 5, 2025, Mark stated that "One or more components failed 9/2024 testing. Repairs were made and will be retested in September 2025." The September 2024 test reports were not provided. However, failed performance tests indicate that the facility may not have been continuously complying with Items 1(g) and 1(h) of Table 1 of NESHAP 6C, specifically from the date of the failed performance test until components have been repaired and the repairs have been verified with a subsequent performance test indicating the system complies with the design standards. 3. 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 regular fuel (RUL) fueling, gasoline vapors at a concentration of 3.59% as propane, above the lower explosive limit (LEL), were observed from the RUL fueling spill bucket. b. During simultaneous RUL and diesel fuel tank filling, vapors were observed from the pressure/vacuum (P/V) vents. c. During and after premium fuel (PUL) fueling, gasoline vapors at a concentration of 3.59% as propane, above the LEL, were observed from the PUL vapor recovery spill bucket Page 4 of 8 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 July 2020. 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 - July 2025 were provided via email by Mark Stewart on August 4, 2025. Last 12-month rolling throughput calculation Provided along with 5-year throughput records 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: 9/21/2024 Results of Last Test: Fail Report Provided: No In an email from Mark Stewart on August 5, 2025, regarding tests TP-201.1E and TP-201.3, Mr. Stewart stated, "One or more components failed 9/2024 testing. Repairs were made and will be retested in September 2025." Date of Last Test: 9/21/2024 Results of Last Test: Fail Report Provided: No In an email from Mark Stewart on August 5, 2025, regarding tests TP-201.1E and TP-201.3, Mr. Stewart stated, "One or more components failed 9/2024 testing. Repairs were made and will be retested in September 2025." 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) 2,000 gallons 2) 5,000 gallons 3) 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 Test: November 18, 2024 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 5 of 8 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 Inspectors observed one tank for each of the following types of fuel: Regular Unleaded, Diesel, Mid, Premium, Deisel Exhaust Equipment prior to Fluid. Equipment was observed to be capped and covered prior refueling event to 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 RUL and PUL fueling, gasoline vapors above the LEL of propane were observed from the vapor balance system equipment using the FLIR and TVA. First, vapors were observed from the RUL fueling spill bucket during RUL fueling. Inspectors also observed liquid accumulated in the bucket, and during fueling movement in the liquid was observed consistent with vapor bubbles passing through liquid and supporting the observation of a leak in the spill bucket. See FLIR0053, Images 5-7, and Video 8. The vapors were measured with the TVA, and a concentration of 35,860 Maintenance of fuel parts per million (ppm) as propane, or 3.59%, was recorded near and vapor line the wall of the spill bucket. This concentration exceeds the LEL connections during of propane of 2.1%. fueling event During simultaneous fueling of the RUL and diesel tanks, vapors were observed with the FLIR from the P/V Vents. See FLIR0054. Diesel vapors were not recovered by the delivery truck. Since the P/V Vents for the diesel and RUL tanks were clustered together, it was not clear which tank the vapors were attributed to. Vapors were also observed from the PUL vapor recovery spill bucket during and after PUL fueling. Inspectors also observed rusting in the spill bucket. See FLIR0055-0056 and Images 2-4. A concentration of 35,930 ppm as propane, or 3.59%, was 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 6 of 8 recorded with the TVA near the wall of the spill bucket. 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 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 Summary of test results was provided, although test reports had not been provided as of the date of this report. Page 7 of 8 APPENDIX A: Photograph and Video Log File Name Description FLIR0053.mp4 FLIR0054.mp4 FLIR0055.mp4 FLIR0056.mp4 Image 1 (20250626_2019 44362_iOS.heic) Image 2 (20250626_2046 12910_iOS.heic) Image 3 (20250626_2048 20844_iOS.heic) Image 4 (20250626_2048 23050_iOS.heic) Image 5 (20250626_2051 28803_iOS.heic) Image 6 (20250626_2051 32211_iOS.heic) Image 7 (20250626_2051 38472_iOS.heic) Video 8 (20250626_2053 40000_iOS.MOV ) Image 9 (20250626_2053 58823_iOS.heic) Image 10 (20250626_2054 03021_iOS.heic) Image 11 (20250626_2054 04323_iOS.heic) Emissions from the RUL fuel spill bucket during RUL fueling. Movement in the liquid accumulated in the bucket can also be seen. Emissions from the P/V Vents during RUL and diesel tank fueling. Emissions primarily appear to be coming from the P/V Vent further to the back. Emissions from the PUL vapor recovery spill bucket during PUL fueling. Emissions from the PUL vapor recovery spill bucket were observed after PUL fueling was complete and the fuel and vapor hoses had been removed. Although the cap had not been placed back on the vapor recovery pipe, the emissions appeared to be coming from the rim of the spill bucket, consistent with the observations during fueling. Annual Trailer Vapor-Tightness Test Report (EPA Method 27) Trailer 4J8T04221ST103407/257254 for Solar Transport Inc. PUL Vapor recovery spill bucket w/ extensive rusting. PUL Vapor recovery spill bucket w/ extensive rusting. PUL Vapor recovery spill bucket w/ extensive rusting. RUL fueling spill bucket with liquid accumulation in the bucket. RUL fueling spill bucket with liquid accumulation in the bucket. Erosion of the spill bucket appears to be forming on the left side of the bucket in the image. RUL fueling spill bucket with liquid accumulation in the bucket. RUL fueling spill bucket with liquid accumulation in the bucket. Video shows disturbances in the liquid, indicating that the spill bucket may not be vapor tight and vapors from the storage tank are escaping through the spill bucket. (Further supported by high TVA readings). RUL Vapor recovery spill bucket w/ extensive rusting RUL Vapor recovery spill bucket w/ extensive rusting RUL Vapor recovery spill bucket w/ extensive rusting Photographer C. Andrade C. Andrade C. Andrade C. Andrade 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 8