Document V3Y8N2QEwQne9eKKv2Dy2Gp9N

INSPECTION REPORT 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_0911_01 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): September 11, 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 EG America, LLC / Mini Mart, Inc. d/b/a "Loaf N Jug" ("Loaf N Jug") Loaf N Jug #084 1104 Pueblo Blvd Way Pueblo, CO 81005 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Inspector Title Branch Manager KATELYN BERGL Date: 2024.11.19 17:36:08 -07'00' Digitally signed by KATELYN BERGL Signature Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2024.11.19 16:03:57 -07'00' FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Loaf N Jug #084 AIRS-ID: Primary Facility Representative & Title: Facility Contact Phone/Email: 101-1145 -001 Theodore Bezel, Tanknology Compliance Manager Martin Hilfinger, EG America, LLC. Vice President Environmental Affairs tbezel@tanknology.com Martin.Hilfinger@egamerica.com Parent Company Name: CAA Permit (if any): Loaf N Jug Permit Exempt Number 08PB0753S.XP On-site Facility Benjamin Olivarez, Representative & Title: Assistant Manager On-site Contact N/A Phone/Email: Facility Address: 1104 Pueblo Blvd Way, Pueblo, CO 81005 Enforcement and Compliance History: None Fuel Delivery Company Fuel Supply Company Name: Groendyke Transport Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 8501 Chris Pape Vice President of Safety Cpape@groendyke.com Trucking Company Name (if different): Suncor Energy Trailer Identifier: 14-1338 Driver Name: Thomas Sharp Company Address: Fuel Supply 1833 E Platteville Blvd, Pueblo West, CO 81007 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: General Inspection Information R8_CAA_2024_0911_01 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 12:42 PM Yes No Benjamin Olivarez Administrative Inspection Items: Katelyn Bergl Photograph Range: 9/11/2024 12:40 PM 1:28 PM Announced Unannounced CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): MOV_3533 - 3534; IMG_0072 - 0086 Weather & Other General Site Observations: Mostly sunny, 90 deg F, winds 8 mph SE Inspection Narrative: 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: For gasoline dispensing facilities with gasoline throughput greater than 100,000 gallons per month, Item 1(g) of Table 1 of NESHAP 6C applies: 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. To demonstrate compliance with Item 1(g) of Table 1 of NESHAP 6C, 40 CFR 63.11120(a) requires that a performance test using Test Procedure TP-201.1E is conducted initially and every three years thereafter. The facility most recently conducted a TP-201.1E performance test on June 25, 2024. The test report indicates that the tested component initially failed the negative leak rate and cracking pressure test. The component was replaced and retested the same day as the initial test and subsequently passed the performance test. The initial failing results Page 3 of 6 indicate that the facility may not have been continuously complying with Item 1(g) of Table 1 of NESHAP 6C. 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 10,000 gallons per month and < 100,000 gallons month 100,000 gallons per month per month Based on records provided since 2019, the Date Applicable Throughput Category facility exceeded the 100,000 gallons per month Was Exceeded: throughput threshold on or before October 2019. Records: All Facilities regardless of throughput Notes 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Throughput records for this facility from October 2019 - September 2024 were provided via email by Theodore Bezel on September 11, 2024. Last 12-month rolling throughput calculation available 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) Provided along with 5-year throughput records Notes Date of Last Test: 6/25/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No The report indicates that the component initially failed the negative leak rate and cracking pressure test. The component was replaced and retested the same day as the initial test and subsequently passed the performance test. This performance test was conducted within the past three years. Date of Last Test: 5/22/2024 Results of Last Test: Pass / Fail Report Provided: Yes / No Report indicates passing performance test. This performance test was conducted within the past three years. Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Amount of Fuel Delivered: 1) 3,000 gallons 2) 1,000 gallons Annual Certification Test - Vapor Tightness Testing - EPA Method 27 of appendix A-8 to part 60 of CAA Date of Last 04/01/2024 Test: 5-Year Test Record Availability: Available with truck Available at office or central loc. Page 4 of 6 Results of Test: Pass Not Available Other: Fuel Delivery Event Observation: A fuel delivery event was observed by the EPA inspector. The inspector used a forward-looking 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 Description/Observations (including any OGI or AVO activity which were observed: observations) Vapors visible from regular unleaded (RUL) fueling spill Conditions of Equipment bucket prior to cap removal or fueling. Liquid was visible in prior to refueling event the spill bucket prior to fueling and could have been the source of vapors. Connection of fuel and vapor lines prior to fuel transfer Maintenance of fuel and A small amount of vapors was observed from RUL fueling vapor line connections spill bucket during RUL fueling. These vapors could have during fueling event come from leftover liquid/gasoline in the spill bucket present prior to fueling. Disconnection of fuel and vapor lines after fuel transfer Conditions of Equipment after 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) APPENDIX A: Photograph and Video Log Notes/Comments Page 5 of 6 File Name Description MOV_3533.mp4 MOV_3534.mp4 IMG_0072.JPG IMG_0074.JPG IMG_0075.JPG IMG_0076.JPG IMG_0077.JPG IMG_0078.JPG IMG_0079.JPG IMG_0080.JPG IMG_0081.JPG IMG_0082.JPG IMG_0083.JPG IMG_0084.JPG IMG_0085.JPG IMG_0086.JPG Vapors visible from RUL fueling spill bucket prior to cap removal or fueling. Liquid was visible in the spill bucket prior to fueling and could have been the source of vapors. Small amount of vapors observed from RUL fueling spill bucket during RUL fueling. Possibly from leftover liquid/gasoline in the spill bucket present prior to fueling. Vapor vent stacks for the RUL, premium, and diesel storage tanks located on top of the canopy structure, as well as the general refueling area. Regular unleaded (RUL) and premium fuel tank fill and vapor recovery equipment. Regular unleaded (RUL), premium, and diesel fuel tank fill and vapor recovery equipment. Regular unleaded (RUL) fuel tank fill and vapor recovery equipment. Premium tank fill and vapor recovery equipment. Diesel tank fill and vapor recovery equipment. General refueling area prior to fuel delivery. General refueling area prior to fuel delivery. Fuel truck fuel delivery header system. Fuel truck: Trailer identifier Fuel truck: Truck identifier EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. EPA Method 27 Certificate for truck. Photographe r K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 6 of 6