Document bBw2p6nMDVmD37xb87owkq2p0

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_003 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 Circle K Stores, Inc. Circle K #2703291 6135 N Carefree Circle, Colorado Springs, CO, 80922 Chris Andrade Field Inspector Name Inspector and Approval Inspector Title CHRISTOPHE CHRISTOPHER ANDRADE Digitally signed by R ANDRADE -06'00' Date: 2025.09.05 14:04:10 Signature Scott Patefield Name of Approving Official Branch Manager Title Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2025.09.05 11:30:24 -06'00' Signature FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Circle K #2703291 Parent Company Name: AIRS-ID: 041-2195 Primary Facility Representative & Title: Facility Contact Phone/Email: Kyle Kobashi, Environmental Compliance Specialist - Rocky Mountain kyle.kobashi@circlek.com CAA Permit (if any): On-site Facility Representative & Title: Circle K Stores, Inc. Permit Exempt Number 21EP05245S.XP Dee T., Sales Lead Facility Address: 6135 N Carefree Circle, Colorado Springs, CO 80922 Enforcement and Compliance History: None Fuel Delivery Company Company Name: Trucking Circle K Stores, Inc. Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: 43100 Jordan Kingery, Fuel Manager - Rocky Mountain Business Unit jkinger@circlek.com Trailer Identifier: 3416 Driver Name: Eric Holmes Company Address: Fuel Supply 5500 S Quebec St., Suite 100, Greenwood Village, CO 80111 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_003 Inspection Date Katelyn Bergl (EPA) Alyson Skeens (EPA) Chris Andrade (EPA) Arrival/Departure Time 6/26/2025 9:56 AM 10:46 AM 10:00 AM Announced Unannounced Yes No Administrative Inspection Items: CBI Procedures Discussed SBREFA Form Provided Dee T., Sales Lead Other materials or compliance assistance provided (describe): Katelyn Bergl (EPA) See APPENDIX A: Alyson Skeens (EPA) Photograph Range: Photograph and Video Chris Andrade (EPA) 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. 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. Gasoline vapors at concentrations above the lower explosive limit (LEL) of propane were observed from the vapor recovery hose during premium fuel (PUL) fueling. b. Standing water in the PUL vapor recovery spill bucket may have caused a malfunction in the poppet valve sealing mechanism for the vapor recovery pipe adapter. An audible continuous hiss indicated that the valve was not forming a proper seal. During the inspection, the fuel truck driver removed some liquid from the spill bucket readjusted the poppet valve. The hissing sound stopped after this adjustment. 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 10,000 gallons per month and < 100,000 gallons month 100,000 gallons per month per month Based on records provided since 2020, the Date Applicable Throughput Category facility exceeded the 100,000 gallons per month Was Exceeded: throughput threshold on or before January 2020. Records: All Facilities regardless of throughput Notes 5-Year Throughput Records Throughput records for this facility from January 2020 - Available (5-year records must be maintained and made available within 24 hours of request) June 2025 were provided via email by Kyle Kobashi on June 24, 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) Date of Last Test: Date of Last Test: 5/14/2024 5/14/2024 Notes Results of Last Test: Pass Report Provided: Yes Results of Last Test: Pass Report Provided: Yes Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Amount of Fuel 1) 7,000 gallons Delivered: 2) 2,000 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: 2/12/25 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, -0.75 Pass, -1.00 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 Description/Observations (including any OGI or AVO which were observed: observations) Equipment was observed to be capped and covered prior to fueling. Standing liquid was observed in the PUL vapor recovery spill bucket and may have caused a malfunction in the poppet valve sealing mechanism for Conditions of Equipment the vapor recovery pipe adapter. An audible continuous prior to refueling event hiss indicated that the valve was not forming a proper seal. See Img_0294-0295. During the inspection, prior to re-fueling the tanks, the fuel truck driver removed some liquid from the spill bucket and readjusted the poppet valve. The hissing sound stopped after this adjustment. See Img_0296. Standing liquid was also observed in the RUL fuel spill bucket. The vapor recovery hose was first connected to the Connection of fuel and vapor vapor recovery tank and truck header. Next, the fuel lines prior to fuel transfer hose was connected to the fuel pipe of the tank, and finally the fuel hose was connected to the truck header. During fueling of the PUL tank, gasoline vapors were observed with the FLIR and TVA. The vapors were Maintenance of fuel and observed to be coming from the vapor recovery hose, near the interface of the hose and the vapor recovery vapor line connections during elbow. See FLIR0052. The vapors were measured with fueling event the TVA, and a concentration of 33,700 parts per million (ppm) as propane, or 3.37%, was recorded. This concentration exceeds the LEL of propane of 2.1%. Hoses were disconnected in the opposite order for which they were connected. Disconnection of fuel and vapor lines after fuel transfer After disconnecting hoses, a reading of 3,000 ppm as propane was observed at the premium vapor bucket with the TVA. Conditions of Equipment after refueling event Caps and covers were returned after fueling. 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 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 APPENDIX A: Photograph and Video Log File Name Description FLIR0052.mp4 Emissions from the premium vapor line hose Img_0294.heic Img_0295.mov Img_0296.mov PUL Vapor recovery pipe. Spill bucket has accumulated liquid, and the spring mechanism on the poppet cap is malfunctioning, staying in the lowered position without the vapor recovery hose attached and allowing vapors to enter or exit the tank. PUL Vapor recovery pipe. Spill bucket has accumulated liquid, and the spring mechanism on the poppet cap is malfunctioning, staying in the lowered position without the vapor recovery hose attached and allowing vapors to enter or exit the tank. Air intrusion into the pipe is audible in the video. PUL Vapor recovery pipe, after the delivery driver removed some liquid from the spill bucket. He also adjusted the poppet spring to attempt to return it to a sealed position, and the hissing noise was no longer audible. Photographer C. Andrade K. Bergl K. Bergl K. Bergl Page 6 of 6