Document dDaEXKGd85B7LReMMQJmyEwYR
U.S. Environmental Protection Agency
Region 7 11201 Renner Blvd., Lenexa, KS 66219
Date:
NOTICE OF INSPECTION
Resource Conservation and Recovery Act (RCRA) Public Law 94-580, as amended.
Subtitle I Underground Storage Tanks
3-1-23
Inspector: Joe Heafner Brian D'Alfonso
Facility Name: Indian Country Mini Mart
Agency Facility ID# EPA-TrUSTD-2320
Street Address: 20330 US HWY 75
Facility Representative(s): [sign and date] See Original
City: Holton
State: KS
Zip Code: 66436
Reason for Inspection: __Scheduled_________ Entry by
Consent (X)
Warrant ( )
To determine the extent of compliance with the above referenced law, which may require the collection
of samples, documents and/or photographs.
Other (Specify)__________________________________________________________________________
Does EPA have access to this facility for the inspection? Yes (X) No ( )
Name and title of person granting access___ ______________________________________
Facility
Compliance Documents Received Log
Document Description, e.g., ATG tapes, CP tests, SIR reports, Line tests, etc.
Representative Initials
ATG Tapes Photos
See Original
See Original
The facts established by this inspection will be reviewed by personnel in the EPA Regional Office. A
final determination of your facility's compliance with the EPA regulations will be made as a result of this review. The review may reveal additional deficiencies.
Signature of Inspector:
JOSEPH HEAFNER
Digitally signed by JOSEPH HEAFNER Date: 2023.04.14 06:03:22 -05'00'
Date:
ECAD RCRA Section Chief:
Digitally signed by AMBER
AMBER WHISNANT WHISNANT
Date: 2023.04.21 11:29:22 -05'00'
Date:
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 1 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
Agency Fac. ID: EPA-TrUSTd-2320
REPORT OF OPENING AND CLOSING CONFERENCES
Opening Conference
1. Give time of and list attendees of Opening Conference: Joe Heafner, Brian D'Alfonso ____
________________Carla Nissen______________________________
_ ____________________________________________________________________________
Circle Yes or No
2. Were UST Inspection Credentials presented?
Yes No
3. Was the statutory and regulatory purpose of the inspection explained?
4. Were areas of the facility being inspected noted?
5. Was a list of records being reviewed provided?
6. Was an opportunity given to claim confidential business information (CBI)?
7. Was the approximate duration of the inspection noted?
8. Were operators at the facility notified they have the opportunity to fix areas of concern identified during the inspection?
9. Was equipment used during the inspection noted?
Yes No Yes No Yes No Yes No Yes No Yes No Yes No
Closing Conference
1. Give time of and list attendees of Closing Conference:_Joe Heafner, Brian D'Alfonso____
___________Carla Nissen_________________________
____________________________________________________________________________
Circle Yes or No
2. Was the purpose of the inspection restated?
Yes No
3. Was what happens with photos taken during the inspection explained?
4. Were areas of concern and inspection observations discussed? Note: Compliance is the responsibility of the operators and any potential deficiencies or areas of concern are not the final determination of compliance.
Yes No Yes No
5. Was EPA's right to bring an enforcement action pending review explained? 6. Were any "fixed" deficiencies or areas of concern noted in the report?
Yes No Yes No
7. Were photos and copies of documents itemized on the report? 8. Was the time frame for receiving the completed report given? 9. Was the Small Business Resources Information Sheet provided?
Yes No Yes No Yes No
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 2 of 24 Pages
Initial/Date:JAH 3/1/23__
1 UST Inspection Checklist
I. Ownership of Tank(s)
Tribal
Agency Fac. ID: EPA-TrUSTd-2320
II. Location of Tank(s) same as owner location (I.)
Owner Name:
Carla Nissen
_____________________________________________________________
Street Address
20330 US HWY 75
______________________________________________________________
County
Jackson
______________________________________________________________
City
State
Zip Code
Holton
KS
66436
______________________________________________________________
Phone Number
785-364-4223
______________________________________________________________
Owner Contact Person
Carla Nissen
______________________________________________________________
Do you own UST(s) at other UST Facilities Yes/No
If Yes, how many facilities______________ How many USTs____ __________________
Facility Name or Company Site identifier, as applicable
Indian Country Mini Mart
___________________________________________________________
Street Address or State Road, as applicable
20330 US HWY 75
___________________________________________________________
County
Jackson
___________________________________________________________
City (nearest)
State
Zip Code
Holton
KS
66436
___________________________________________________________
Contact Person(s) at Facility
Phone Number
Carla Nissen
785-364-4223
___________________________________________________________
Latitude
Longitude
39.145167
-95.747322
___________________________________________________________
Datum
WGS 84
___________________________________________________________
ICIS/FERS Number:
Date entered:
___________________________________________________________
III. Notification (280.22)
Notification to implementing agency; name _________________________[280.22(a)]
Agency Facility ID # _EPA-TrUSTD-2320 ___; Agency notified? Y N Unknown NA [280.22(b)]
Has ownership changed in previous 30 days?
Y N Unknown NA [280.22(b)]
Have substances stored changed in the USTs?
Y N Unknown NA [280.22(b)]
Do newly stored substances include blends greater than E10 or B20? Y N Unknown NA [280.32(b)]
IV. Financial Responsibility (280.93)
Is documentation of financial responsibility available?
Y N Unknown NA
Does Wording Follows 40 CFR 280 Subpart B
Y N Unknown NA
Does FR mechanism cover cleanup of releases from USTs?
Y N Unknown NA
Does FR mechanism cover damage to property and third party liability caused by releases from USTs? Y N Unknown NA
Is amount of FR coverage adequate based on number of facilities?
Y N Unknown NA
$1,000,000 for less than 200 facilities
$2,000,000 for more than 200 facilities
Is amount of FR coverage adequate based on monthly throughput? $1,000,000 if through put greater than 100,000 gallons $50,000 if throughput less than 100,000 gallons
Y N Unknown NA
Does the FR mechanism list the covered facilities as registered by EPA on the Declaration Page? Y N Unknown NA
Does the FR mechanism provide first dollar coverage without self-insured retention?
Y N Unknown NA
Specific Financial Mechanism used - check below:
State Fund _____ Private Insurance: Insurer/Policy #__FEI-LST-25063-04 Expires 6/7/23
Guarantee Surety Bond Letter of Credit Self Insured
Local Government Not Required (Federal & State government, hazardous substance USTs)
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 3 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
Agency Fac. ID: EPA-TrUSTd-2320
V. Operator Training (280.240) [List names, certificate numbers, expiration dates, trainer, and state]
A Operator(s): Carla Nissen, Cert. No A/B 00006243 TMS-Kansas 12/6/2018
__________________________________________________________________________________________
B Operators(s): Carla Nissen, Cert. NO A/B 00006243, TMS-Kansas 12/6/18
__________________________________________________________________________________________
C Operators(s): Debbie Nissen 12/6/2018____________________________________________
Does the owner have a list of designated operators currently trained at each facility?
Y N Unknown NA
Does the owner have evidence of operator training or retraining?
Y N Unknown NA
Were any of the designated UST Operators on duty during the inspection?
Y N Unknown NA
VI. Proximity of Groundwater Wells and Release History
Drinking water wells within 1,500 feet of the tank basin; is so note how many and list what types:
Two domestic or wells required water rights were within 1,500 feet of the tank basin
Evidence of release or spills at facility Greater than 25 gallons (estimate)
Releases reported to implementing agency; if so, date(s)
[280.53]
Release confirmed; when and how
Initial abatement measures and site characterization Free product removal
Soil or ground water contamination Corrective action plan submitted
Remediation ongoing
Remediation completed, no further action;date(s)
Unknown
VII. Tank Information (give numbers)
Tank 6
Tank presently in use
Yes
If not, date last used If empty, verify 1" or less left
(see Section IX.) (see Section IX.)
Most recent M/Y tank installed/upgraded (mm/dd/yr) 1/1/2007
Material of Construction: steel, impressed current, sacrificial anodes, composite, FRP,, internal lining, excavation liner single-walled (SW), double-walled (DW)
Capacity of Tank (gal) Substance Stored
E-15, E85 labeling correct? Are Compatibility Records available? [280.34(b)(3)] Is compatibility demonstrated? [280.32(b)(1) and (2)]
Yes No NA UNK Yes No NA UNK
Yes No NA UNK
Contained Submersible Turbine Pump (STP) Sumps Yes No NA UNK If yes, give installation date___________________
Is STP used for release detection? Yes No NA UNK
FRP, SW
6000 Dyed Diesel
NA NA
NA
NA
Is STP double-walled?
Yes No NA UNK
If Double-Walled (DW), Date of Last Monthly Integrity
Check of Annular Space? [280.35(a)(1)(i)] Note: only
NA
applies to interstitial spaces under pressure or vacuum
or filled with brine.
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 4 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
VII. Tank Information (give numbers)
Contained Submersible Turbine Pump (STP) Sumps If DW, are the last 12 months of records available? Yes No NA UNK
Tank 6 NA
Agency Fac. ID: EPA-TrUSTd-2320
If non-DW, Date of Last 3-year Containment Integrity
Test? [280.35(a)(1)(ii)] Note: Triennial Sump Testing is
NA
required if sumps installed on or after April, 11, 2016.
Special Configuration
Manifolded/Compartmentalized - Describe using tank
NA
numbers
Field-Constructed/Airport Hydrant System FC or AHS
NA
VIII. Piping Information
Piping type
Pressurized
X
Suction
Piping Material: steel, copper, impressed current, sacrificial anodes, FRP, flexible nonmetallic single-walled (SW), double-walled (DW) Under Dispenser Containment (UDC) Yes No NA UNK If yes, give installation date___________________
Is UDC used for release detection? Yes No NA UNK
Flexible DW
Nonmetal
NA
NA
Is UDC double-walled?
Yes No NA UNK
If DW, Date of Last Monthly Integrity Check of Annular
NA
Space?[280.35(a)(1)(i)] Note: only applies to interstitial
spaces under pressure or vacuum or filled with brine.
If DW, are the last 12 months of records available?
NA
Yes No NA UNK
If non-DW, Date of Last 3-Year Containment Integrity
Test? [280.35(a)(1)(ii)] Note: Triennial Sump Testing is
NA
required if sumps installed on or after April, 11, 2016.
Tank or piping properly designed and constructed according to a code of practice developed by a nationally recognized association or
independent testing laboratory [280.20(a), 280.20(b)] Y N Unknown NA
IX. Repairs
NA
Repairs are conducted according to a code of practice [280.33(a)] Y N Unknown NA
Metal piping sections/fittings that are damaged and have released product are replaced manufacturer's specifications. Non-corrodible pipes and fittings may be repaired in accordance with the manufacturer's specifications.
[280.33(c)] Y N Unknown NA
Repairs to secondary containment areas of tanks, piping, and containment sumps are tightness tested within 30 days of repair completion. All other repairs to tanks and piping are tightness tested within 30 days of repair completion (except when internal inspection conducted or
monthly monitoring is conducted) [280.33(d)] Y N Unknown NA
CP systems are tested/inspected within 6 months of repair of any cathodically protected UST system [280.33(e)]
Y N Unknown NA
Internal linings repaired following standard code or practice [Citation needed] Y N Unknown NA
Repaired spill or overfill prevention equipment are tested or inspected within 30 days, as appropriate, in accordance with 280.35 to ensure
it is operating properly. [280.33(f)] Y N Unknown NA
Records of repairs are maintained [280.33(g)] Y N Unknown NA
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 5 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
X. Temporary Closure NA CP is continued to be maintained [280.70(a)] Y N Unknown NA
Agency Fac. ID: EPA-TrUSTd-2320
Release detection is being performed and UST system contains > 1 inch of product [280.70(a)] Y N Unknown NA
Vent lines left open and functioning [280.70(b)] Y N Unknown NA
Lines, pumps, manways, and ancillary equipment capped and secured [280.70(b)] Y N Unknown NA XI. Corrosion Protection (CP)
Tank and piping components are constructed of or jacketed with non-corrodible materials, e.g., FRP, dielectric coatings,
plastic, etc. [280.20(a)(1), 280.20(a)(3), [280.20(b)(1)] Circle one or both: Tanks Pipes Y N Unknown NA
Implementing agency has determined that tank and piping construction and corrosion protection are designed to prevent releases in a manner
that is no less protective of human health and environment [280.20(a)(5), 280.20(b)(4)] Y N Unknown NA
Owners and operators have maintained records by corrosion expert to document that CP is not necessary [280.20(a)(4)(ii), 280.20(b)(3)(ii)]
Y N Unknown NA
Steel tank or piping coated with suitable dielectric material and cathodically protected [280.20(a)(2)(i), 280.20(b)(2)(i)]
Y N Unknown NA
Field-installed CP system designed by a corrosion expert [280.20(a)(2)(ii), 280.20(b)(2)(ii) Y N Unknown NA
CP system tested and documentation maintained every three years or a time frame established by implementing agency [280.31(b)(1),
280.31(d)(2)] Y N Unknown NA
Criteria used to determine that CP is adequate was in accordance with a standard code of practice developed by a nationally recognized
association [280.31(b)(2)] Y N Unknown NA
CP system did not meet acceptable criteria at last test and action was taken by owner/operator to correct problem [280.31(b)(2)]
Y N Unknown NA
Metal components in sumps NA
Tank numbers: Tank 6
Are the metal components at the tank and dispenser isolated (e.g. booted),
Yes
cathodically protected or isolated? [280.20(b)(4)] Yes No NA UNK
Notes:
Metal components are booted and isolated.
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 6 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
XI. Corrosion Protection (CP) Tank numTank 6
Lining: [280.21(b)(1)]
NA
Periodic lining inspection requirements for tank
met [280.21(b)(1)(ii)]
Yes
No NA UNK
[10 years after installation, every five years
thereafter]
Documentation that lining was installed [280.21 (b)
(1) (i)] Yes No NA UNK Shell integrity tested and passed? NA UNK
Yes No
Internal inspection test result - Pass or Fail
If Fail, is tank still in service? [280.21(b)(1)(ii)] Yes No NA UNK
Agency Fac. ID: EPA-TrUSTd-2320
Sacrificial Anode:
NA
CP system operated and maintained continuously. [28 Yes No NA UNK
Tested Six Months after repair
Last 3 yr test results show a voltage of at least -850mV [280.31(b)(2)] Yes No Dates of last two 3 yr test results available? [280.31(d)(2)] Yes No
Every Three Years after installation [280.31(b)(1)]
List Dates:
Impressed Current:
NA
Is the Rectifier on a dedicated power circuit? Yes No NA UNK CP system operated and maintained continuously. [28 Yes No NA UNK
Tested Six Months after repair
Last 3 yr test results show a voltage of at least -850mV 100 mv shift [280.31(b)(2)] Yes No NA UNK CP inspected and rectifier log maintained every 60 days to ensure equipment is running properly. Last three test results available? [280.31(d)(1)] Yes No NA UNK Dates of last two 3 yr test results available? [280.31(d)(2)] Yes No
Every Three Years after installation [280.31(b)(1)]
List Dates:
Notes:
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 7 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian County Mini Mart
Agency Fac. ID: EPA-TrUSTd-2320
XII. Spill and Overfill Protection [280.21(d)] Indicate any USTs filled by transfers < 25 gallons For transfers greater than 25 gallons
Spill Prevention
Tank numbers: Tank 6
Device is present and functional? [280.20(c)(1)(i)] Yes No NA UNK Spill bucket free of water, debris, etc. Yes No NA UNK Double walled? Yes No NA UNK Note: only applies to interstitial spaces under pressure or vacuum or filled with brine.
YES NO
NA
If Yes, Last Monthly Check? [280.35(a)(1)(i)] List date:
If No, Date of Last Triennial Containment Integrity Test [280.35(a)(1)(ii)] List date:
NA 4/8/2021
Overfill Prevention
Device is present and operational? [280.20(c)(1)(ii)] Yes No NA UNK Date of Last Triennial Inspection? [280.35(a)(2)]
YES 4/8/21
Ball float valve riser present:
[280.20(c)(1)(ii)(B) Yes No NA UNK Ball float valves are not suitable on suction systems,
YES
with coaxial drop tubes, or pressurized deliveries.
Ball float valve installed or replaced after October 13, 2015? [280.20(c)(3)] Yes No NA UNK NA
Flapper valve Operational: [280.20(c)(1)(ii)(B)] NA Yes No NA UNK
Automatic shutoff: Operational: [280.20(c)(1)(ii)(A)] NA Yes No NA UNK
Automatic shutoff: Operational: [280.20(c)(1)(ii)(A)] NA Yes No NA UNK
Alarms Operational: [ 280.20(c)(1)(ii)(B)] NA Yes No NA UNK
Visible and/or audible to jobber/driver? NA Yes No NA UNK
Location(s) of overfill alarm(s): South of Tank, North side of Building
Failure to take necessary precautions to prevent a spill or overfill during product delivery [280.30(a)] Y N Unknown NA
XIII. Tank and Pipe Release Detection
Release detection present [280.40(a)] Y N Unknown NA Note: Emergency Generator Tanks installed on or before 10/13/2015
must have release detection by 10/13/2018. Emergency Generator Tanks installed after 10/13/2015 but before 4/11/2016 must have release detection installed during installation. Emergency Generator Tanks installed after 4/11/2016 must have secondary containment and use interstitial monitoring.
Release detection system operating properly (i.e., system must be able to detect a release from any portion of the tank and piping that
routinely contains product) [(280.40(a)(1)] Y N Unknown NA
Release detection system meets the performance requirements at 280.43 or 280.44 [(280.40(a)(3)] Y N Unknown NA
Implementing agency has been notified of a suspected release as required, or when a release detection method or device alarms or fails a test
[(280.40(b)] Y N Unknown NA
Tanks and piping are monitored monthly for releases and records available (must have records for the two most recent consecutive months
and for 10 months of the last 12 months). [280.41(a), and 280.45(b)] Y N Unknown NA
Meets performance requirements for tank and line tightness test and maintains records.[280.43(c), 280.44(b), and 280.45(b)]
Y N Unknown NA
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Page 8 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
Agency Fac. ID: EPA-TrUSTd-2320
XIII. Tank and Pipe Release Detection
Hazardous Substance UST Systems: NA
Release detection requirements are complied with for UST systems containing product. [(280.42)(b)]
Tanks and all piping systems equipped with secondary containment Pressurized piping w/ ALLD Monitored for a release every 30 days
Y N Unknown NA Y N Unknown NA
Y N Unknown NA
Pressurized Piping Set 1
TWO METHODS MUST BE SELECTED; ONE FROM EACH SET.
Tank numbers: Tank 6
Automatic Line Leak Detector (ALLD) installed (give date last tested/checked) Yes No NA UNK 4/12/2022
Annual function test of the operation of the leak detector within last 12 months [280.44(a)] Yes No NA UNK * In accordance with the manufacturer's requirements
YES YES
Does the owner/operator have ALLD function tests available
for the last 3 years? Yes No NA UNK
Operating so as to alert the operator to the presence of a leak
(see 280.44(a) for description of ALLD) [280.44(a)]
Yes No NA UNK
Is the ALLD appropriate for the fuel stored in the UST?
Yes No NA UNK
Automatic Shut-off Device
(Electronic line leak detector (ELLD))
NA
Continuous Alarm System (sump sensor/double-walled piping) Must meet leak threshold for large and small releases.
NA
Set 2
Tank numbers:
NO YES YES
Tank 6
Annual Line Tightness Testing -- give date 4/12/2022 Is the last Line Tightness Test within the last 12 months? Yes No NA UNK Does the owner/operator have line tightness test reports available for the last 3 years? Yes No NA UNK Secondary Containment with Interstitial Monitoring Yes No NA UNK Other (SIR, etc.) Yes No NA UNK
Suction Piping
Line Tightness Testing (required every 3 yr) Yes No NA UNK
YES NO NA NA
NA
Indicate date of most recent test Secondary Containment with Interstitial Monitoring Yes No NA UNK NA Other (SIR, etc.) Yes No NA UNK NA No Leak Detection Required (must answer yes to all of the following questions):
Operates at less than atmospheric pressure Yes No NA UNK NA Has only one check valve which is located directly under pump NA (dispenser) Yes No NA UNK Slope of piping allows product to drain back into tank when NA suction released Yes No NA UNK
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 9 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
Agency Fac. ID: EPA-TrUSTd-2320
XIII. Tank and Pipe Release Detection
Tank Numbers: Tank 6
Under Dispenser Containment (UDC)
List dates installed
NA
Note: Triennial Sump Testing required if sump installed
on or after April 11, 2016.
Are UDC Monitored? NA Yes No NA UNK
How are UDC Monitored? Visual or Electronic
Are records of inspections available? Yes No NA UNK NA
UDC Monitoring Notes: (Records of release: State the past 12 months monitoring records)
Tank Release Detection Summary
Mark Tank numbers with an "X"
Automatic Tank Gauging (ATG)
Automatic Line Monitoring (ALM)
(refer to appropriate detailed RD form) Pages 13-18 x
Interstitial Monitoring (IM)
Statistical Inventory Reconciliation (SIR)
Manual Tank Gauging (MTG)
XIV. Walkthrough Inspections [ 280.36 - Subpart C]
Owner and operators must conduct walkthrough inspections of the following: Must have records for inspections performed every 30 days
Y N Unknown NA
Date of last 30-day Walkthrough Inspection_______12/2022_____________________
Spill Prevention Equipment - must be checked for damage, remove liquid or debris, and check
Y N Unknown NA
fill cap. [If deliveries occur at intervals greater than every 30 days, spill prevention equipment
can be checked at the time of delivery]
DW spill prevention equipment with interstitial monitoring - must check for leak in interstitial area. [Only applies to DW spill prevention equipment with vacuum, pressurized or brine-filled interstitial spaces]
Y N Unknown NA
Release detection equipment - must check to ensure operating with no alarms and review records of of release detection testing.
Y N Unknown NA
Do the 30-day walkthrough inspections follow a nationally recognized standard code or practice?
Y N Unknown NA
Are records of 30-day walkthrough inspections available for the two most recent consecutive months and for 10 of the last 12 months?
Y N Unknown NA
Must have records for inspections performed each year
Date of last Annual Walkthrough Inspection____4/12/2022________
Containment sumps - must check for damage, leaks, remove liquid or debris. DW sumps with interstitial monitoring - must be checked for leak in interstitial area.
Hand-held release detection equipment - must check tank gauge sticks or groundwater bailer.
Does the annual walkthrough inspection follow a nationally recognizes standard code or practice?
Y N Unknown NA
Y N Unknown NA Y N Unknown NA Y N Unknown NA Y N Unknown NA
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Page 10 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart SITE DRAWING
DATE: 3-1-23 WEATHER:
TIME ON SITE: 09:30
ENVIRONMENTALLY SENSITIVE AREA : Y N
If "Yes", please describe:
Agency Fac. ID: EPA-TrUSTd-2320
TIME OFF SITE: 11:00
ATG Probe
STP Sump and ball float
Spill Bucket
Dyed Diesel Dispenser
Diesel and Gasoline Dispensers
Tank 6 (Dyed Diesel) 6K UST
All other diesel (north) and all gasoline (south) served by ASTs to the east.
ASTs
Pictures
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 11 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart NOTES: No additional notes
Agency Fac. ID: EPA-TrUSTd-2320
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 12 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
Automatic Tank Gauging (ATG) NA
Agency Fac. ID: EPA-TrUSTed-2320
Manufacturer, name and model number of system: Veeder-Root TLS-350
Third-party evaluators: Midwest Research Institute, Ken Wilcox Associates
Unknown
NOTE: Most ATGs are not certified for use with used/waste oil tanks
ATG checking portion of tank that routinely contains product [280.40(a)(1)]
Yes No
Device documentation is available at site (e.g., manufacturer's brochures, owners' manual, third-party certification)
Yes No
Checked for presence of monitoring box and evidence that device is working.
Yes No
Checked documentation that system installed, calibrated, & maintained according to manufacturer's instructions [280.40(a)(2)] ATG must be set for 0.2 gal/hr minimum
Yes No
Monitoring (includes inventory) and testing records are available for the past 12 months
Year
Month
Tank #1
Tank #2
Tank #3
2023
January
No Test
Tank #4
Tank #5
Yes No
Tank #6
2023
February 28
Pass
2022
March 25
Pass
2022
April 29
Pass
2022
May 27
Pass
2022
June 1
Pass
2022
July 3
Pass
2022
August 21
Pass
2022
September 9
Pass
2022
October 29
Pass
2022
November 1
Pass
2022
December 23
Pass
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)]
NA Yes No
Annual Release Detection Operability
Test Date: ____4/8/21____
1. Automatic tank gauge and other controllers: test alarm; verify system configuration; test battery backup.
2. Probes and sensors: inspect for residual buildup; ensure floats move freely; ensure shaft is not damaged; ensure accessible cables are free of kinks and breaks; test alarm operability and communication with controller.
3. Does the owner/operator have operability test records for the last three years?
Y N Unknown NA Y N Unknown NA
Y N Unknown NA
x Test was performed on April 12, 2022 (Received after the completion of the inspection)
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 13 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart Automatic Line Monitoring (ALM) NA
Manufacturer, name and model number of system:
Third-party evaluators:
Agency Fac. ID: EPA-TrUSTd-2320
Unknown
ALM checking portion of piping that routinely contains product [280.40(a)(1)]
Device documentation is available at site (e.g., manufacturer's brochures, owners' manual, third-party certification)
Checked for presence of monitoring box and evidence that device is working.
Checked documentation that system installed, calibrated, & maintained according to manufacturer's instructions [280.40(a)(2)] ALM must be set for 0.2 gal/hr minimum
Monitoring (includes inventory) and testing records are available for the past 12 months
Year
Month
Tank #2
January
February
Yes No Yes No Yes No Yes No
Yes No
March April May June July August September October November December
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)]
NA
Annual Function Test
Test Date: ____________
Yes No
1. Automatic tank gauge and other controllers: test alarm; verify system configuration; Y N Unknown NA
test battery backup.
2. ALM units: ensure accessible cables are free of kinks and breaks; test alarm operability and communication with controller.
Y N Unknown NA
3. Does the owner/operator have function test records for the last three years?
Y N Unknown NA
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Page 14 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart Interstitial Monitoring for: Piping / Tank(s) NA
Agency Fac. ID:EPA-TrUSTd-2320
Manufacturer and name of system:
Date system installed:
Materials used for secondary containment:
Materials used for internal lining:
Interstitial space is monitored (Circle one): automatically, continuously, or on a monthly basis.
If tank is of double-walled construction, what is material of construction?
FRP
If piping is of double-walled construction, what is material of construction? FRP
Documentation of monthly readings is available for last 12 months.
Year
Month
Tank Pipe
#1
#1
January
February
March
April
May
June
July
August
September
October
November
December
Yes No NA
Monitoring method is documented as capable of detecting a leak as small as .1 gal/hr with at least a 95% probability of detection and a probability of false alarm of no more than 5%.
Yes No NA
System is designed to detect release from any portion of UST system that routinely contains product.
Yes No NA
Secondary containment tight as to direct a release to the monitoring point and permit its detection [280.43(g)(2)] Yes No NA
Sensor is positioned correctly and operating in accordance with manufacturer's instructions [280.40(a)(2)]
Yes No NA
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)]
Yes No NA
Annual Release Detection Operability
Test Date: ___ _________
1. Vacuum pumps and pressure gauges to ensure proper communication with sensors Y N Unknown NA
and controller.
2. Sensors: ensure floats move freely; ensure accessible cables are free of kinks and breaks; test alarm operability and communication with controller.
Y N Unknown NA
3. Does the owner/operator have operability test records for the last three years?
x
Y N Unknown NA
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 15 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart
Agency Fac. ID: EPA-TrUSTd-2320
Inventory Control [for Compliance Assistance Purposes only] NA
Inventory Control data input: ATG Manual tank gauging (stick)
Leak Check Calculation is performed each month to detect a release of 1.0 percent of flow-through plus 130 gallons. [280.43(a)]
Inventory volume measurements for regulated substance inputs, withdrawals, and the amount still remaining in the tank are recorded each operating day. [280.43(a)(1)]
The equipment used is capable of measuring the level of product over the full range of the tank's height to the nearest oneeighth of an inch. [280.43(a)(2)]
The regulated substance inputs are reconciled with delivery receipts by measurement of the tank inventory volume before and after delivery. [280.43(a)(3)] Deliveries are made through a drop tube that extends to within one foot of the tank bottom. [280.43(a)(4)]
Product dispensing is metered and recorded within the local standards for meter calibration or an accuracy of 6 cubic inches for every 5 gallons of product withdrawn. [280.43(a)(5)]
The measurement of any water level in the bottom of the tank is made to the nearest one-eighth of an inch at least once a month. [280.43(a)(6)]
Inventory Control Records are available for the past 12 months
Operator or owner has access to correct tank charts to convert inches to gallons.
Leak Check Calculation Results: P = PASS
Year
Month
F = FAIL N=None
Tank #1
Tank #2
Tank #3
Tank #4 Tank #5
January
February
March
April
May
June
July
August
September
October
November
December
Yes No Yes No
Yes No Yes No Yes No Yes No Yes No Yes No Yes No
Tank #6
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)] Notes:
NA
Yes No
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 16 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart Statistical Inventory Reconciliation (SIR) NA
Agency Fac. ID: EPA-TrUSTd-2320
Designer/Manufacturer and name of program:
SIR Service Provider:
Third-party evaluators:
SIR data input: ATG
* Manual tank gauging (stick) (Must follow the requirements for inventory control)
* Monthly water level readings recorded, drop tubes present, meters calibrated, and the dipstick is marked legibly and product levels can be measured to the nearest 1/8 inch
Yes No
SIR documentation is available at site (e.g., designer's brochures, owners' manual)
Yes No
Owner/Operator has documentation on file verifying method meets minimum performance standards of 0.20 gph with Pd 95% and
Pfa of 5% for statistical inventory reconciliation (e.g., results sheets under EPA's "Standard Test Procedures for Evaluating Leak
Yes No
Detection Methods").
SIR results are available for the past 12 months
Yes No
SIR Test Results: P = PASS Year
F = FAIL Month
INC = Inconclusive
N=None
Tank #1
Tank #2
Tank #3
Tank #4 Tank #5 Tank #6
January
February
March
April
May
June
July
August
September
October
November
December
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)] Receiving results within a time frame established by implementing agency [280.41(a) & 280.43(h)]
NA
Yes No Yes No
Annual Release Detection Operability
Test Date: _____________
1. If ATG used for data input, refer to page 12 for annual testing requirements.
2. If tank measuring stick used for data input: Hand-held sampling equipment (gauging Y N Unknown NA
sticks, etc.) to ensure proper operation.
3. Does the owner/operator have operability test records for the last three years?
Y N Unknown NA
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 17 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart Manual Tank Gauging (MTG) NA
Agency Fac. ID: EPA-TrUSTd-2320
Manual tank gauging may be used as the sole method of leak detection only for tanks of 1,000 gal or less, or in combination with tank tightness testing for tanks 2,000 gal. or less. * Manual tank gauging must be used in combination with tank tightness testing for tanks over 1,000 gal.
Records show liquid level measurements are taken at beginning and ending of period of at least 36 hours during which no liquid is added to or removed from the tank. [280.43(b)(1)]
Yes No
Level measurements based on aver. of two consecutive stick readings at both beginning and end of period.
Yes No
Monthly average of variation between beginning and end measurements is less than standard shown below for corresponding size and dimensions of tank and waiting time.
Yes No
Gauge stick is long enough to reach bottom of the tank. Ends of gauge stick are flat and not worn down. [280.43(b)(3)] Yes No
Gauge stick is marked legibly and product level can be determined to the nearest 1/8 inch [280.43(b)(3)]
Yes No
MTG is used as sole method of leak detection for tank.
Yes No
MTG is used in conjunction with tank tightness testing.
Yes No
Are all tanks for which MTG is used 2,000 gal or less in capacity? [280.43(b)(5)]
Yes No
Operator or owner has access to correct tank charts to convert inches to gallons.
Yes No
Check One:
Nominal Tank Capacity (gal)
Tank Dimensions
Monthly Standard (gal) Minimum Test Duration
( ) ( ) ( ) ( ) ( ) Year
Month JAN FEB MAR APR MAY JUN
Tank #1
550
551 - 1,000
1,000
1,000
1,001 - 2,000*
Tank #2
Tank #3
Tank #4
Tank #5
NA
NA
64" diam. X 73" length
48" diam. X 128" length
NA
Tank #6
Year
Month JUL
AUG
SEP
OCT
NOV
DEC
Tank #1
5
7
4
6
13 Tank
#2
Tank #3
36 hr 36 hr 44 hr 58 hr
Tank #4
Tank #5
Tank #6
Are monitoring records available for the last 12 month period? Performing proper recording and reconciliation activities [280.43(b)(4)] Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)]
NA
Yes No Yes No Yes No
Annual Release Detection Operability 1. Hand-held sampling equipment (gauging sticks, etc.) to ensure proper operation.
Date: _____________
Y N Unknown NA
2. Does the owner/operator have operability test records for the last three years?
Y N Unknown NA
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 18 of 24 Pages
Initial/Date:JAH 3/1/23__
2 Underground Storage Tank (UST) Inspector's Observation Report
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (EPA) REGION 7
Tanks, Toxics, and Pesticides Branch
LCRD/TTPB 11201 Renner BLVD
Lenexa, Kansas 66219
913-551-7216
Facility Name: Indian Country Mini Mart
Agency Fac. ID _EPA-TrUSTd-2320__
No areas of concern or deficiencies were observed at the conclusion of this inspection.
The above named facility was inspected by a duly authorized representative of EPA Region 7, and the following are the inspector's
observations and/or recommended corrective action(s):
Deficiencies or Areas of Concern Identified:
Regulatory Citation
Description
280.44a
No function test for the ALDD in past 12 months (test performed on 4/12/22)
280.36
No annual walk-through for 2022 (Received after inspection 4/12/22)
280.40 (a)(3)
No annual operability test for past 12 months (test performed on 4/12/22)
280.44
No line tightness test in past 12 months (test performed on 4/12/22)
280.45(b)(1)
Failure to maintain 3 years of line leak detector function test documentation
Actions Taken:
Field Citation; # ___ Additional information required
Inspection Deficiency Summary/Due date _
Notes:
After end of inspection, I received the annual 2022 annual walk through, 2022 operability test, 2022 line tightness test, and the 2022 ALDD function test.
Did not provide last 3 years of line tightness test results
Name of Owner/Operator Representative:
Name of EPA Representative:
_____________See Original________________________________
(Please print) ____________________________________________________________
(Signature)
Other Participants: ___________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________See Original__________________________
(Please print)
_______________________________________________________ (Signature)
______________________________________________________ (Credential Number)
______________________________________________________ (Title)
Date of Inspection _________ Time __________ AM/PM
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 19 of 24 Pages
Initial/Date:JAH 3/1/23__
Facility Name: Indian Country Mini Mart Additional Inspector's Observation Report Notes
Agency Fac. ID: EPA-TrUSTd-2320
No Additional Notes
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 20 of 24 Pages
Initial/Date:JAH 3/1/23__