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BRIAN D'ALFONSO Date: 2022.11.01 14:31:50 -05'00' Digitally signed by BRIAN D'ALFONSO AMBER WHISNANT Date: 2022.12.29 19:03:42 -06'00' Digitally signed by AMBER WHISNANT
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Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
REPORT OF OPENING AND CLOSING CONFERENCES
Opening Conference
1. Give time of and list attendees of Opening Conference_Aleisha Barclay, Amos Two Bulls, Mark Aaron, William Blair, Joseph Heafner, Brian D'Alfonso_________________________
_ ____________________________________________________________________________
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_ Aleisha Barclay, Amos Two Bulls, Mark Aaron, William Blair, Joseph Heafner, Brian D'Alfonso ______________________
____________________________________________________________________________
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?
Yes No
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
5. Was EPA's right to bring an enforcement action pending review explained? Yes No
6. Were any "fixed" deficiencies or areas of concern noted in the report?
Yes No
7. Were photos and copies of documents itemized on the report?
Yes No
8. Was the time frame for receiving the completed report given?
Yes No
9. Was the Small Business Resources Information Sheet provided?
Yes No
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 2 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
1 UST Inspection Checklist
I. Ownership of Tank(s)
Tribal
Agency Fac. ID EPA-TrUSTD-2311 Agency Fac. ID EPA-TrUSTD-2311
II. Location of Tank(s) same as owner location (I.)
Owner Name:
Ho Chunk, Inc
_____________________________________________________________
Street Address
1 Mission Drive
______________________________________________________________
County
Thurston
______________________________________________________________
City
State
Zip Code
Winnebago
Nebraska
68071
______________________________________________________________
Phone Number
402-878-2809
______________________________________________________________
Owner Contact Person
Danielle Gutierrez (dgutierrez@ponyexpressstores.com)
______________________________________________________________
Do you own UST(s) at other UST Facilities Yes/No
If Yes, how many facilities__5____________ How many USTs____15_________________
Facility Name or Company Site identifier, as applicable
Pony Express (North)
___________________________________________________________
Street Address or State Road, as applicable
137 Hwy 77 North
___________________________________________________________
County
Thurston
___________________________________________________________
City (nearest)
State
Zip Code
Winnebago
Nebraska
68071
___________________________________________________________
Contact Person(s) at Facility
Phone Number
Virginia Hansen
402-268-5417
___________________________________________________________
Latitude
Longitude
42.257285
-96.478322
___________________________________________________________
Datum
WGS 84
___________________________________________________________
ICIS/FERS Number:
Date entered:
___________________________________________________________
III. Notification (280.22)
Notification to implementing agency; name _EPA Region 7________________________[280.22(a)]
Agency Facility ID # _EPA-TrUSTD-2311___; 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 NE Title 200_____ Private Insurance: Insurer/Policy #NACL0058012 Expires 1-1-2023
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: BPD/10-20-22
Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
V. Operator Training (280.240) [List names, certificate numbers, expiration dates, trainer, and state]
A Operator(s): Aleisha Barclay, A/B, Petro Classroom, 8-26-2001 (#0360349)
Virginia Hansen, A/B, Petro Classroom, 10-13-2020 (#0352953)
_____________________________________________________________________________
B Operators(s): Aleisha Barclay, A/B, Petro Classroom, 8-26-2001 (#0360349)
Virginia Hansen, A/B, Petro Classroom, 10-13-2020 (#0352953)
__________________________________________________________________________________________
C Operators(s): Maurice Scott, 12-2-20; Brandon Baker, 8-24-22 (Both on duty)
_________________________________________________________________________________________
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:
_No domestic water wells within 1500 feet________
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)
1
2
3
Tank presently in use
Yes
Yes
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) 1/2001 1/2001 1/2001
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?
Yes No NA UNK
Are Compatibility Records available? Yes No NA UNK
[280.34(b)(3)]
Is compatibility demonstrated?
Yes No NA UNK
[280.32(b)(1) and (2)]
Contained Submersible Turbine Pump (STP) Sumps
Yes No NA UNK
If yes, give installation date_1-1-2001______________
Is STP used for release detection? Yes No NA UNK
DW FRP DW FRP
DW FRP
15,000 E85
Yes Yes
15,000
Unleaded V-grade
NA
15,000
Clear Diesel
NA
NA
NA
Yes
Yes
Yes
Yes
Yes
Yes
Is STP double-walled?
Yes No NA UNK
If Double-Walled (DW), Date of Last Monthly Integrity
No
Check of Annular Space? [280.35(a)(1)(i)] Note: only
applies to interstitial spaces under pressure or vacuum
or filled with brine.
No
No
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 4 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
VII. Tank Information (give numbers)
1
2
3
Contained Submersible Turbine Pump (STP) Sumps
If DW, are the last 12 months of records available? Yes No NA UNK
NA
NA
NA
If non-DW, Date of Last 3-year Containment Integrity Test? [280.35(a)(1)(ii)] Note: Triennial Sump Testing is required if sumps installed on or after April, 11, 2016. Special Configuration Manifolded/Compartmentalized - Describe using tank numbers Field-Constructed/Airport Hydrant System FC or AHS
VIII. Piping Information
Piping type
Pressurized
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__1-1-2001______________
Is UDC used for release detection? Yes No NA UNK
NA
NA
NA
X
Flexible DW Non-
metallic Yes No
NA
NA
NA
X
Flexible DW Non-
metallic Yes No
NA
NA
NA
X
Flexible DW Non-
metallic Yes No
Is UDC double-walled?
Yes No NA UNK
If DW, Date of Last Monthly Integrity Check of Annular
No
No
No
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? Yes No NA UNK
NA
NA
NA
If non-DW, Date of Last 3-Year Containment Integrity
Test? [280.35(a)(1)(ii)] Note: Triennial Sump Testing is
NA
NA
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: BPD/10-20-22
Facility Name Pony Express (North)
X. Temporary Closure NA CP is continued to be maintained [280.70(a)] Y N Unknown NA
Agency Fac. ID EPA-TrUSTD-2311
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: 1
2
3
Are the metal components at the tank and dispenser isolated (e.g. booted),
cathodically protected or isolated? [280.20(b)(4)] Yes No NA UNK
Yes Yes Yes
Notes: Contained sumps for tanks 1,2,3; Contained UDC for E85, gas and diesel
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 6 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
XI. Corrosion Protection (CP) Tank numbers: 1
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?
Yes No NA UNK
Agency Fac. ID EPA-TrUSTD-2311
2
3
Internal inspection test result - Pass or Fail
If Fail, is tank still in service? [280.21(b)(1)(ii)]
Yes No NA UNK
Sacrificial Anode:
NA
CP system operated and maintained continuously. [280.31(a)]
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. [280.31(a)]
Yes No NA UNK
Tested Six Months after repair
Last 3 yr test results show a voltage of at least -850mV or
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: BPD/10-20-22
Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
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 numb 1
2
3
Device is present and functional? [280.20(c)(1)(i)] Yes No NA UNK Yes Yes Yes
Spill bucket free of water, debris, etc.
Yes No NA UNK
No
No
No
Double walled? Yes No NA UNK Note: only applies
interstitial spaces under pressure or vacuum or fill No
No
No
with brine.
If Yes, Last Monthly Check? [280.35(a)(1)(i)] List date NA
If No, Date of Last Triennial Containment Integrity Test
[280.35(a)(1)(ii)] List date:
6/12/2019
NA Unk6/12/2019
NA Unk6/12/2019
Overfill Prevention
Device is present and operational? [280.20(c)(1)(ii)]
Yes
Yes
Yes
Yes No NA UNK
Date of Last Triennial Inspection? [280.35(a)(2)]
No
No
No
Ball float valve riser present:
[280.20(c)(1)(ii)(B) Yes No NA UNK
NA
NA
NA
Ball float valves are not suitable on suction systems,
with coaxial drop tubes, or pressurized deliveries.
Ball float valve installed or replaced after October 13,
2015?
NA
NA
NA
[280.20(c)(3)] Yes No NA UNK
Flapper valve Operational: [280.20(c)(1)(ii)(B)] Yes No NA UNK NA NA NA
Automatic shutoff: Operational: [280.20(c)(1)(ii)(A)] Yes No NA UNK Yes NA NA
Automatic shutoff: Operational: [280.20(c)(1)(ii)(A)] Yes No NA UNK Yes NA NA
Alarms Operational: [ 280.20(c)(1)(ii)(B)]
Yes No NA UNK
Yes
Yes
Yes
Visible and/or audible to jobber/driver?
Yes No NA UNK
Yes
Yes
Yes
Location(s) of overfill alarm(s): North side of store, east of vent pipes
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 Yes for tanks, no for lines
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
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 8 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
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: 1
2
3
Automatic Line Leak Detector (ALLD) installed
(give date last tested/checked) Yes No NA UNK
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
2-14-2022
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:
Annual Line Tightness Testing -- give date
2/14/2022
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
ALM:IM
Suction Piping
Line Tightness Testing (required every 3 yr)
Yes No NA UNK
Yes
No Yes Yes Yes Yes Yes
NA NA Yes ALM
Yes
No Yes Yes Yes Yes Yes
NA NA Yes ALM
Yes
No Yes Yes Yes Yes Yes
NA NA Yes ALM
Indicate date of most recent test Secondary Containment with Interstitial Monitoring
Yes No NA UNK
Other (SIR, etc.)
Yes No NA UNK
No Leak Detection Required (must answer yes to all of the following questions):
Operates at less than atmospheric pressure
Yes No NA UNK
Has only one check valve which is located directly under pump
(dispenser) Yes No NA UNK
Slope of piping allows product to drain back into tank when
suction released Yes No NA UNK
Facility Name Pony Express (North)
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 9 of 24 Pages
Agency Fac. ID EPA-TrUSTD-2311
Initial/Date: BPD/10-20-22
XIII. Tank and Pipe
1
2
3
Release Detection
Tank Numbers
Under Dispenser Containment (UDC)
List dates installed
1/2001
Note: Triennial Sump Testing required if sump install
1/2001
1/2001
on or after April 11, 2016.
Are UDC Monitored?
Yes No NA UNK
Yes
Yes
Yes
How are UDC Monitored? Visual or Electronic
Electronic Electronic Electronic
Are records of inspections available?
Yes No NA UNK
NA
NA
NA
UDC Monitoring Notes: (Records of release: State the past 12 months monitoring records)
280.44(a) - Leak detector function tests not available during the inspection
Tank Release Detection Summary (refer to appropriate detailed RD form) Pages 13-18
Mark Tank numbers with an "X"
Automatic Tank Gauging (ATG)
X
X
X
Automatic Line Monitoring (ALM)
X
X
X
Interstitial Monitoring (IM)
X
X
X
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
Date of last 30-day Walkthrough Inspection___Sept. 2022___________
Spill Prevention Equipment - must be checked for damage, remove liquid or debris, and check 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]
Release detection equipment - must check to ensure operating with no alarms and review records of of release detection testing.
Do the 30-day walkthrough inspections follow a nationally recognized standard code or practice?
Are records of 30-day walkthrough inspections available for the two most recent consecutive months and for 10 of the last 12 months?
Must have records for inspections performed each year
Date of last Annual Walkthrough Inspection__None__________
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 Y N Unknown NA
Y N Unknown NA Y N Unknown NA Y N Unknown NA Y N Unknown NA Y N Unknown NA
Facility Name Pony Express (North)
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 10 of 24 Pages
Agency Fac. ID EPA-TrUSTD-2311
Initial/Date: BPD/10-20-22
SITE DRAWING
DATE: 9-7-22 WEATHER:
TIME ON SITE:
12:30
TIME OFF SITE: 2:30
ENVIRONMENTALLY SENSITIVE AREA : Y N
If "Yes", please describe:
Pony Express Winnebago, 137 US HWY 77 North, Winnebago, NE 68701 EPA-R7-UST Fac. ID #635
N
W
E
S
Legend
STP STP Sump SB Spill Bucket ATG ATG Probe IM /DZZ PS Piping Sump
Index Map
N
# # Dispenser Vent Tube
ATG Zd' OA K
(1) Tank 1 -- E85 (15K gallons) (2) Tank 2 --Unleaded V-grade (15K gallons) (3) Tank 3 --Diesel (15K gallons)
W
E
S
Diesel Dispe nsers
Map Work --Google Maps
Pictures
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 11 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
NOTES:
Weather: Partly cloudy x Diesel Dispenser UDC Notes
Dispenser Number Product
Observation
2 Master 2 Slave 1 Master
Clear Diesel Clear Diesel Clear Diesel
~2" of liquid in bottom of UDC. Liquid sensor laying on it's side in the liquid. No alarm was triggered on ATG.
~1" of liquid in bottom UDC. Sensor was touching the bottom, thus was not in the liquid.
~1/2" of liquid in bottom of UDC. ATG showed an alarm for this dispenser.
1 Slave
Clear Diesel
Good
9 Master
Clear Diesel
~2" of liquid in bottom of UDC. ATG showed an alarm for this dispenser.
9 Slave
Clear Diesel
Good
x Gasoline Dispenser UDC Notes Dispenser Number Product
3/4
Gasoline
5/6
Gasoline
7/8
Gasoline
Observation
~2" of liquid in UDC. Sensor was not touching bottom, thus not touching liquid. ~2" of liquid in UDC. Sensor was touching the liquid, but did not trigger an alarm.
UDC was dry. Sensor was touching the bottom.
x Tank
Contained STP Sump and Spill Number Product Stored
1
E85
2 Unleaded V-grade gasoline
3
Clear Diesel
Bucket Notes Observations Veeder-Root PLLD installed on STP, no liquid in bottom, no Schraeder valve on test boot, test boot open but over break in secondary pipe, sump sensor properly positioned. ~1" of liquid in spill bucket. Veeder-Root PLLD installed on STP, bottom of sump sensor above the level of liquid in the sump, no Schraeder valve on test boot, test boot open but over break in secondary pipe. ~1" of liquid in spill bucket. Veeder-Root PLLD installed on STP, bottom of sump sensor is below the level of the liquid - no alarm for that condition, no Schraeder valve on test boot, test boot open but over break in secondary pipe. LLD junction box missing cover. ~1" of liquid in spill bucket.
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 12 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
Automatic Tank Gauging (ATG) NA
Agency Fac. ID EPA-TrUSTD-2311
Manufacturer, name and model number of system: Gilbarco EMC Environmental Management Console Third-party evaluators: Ken Wilcox and Associates, Inc.
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)]
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)] ATG 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 #1
Tank #2
Tank #3
Tank #4
Tank #5
2022
January
P
P
P
2022
February
P
P
P
2022
March
P
P
P
20222
April
P
P
P
2022
May
P
P
P
2022
June
P
P
P
2022
July
P
P
P
2022
August
P
P
P
2022
September
P
P
P
2021
October
NA
NA
NA
2021
November
NA
NA
NA
2021
December
NA
NA
NA
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)]
NA Yes No
Annual Release Detection Operability
Test Date: 2-14-22________
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 July, Aug, Sept. - ATG shows "L2" & "L12" alarms in status report. x Tanks 1, 2, 3 passed 0.2 gph tests during inspection x 3 years of release detection operability test results not available during inspection
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 13 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North) Automatic Line Monitoring (ALM) NA
Manufacturer, name and model number of system: Veeder Root PLLD
Third-party evaluators: Ken Wilcox and Associates, Inc.
Agency Fac. ID EPA-TrUSTD-2311
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
2022
September
P
P
P
October
November
December
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)]
NA
Yes No
Annual Function Test
Test Date: _02/14/2022___________
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
x ALM Tests from printouts collected during the inspection on 9/7/2022
Tank 1 (Q1 on ATG printout), Tank 2 (Q2), Tank 3 (Q3)
Line
3.0 gph Test
0.2 gph Test
0.1 gph Test
Number Result
Test Date
Result
Test Date
Result
Q1
Pass
9/7/2022
Pass
9/7/2022
Pass
Q2
Pass
9/7/2022
Pass
9/7/2022
Pass
Q3
Pass
9/7/2022
Pass
9/7/2022
Pass
x 280.45(b) - Not printing 0.2 gph tests from ALMs each month
Test Date 9/7/2022 9/7/2022 9/7/2022
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 14 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
Interstitial Monitoring for: Piping / Tank(s)
NA
Agency Fac. ID EPA-TrUSTD-2311
Manufacturer and name of system: Veeder Root 794380 Non discriminating Sump Sensors
Date system installed: 1/1/2001
Materials used for secondary containment: FRP for tanks, plastic for sumps (STP and UDC) and piping
Materials used for internal lining: NA
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? Plastic
Documentation of monthly readings is available for last 12 months.
Year
Month
Tank Pipe Tank Pipe Tank Pipe
#1
#1
#2
#2
#3
#3
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
Y N Unknown NA
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
x 280.45 - Not printing liquid sensor reports each month x Sump sensor liquid status during inspection - L2 "Fuel Alarm" and L12 "Fuel Alarm". x 280.40(a)(2) - Improperly installed sump sensors for dispenser 3/4, dispenser 9 master, dispenser 9 slave. x 280.430(a)(2) -Sensors touching liquid but nor producing alarm; Dispenser 5/6, dispenser 9 slave, tank 3 STP sump.
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 15 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North)
Agency Fac. ID EPA-TrUSTD-2311
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
2022
January
P
P
P
2022
February
P
P
P
2022
March
P
P
P
2022
April
P
P
P
2022
May
P
P
P
2022
June
P
P
P
2022
July
P
P
P
2022
August
P
P
P
2022
September
P
P
P
2021
October
P
P
P
2021
November
P
P
P
2021
December
P
P
P
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: BPD/10-20-22
Facility Name Pony Express (North)
Statistical Inventory Reconciliation (SIR)
NA
Agency Fac. ID EPA-TrUSTD-2311
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
SIR documentation is available at site (e.g., designer's brochures, owners' manual)
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 Detection Methods").
SIR results are available for the past 12 months
SIR Test Results: P = PASS Year
F = FAIL Month
INC = Inconclusive
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
Tank #6
Non-passing results reported and resolved in accordance with implementing agency's directions. [280.40(b)] NA Yes No
Receiving results within a time frame established by implementing agency [280.41(a) & 280.43(h)]
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: BPD/10-20-22
Facility Name Pony Express (North) Manual Tank Gauging (MTG) NA
Agency Fac. ID EPA-TrUSTD-2311
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
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 18 of 24 Pages
Initial/Date: BPD/10-20-22
Facility Name Pony Express (North) Additional Inspector's Observation Report Notes
Agency Fac. ID EPA-TrUSTD-2311
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 20 of 24 Pages
Initial/Date: BPD/10-20-22
4 Underground Storage Tank (UST) Inspection Photo Documentation Log
Facility Name:
Location (City/State)
Date Photos Taken: Photo No. Time Direction
Agency Fac. ID:
Photographer: Description
Date and time will be imprinted on photo. Lat/Long retained in photo properties if GPS Camera used.
Photos Downloaded to_________________________________________________________________________________
Date:
Time:
Initials:_________________
UST Inspection Report USTREPORT-001-R07 v3.3/April 2021
Page 24 of 24 Pages
Initial/Date: BPD/10-20-22