Document g2gRK9zBaG6QXqyJworB25npL

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: R8_CAA_2024_0909_02 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: September 9, 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 United Pacific / CF Altitude LLC Facility Name: Facility Physical Location: (street address, building/unit #) (city, state, zip code): Alta Convenience #3104 725 W Northern Ave Pueblo, CO 81004 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Inspector Title Branch Manager KATELYN BERGL Date: 2024.11.19 17:27:25 -07'00' Digitally signed by KATELYN BERGL Signature Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2024.11.19 15:30:04 -07'00' FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Alta Convenience #3104 AIRS-ID: 101-0186-001 Primary Facility Representative & Title: ODeana Wilson Corporate Environmental Manager Parent Company Name: CAA Permit (if any): On-site Facility Representative & Title: CF Altitude LLC Permit Exempt Number 02PB0391S.XP Cole Barlow, Assistant Manager Phone/Email: Facility Contact Odeana.Wilson@unitedpacific.com On-site Contact N/A Phone/Email: Facility Address: 725 W Northern Ave, Pueblo, CO 81004 Enforcement and Compliance History: None Fuel Delivery Company Fuel Supply Company Name: World Kinect Corporation Truck Identifier: Fuel Supply Company Representative & Title: Fuel Supply Company Contact Phone/Email: Ron Browning Operations Manager Ronbrowning@wfscorp.com Name (if different): Trucking Company Same Trailer Identifier: 0986 Driver Name: Fermin Moreno Company Address: Fuel Supply 1739 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. General Inspection Information R8_CAA_2024_0909_02 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 5:45 PM Yes No Cole Barlow Administrative Inspection Items: 9/9/2024 5:39 PM 6:55 PM Announced Unannounced CBI Procedures Discussed SBREFA Form Provided Other materials or compliance assistance provided (describe): Photographer Name: Weather & Other General Site Observations: Inspection Narrative: Katelyn Bergl Photograph Range: IMG_0014 - IMG_0017 MOV_3514 - 3516 Mostly cloudy, 80 deg F, winds 9 mph S 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. Areas of Concern: The tank and associated vapor system were not vapor tight during the fuel delivery event. The following emissions were observed during the fuel delivery portion of EPA's inspection: 1) During fueling of the RUL tank, the vapor recovery hose valve between the hose and the truck was left in the closed position, causing vapors to escape from the tank vents rather than be recovered into the truck. The driver was notified of the emissions and subsequently opened the valve, at which point the vapors were no longer observed coming out of the tank vents. 2) Vapors were observed from the vapor recovery header of the fuel truck after the cap had been removed and before fueling began. Gasoline Throughput and Testing Records Applicable Throughput Category: Calculated based on volume of gasoline loaded Calculated based on volume of gasoline into all storage tanks dispensed from all storage tanks Page 3 of 6  <10,000 gallons per 10,000 gallons per month and < 100,000 100,000 gallons per month gallons per month month Date Applicable Throughput Category Was Exceeded: Records indicate >10,000 gpm since at least 2019 Records Notes Throughput records for this facility from October 2019 - 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) September 2024 were provided via email by ODeana Wilson on September 24, 2024. The spreadsheet indicates that the records are for the product "gasoline", and Ms. Wilson clarified that "gasoline" includes unleaded, midgrade, premium, and E-85 blends. Last 12-month rolling throughput calculation Provided along with 5-year throughput records Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium Amount of Fuel Delivered: Annual Certification Test - Vapor Tightness Testing - EPA Method 27 of appendix A-8 to part 60 of CAA 1) 7,200 gallons 2) 900 gallons Available with truck Date of Last 01/01/2024 Test: 5-Year Test Record Availability: Available at office or central location Not Available Other: Results of Test: Pass 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) Equipment capped and covered prior to fuel delivery. Conditions of Equipment Vapors were observed from the vapor recovery header of prior to refueling event the fuel truck after the cap had been removed and before fueling began. Connection of fuel and vapor Emissions were observed from the vapor recovery lines prior to fuel transfer header on the truck after the cap was removed and prior to vapor recovery hose connection (MOV_3516). Page 4 of 6 During fueling of RUL tank, the vapor recovery hose Maintenance of fuel and valve between the hose and the truck was left closed, vapor line connections causing vapors to escape from the tank vents rather during fueling event than be recovered into the truck. The driver was notified and opened the valve, at which point the vapors were no longer observed coming out of the tank vents. Disconnection of fuel and vapor lines after fuel transfer Conditions of Equipment after refueling event Document(s) 5-year fuel throughput records include previous 12-month fuel throughput calculation EPA Method 27 for the fuel delivery truck Documents Requested Status Document(s) Document(s) Provided Denied Will Provide After Other (see notes) Inspection Document(s) Document(s) Provided Denied Will Provide After Other (see notes) Inspection Notes/Comments Page 5 of 6 APPENDIX A: Photograph and Video Log File Name Description MOV_3514.mp4 MOV_3515.mp4 MOV_3516.mp4 IMG_0014.JPG IMG_0015.JPG IMG_0016.JPG IMG_0017.JPG Pre-fuel equipment scan Vapors were observed from the vapor recovery header of the fuel truck after the cap had been removed and before fueling began. Large plume of continuous vapors observed from P/V Vapor vents during RUL fueling. The truck-side valve on the vapor recovery hose was left in the shut position during fueling, preventing vapors from being recovered by the truck and forcing the vapors out of the vent pipe. As soon as the inspector pointed this out to the driver, the driver opened the valve and began recovering the vapors, and the vapors were no longer visible. Fuel truck: Trailer identifier Condition of tank covers prior to fuel delivery. Vapor Vents: 1 each for RUL and Premium fuel types. RUL and Premium are Pressure/Vapor-Type vents. Fuel truck: Trailer identifier Photographer K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 6 of 6