Document kwJD9nQ8OBMk7oqepb8E6YND

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_0910_04 Inspection Date(s): Regulatory Program(s): EPA Region/Program Conducting Inspection: Company Name: September 10, 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 #3113 723 S Pueblo Blvd Pueblo, CO 81005 Inspector and Approval Katelyn Bergl Field Inspector Name Scott Patefield Inspector Title Branch Manager KATELYN BERGL Date: 2024.11.19 17:34:54 -07'00' Digitally signed by KATELYN BERGL Signature Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2024.11.19 15:59:59 -07'00' FACILITY INSPECTION DETAILS AND OBSERVATIONS General Facility Information Gasoline Dispensing Facility Facility Name: Alta Convenience #3113 AIRS-ID: 101-0184-001 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 02PB0390S.XP Brenda Mahoney, Assistant Manager Phone/Email: Facility Contact Odeana.Wilson@unitedpacific.com On-site Contact N/A Phone/Email: Facility Address: 723 S Pueblo Blvd, Pueblo, CO 81005 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 7 Inspection Number/ID: Inspector(s): Time Inspector Presented Credentials: Permission to Enter Facility Granted? If Yes, by whom? If No, explain. Photographer Name: Weather & Other General Site Observations: Inspection Narrative: Areas of Concern: General Inspection Information R8_CAA_2024_0910_04 Inspection Date Katelyn Bergl (EPA) Arrival/Departure Time 9/10/2024 4:30 PM 6:35 PM 4:30 PM Yes No Brenda Mahoney Katelyn Bergl Announced Unannounced Administrative Inspection Items: CBI Procedures Discussed SBREFA Form Provided Photograph Range: Other materials or compliance assistance provided (describe): MOV_3530 - 3532; IMG_0050 - 0069 Overcast, 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. The following are areas of concern identified during the inspection or records review: The fuel delivery driver did not engage the cam-lock gasket of the fuel line during premium fueling, causing vapor leak and liquid gasoline spillage into the spill bucket. As soon as this was pointed out, the driver engaged the cam-lock and the leakage and bubbling that was observed ceased. Gasoline Throughput and Testing Records Applicable Throughput Category: Calculated based on volume of gasoline loaded into all storage tanks Calculated based on volume of gasoline dispensed from all storage tanks <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 Records indicate >10,000 gallons per month since at least Exceeded: 2019 Records Notes 5-Year Throughput Records Available (5-year records must be maintained and made available within 24 hours of request) Throughput records for this facility from October 2019 - September 2024 were provided via email by 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 Provided along with 5-year throughput records throughput calculation Page 3 of 7 Fuel Delivery Truck Compliance (Gasoline Cargo Tanks under NESHAP 6C) Fuel Type: 1) Regular Unleaded (RUL) 2) Premium 3) E-85 4) Diesel Amount of Fuel Delivered: 1) 4400 gallons 2) 1600 gallons 3) 1100 gallons 4) 900 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 01/01/2024 Test: 5-Year Test Record Availability: Available at office or central loc. 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 activity which were observed: Description/Observations (including any OGI or AVO observations) Conditions of Equipment prior to refueling event The fuel delivery driver did not engage the cam-lock gasket of Connection of fuel and the fuel line during premium fueling, causing vapor leak and vapor lines prior to liquid gasoline spillage into the spill bucket. As soon as this fuel transfer was pointed out, the driver engaged the cam-lock and the leakage and bubbling that was observed ceased. (IMG_0064 and IMG_0066-0067). Vapors were observed from the tank vents during regular unleaded (RUL) and premium filling. The driver reported Maintenance of fuel that there was no vapor recovery system installed at this and vapor line facility, so vapors were not recovered during fueling and were connections during consequently vented simultaneously from the tank vent fueling event pipes, RUL spill bucket, premium spill bucket, and an adjacent automatic tank gauging (ATG) spill bucket (MOV_3530 and MOV_3531). Disconnection of fuel and vapor lines after fuel transfer Conditions of Vapors were observed from the ATG system spill bucket and Equipment after the RUL spill bucket after all fill pipes and spill buckets had refueling event been capped and covered post-fuel delivery (MOV_3532). Page 4 of 7 Documents Requested Document(s) 5-year fuel throughput records including previous 12-month fuel throughput calculation EPA Method 27 for the fuel delivery truck 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) Notes/Comments APPENDIX A: Photograph and Video Log Page 5 of 7 File Name MOV_3530.mp4 MOV_3531.mp4 MOV_3532.mp4 IMG_0050.JPG IMG_0051.JPG IMG_0052.JPG IMG_0053.JPG IMG_0054.JPG IMG_0055.JPG IMG_0056.JPG IMG_0057.JPG IMG_0058.JPG IMG_0059.JPG IMG_0060.JPG IMG_0061.JPG IMG_0062.JPG IMG_0063.JPG Description Vapors were observed from tank vents during RUL and premium filling. The driver reported that there was no vapor recovery equipment, so vapors were not recovered during fueling and vented from the vent pipes, RUL spill bucket, premium spill bucket, and an adjacent ATG spill bucket. Vapors continued to be observed from the adjacent ATG spill bucket while the diesel tank was being filled, after the RUL and premium tanks were filled, capped, and covered. Vapors continued to be observed from the adjacent ATG spill bucket and the RUL spill bucket, after all tanks were filled, capped, and covered. Condition of tank covers prior to fuel delivery. There was an active construction project adjacent to the tank covers to repair or remove old fuel storage tanks. Condition of first RUL tank cover prior to fuel delivery. Condition of second RUL tank cover prior to fuel delivery. Condition of diesel tank cover prior to fuel delivery. Condition of E-85 tank cover prior to fuel delivery. Condition of premium tank cover prior to fuel delivery. Tank vent stacks. Tank vent stacks. Condition of the first RUL tank spill bucket prior to fuel delivery. The bucket was rusted and in poor condition. Condition of the second RUL tank spill bucket prior to fuel delivery. The bucket was filled with liquid prior to fuel delivery. Condition of the second RUL tank spill bucket prior to fuel delivery. The bucket was filled with liquid prior to fuel delivery. Condition of the diesel tank spill bucket prior to fuel delivery. The bucket was filled with liquid prior to fuel delivery. Condition of the E-85 tank spill bucket prior to fuel delivery. The bucket was filled with liquid prior to fuel delivery. Condition of the premium tank spill bucket prior to fuel delivery. The bucket was filled with liquid prior to fuel delivery. Photographer K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 6 of 7 IMG_0064.MOV IMG_0065.JPG IMG_0066.MOV IMG_0067.MOV IMG_0068.JPG IMG_0069.JPG Video capturing vapor bubbles coming up through the pre-existing liquid in the spill bucket during the fueling of the second RUL tank. Fuel truck: Trailer identifier Video capturing liquid fuel spilling into the preexisting liquid in the spill bucket during the fueling of the premium tank, due to the cam-lock not being engaged during fueling. Video capturing vapor bubbles coming up through the pre-existing liquid in the spill bucket after the fueling of the premium tank. Method 27 certificate for the truck Method 27 certificate for the truck K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl K. Bergl Page 7 of 7