Document peJGjj85kB9gJ7oBVYmpnO0nd

Compliance Evaluation Inspection Report Farmers Union Oil Co. Main Street July 2024 Submitted to: U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop St. Denver, CO 80202 Submitted by: Eastern Research Group. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 EPA Contract No. 68HERC21D0007 Task Order 68HERC22F0492 COMPLIANCE EVALUATION INSPECTION REPORT Date of Report: July 8, 2024 Date and Time of Inspection: May 14, 2024, at 1:15 PM MST Weather: Cloudy, 60 Fahrenheit Facility Contact/Owner: Farmer's Union Oil Co. Owner Address: PO Box 70 Dupree, South Dakota 57623 Facility Address: 111 D Street Dupree, South Dakota 57623 Facility Phone: Facility ID Number: 4020020 Reason for Inspection: Compliance Inspection Inspector(s): , ERG (Lead) Farmers Union Oil Co. Main Street ii July 2024 TABLE OF CONTENTS 1. NARRATIVE ..................................................................................................................... 1 2. SUMMARY ........................................................................................................................ 4 ATTACHMENTS Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: Attachment F: Attachment G: EPA Region 8 UST Compliance Checklist Photograph Log Tank Leak Detection Records Equipment Testing Records Cathodic Protection Testing Records Commercial Insurance Certification Notice Of Inspection Farmers Union Oil Co. Main Street iii July 2024 1. NARRATIVE The Region 8 (R8) office of the Environmental Protection Agency (EPA) requested multiple facilities be inspected on tribal lands. Eastern Research Group (ERG) under EPA's Contract No. 68HERC21D0007, Task Order 68HERC22F0492, provided assistance to EPA in preparing for, conducting the inspection, and preparing this inspection report. ERG inspected the Farmers Union Oil Main Street located in Dupree, South Dakota on May 14, 2024. The facility was last inspected on June 29, 2021. , contract inspector for EPA, contacted Mr. , representative of Farmers Union Oil Co, to notify the facility about the inspection on April 26, 2024, prior to the inspection. The inspection verified compliance with the federal underground storage tank (UST) requirements of Resource Conservation and Recovery Act (RCRA) Subtitle I under 40 CFR Part 280. Upon arrival at the facility, Ms. introduced herself as a contract inspector for EPA, presented her credentials, and provided an in-brief to Mr. to explain the purpose of the inspection. Following the inspection, Ms. concluded with an exit brief to inform the facility of preliminary observations identified during the inspection and had Mr. sign the Notice of Inspection (NOI). Ms. took photographs during the inspection. UST System Description Farmers Union Oil Co. Main Street (facility) is a privately owned gas station with a convenience store located at 111 D Street, Dupree, SD 57623. The fuel at this facility is sold to the public. The facility is located on the Cheyenne River Indian Reservation. According to the previous EPA inspection report and observations made during the inspection, the facility has four STI-P3 underground storage tanks (USTs) installed in April 1988. Tank 1 has a capacity of 4,000 gallons and contains dyed diesel. Tank 2 has a capacity of 4,000 gallons and contains E10 gasoline. Tank 3 has a capacity of 2,000 gallons and contains dyed diesel. Tank 4 has a capacity of 4,000 gallons and contains diesel. The facility piping for each tank is fiberglass reinforced plastic (FRP) safe suction. Ms. completed an EPA Region 8 UST Compliance Inspection Checklist for the USTs while on site which is included in Attachment A. Photograph #1 in Attachment B shows the dispensers and an overview of the UST system. UST System Records The listing of documents reviewed for the Farmer's Union Oil Co. inspection included the following: 1. UST Leak Detection Records 2. Cathodic Protection Records 3. Insurance Coverage Certification 4. UST Compliance Testing Records Farmers Union Oil Co. Main Street 1 July 2024 The facility maintains their records on site. Mr. and the day following the inspection. provided the records for the UST during Tank Release Detection The facility uses a Gilbarco EMC Plus monitoring system and associated in-tank probes that conduct automatic tank gauging (ATG) of the tanks. Photograph #2 in Attachment B shows the monitoring system interface. Mr. provided leak detection results for June 2023 through January 2024, March 2024, and May 2024. Mr. was unable to find the test results from February 2024 and April 2024 during the inspection. Tank 1 failed the leak detection tests in July 2023 and August 2023 due to low tank levels and in December 2023, January 2024, and March 2024 due to invalid fuel levels. Tank 2 failed the leak detection tests in June 2023, August 2023, and October 2023 due to low tank levels. Tank 4 failed the failed the leak detection tests in July 2023, October 2023, November 2023, and March 2024 due to low tank levels. Attachment C contains a compilation of the ATG static leak test results. Piping Release Detection Piping leak detection is not required because this facility has safe suction piping. This was confirmed during the site inspection. Spill/Overfill Prevention The facility's overfill prevention is provided by audible alarm. Overfill prevention equipment tests from May 15, 2024, were provided for review following the inspection. Overfill alarms failed for all four tanks. The facility had overfill alarm tests conducted on May 15, 2024, the day following the inspection and the overfill alarms failed for all four tanks. Spill bucket tests from May 15, 2024 were provided for review the day following the inspection. All four spill buckets passed the integrity test. Photographs #3 through #6 in Attachment B show the fill ports for the respective USTs. The overfill prevention test results and the spill bucket integrity test results from May 2024 are included in Attachment D. Corrosion Protection The facility requires cathodic protection (CP) for the USTs as they are single-walled STI-P3 tanks. CP tests from February 2024 were provided for review during and following the inspection. The passing CP tests for all four USTs are included in Attachment E. Operator Training Certificates for the Class A and Class B operator were presented during the inspection. Mr. is both the Class A and Class B designated operator. There were no records for Class C operator training. Walkthrough Inspections Records of the monthly and annual walkthrough inspections were not available at the time of the inspection. Farmers Union Oil Co. Main Street 2 July 2024 Financial Assurance In South Dakota, financial coverage for owners/operators of regulated USTs is provided through the South Dakota Petroleum Release Compensation Fund. Mr. had a copy of the letter from the state indicating facility coverage. The facility is self-insured for the deductible. Attachment F includes the financial assurance certification for the facility. Physical Inspection During the site visit, Ms. reviewed documents on site and observed the fill ports, two of the three dispensers and associated dispenser sumps, and the ATG monitoring interface for the four USTs on site. Photograph #2 in Attachment B shows the interface for V Gilbarco EMC ATG system. Ms. observed the spill bucket and fill pipe for the four USTs. The spill buckets for Tank 1 and Tank 2 were dry and in good condition at the time of the inspection. The spill buckets for Tank 3 and Tank 4 contained approximately two inches of water. The facility has three double-sided pump dispensers, and two of the dispensers were opened as part of the inspection. The dispensers are a safe suction system and are not equipped with sumps or liquid sump sensors. Ms. did not observe signs of leaks at the time of the inspection. Photographs #7 through #10 in Attachment B show the piping beneath dispensers 3/4 and dispensers 5/6. No monitoring wells were observed at the tank field during the inspection. Vent lines are located west of the USTs against one of the garages. No obstructions or concerns were noted for the vent lines at the time of the inspection. Farmers Union Oil Co. Main Street 3 July 2024