Document ppbBdNn3kaaG0aMMQ53Rqx2Ma

COMPLIANCE INSPECTION REPORT FOR UNDERGROUND STORAGE TANKS EPA Region 6 Federal Form FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Physical Address: City, State, Zip: Mailing Address: Facility Representative Title and E-mail: 121 Panther Trail Drive Phone: 337-224-3159 Kinder, LA, 70648 County Allen PO Box 1510 (Address) Kinder (City) LA (State) 70648 (Zip) Carla Oliver / Facility Manager / coliver@coushattacasinoresort.com UST Operator: Coushatta Casino Resort Mailing Address: UST Contact: Mailing Address: UST Owner: PO Box 1510 (Address) Carla Oliver PO Box 1510 (Address) Same as Operator Mailing Address: Contact Name and E-mail: (Address) Phone: 800-584-7263 Kinder (City) Phone: 337-738-7150 Kinder (City) Phone: Fax: LA 70648 (State) (Zip) Fax: NA LA 70648 (State) (Zip) Fax: (City) (State) Phone Number: (Zip) Facility Land Tribally Owned: Yes No Facility Privately Owned/Leased on Tribal Land: Yes No Lead Inspector: Robert Glynn Additional Inspector(s) and Others present: See Comments Summary of Findings and Facility Comments: Facility well maintained and records in good order. Additional Inspector(s) and Others present: Carla Oliver - Facility Manager Duane Langley - Resort Safety Willie Wells - Compliance Assistance Jesse Spence - Compliance Assistance David Hayes & Larry Scrapper - ITEC EPA REGION 6 UST CEI CHECKLIST 1/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Start Time: 9:55 AM PM End Time: 11:03 AM Type of Inspection: PM CEI Follow Up Over all: YES NO Facility SOC: Prevention: YES NO Detection: YES NO Comments: Report By: Printed Name, Title Reviewed By: Robert Glynn (Date) 03/20/2018 (Date) EPA REGION 6 UST CEI CHECKLIST 2/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels Section A Registration Requirements INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Further Explanation Attached 1. Are all New and Existing Petroleum UST systems registered? (New - 280.22(a); Existing280.22 (a)) Yes No N/A 2. Are all new USTs that contain regulated hazardous substances registered? Yes No N/A 3. Please indicate the number, size, product stored, installation date, and upgrade date for all tanks at the facility? TANK SIZE of TANK PRODUCT NO. (GALLONS) STORED 1 12000 No Eth/Reg Gas TANK TYPE SW / DW Cathodically Protected Steel/SW STATUS Compartment or Manifold Active or TC Indicate associated tank(s) Active Compartment Manifold 2 12000 No Eth/Reg Gas Cathodically Protected Steel/SW Active Compartment Manifold 3 12000 Premium Gas Cathodically Protected Steel/SW Active Compartment Manifold 4 12000 Diesel Cathodically Protected Steel/SW Active Compartment Manifold 5A 4000 No Eth/Reg Gas Cathodically Protected Steel/SW Active Compartment Manifold 6A 8000 Diesel Cathodically Protected Steel/SW Active Compartment Manifold INSTALL DATE 01/01/2002 01/01/2002 01/01/2002 01/01/2002 01/01/2002 01/01/2002 UPGRADE DATE Compartment Manifold Compartment Manifold Compartment Manifold Compartment Manifold Latitude: Degrees: Minutes: 30.548462 Seconds: Number of Dispenser's: 16 X 2 Longitude: Degrees: Minutes: Seconds: -92.810213 GPS Measured At: Input Tank # fill- Other port. (detail how this count was made below) Section A Comments: Add converted GPS measurement in Decimal Degrees In front of Store: 6 islands with 2 double side dispenser on each island. To North side of store: 2 islands with 1 double sided dispenser on each island. Sump and Spill buckets contained residual water from rain (plus low water table) but had crew scheduled to remedy. EPA REGION 6 UST CEI CHECKLIST 3/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Significant Operational Compliance Components (SOC) SOC - Release Prevention Section B Standards for New Underground Storage Tanks (Tanks installed after 12/22/88) Further Explanation in Narrative Section B Not Applicable 1. Tank Construction: S-p8 SW DW a. Is each tank properly designed and constructed to prevent corrosion in any portion of the Yes No N/A tank that routinely contains product?(280.20(a)) b. If installed after 4/11/16 is tank secondarily contained? Yes No N/A 2. What is the corrosion protection method for the tanks? S-p8 a. Fiberglass reinforced plastic-FRP (280.20(a)(1)) Yes No N/A b. Tank constructed of metal and cathodically protected e.g. galvantic - STI-P3, metal tank with impressed current system (280.20(a)(2)) Specify: Sacrifical Anodes Yes No N/A c. Metal-fiberglass-reinforced-plastic composite (ACT-100) (280.20(a)(3)) Yes No N/A d. Records available to document that Corrosion Protection is not necessary. (280.20(a)(4)) Yes No N/A e. Other corrosion protection (280.20(a)(5)) Specify: 3. Have repairs been conducted on any tank? Yes No Tank #: Repair Date: a. Were repairs to tanks conducted in accordance with accepted codes and standards? (280.33(a)) b. Were repairs to fiberglass-reinforced tanks conducted by manufacturer's authorized representatives or in accordance with accepted codes and standards? (280.33(b)) Yes No N/A Yes No N/A c. Were the repaired tanks tightness tested within 30 days of the completion of the repair (280.33(d)) unless inspected, monitored or otherwise tested? (280.33(d)(1, 2, 3)) S-p3 Yes No N/A Section B Comments: Section C Upgrading Existing Tanks to New System Standards Further Explanation in Narrative (Tanks installed on or before 12/22/88) Section C Not Applicable 1 Do the Existing Tank(s) comply with one of the following requirements: a. Are all existing tanks upgraded to meet the standards or do they already meet the stardards for New UST systems?(280.21) Yes No N/A If yes, specify tank type: b. Are all existing tanks upgraded with cathodic protection?(280.21(b))If yes, complete Yes No N/A 2. What method of corrosion protection is used for each tank? S-p8 Yes No N/A a. Metal tank retrofitted with interior lining (280.21(b)(1)) Date Lining Installed: Yes No N/A b. Is lining inspected periodically? (280.21(b)(1)(ii)) Date of Last Lining Inspection: Yes No N/A Metal tank retrofitted with cathodic protection (280.21(b)(2)) c. Type of CP: Yes No N/A If tank >10 years old when CP was added, was a tank integrity test performed? d. (280.21(b)(2)(i) S-p8 Yes No N/A EPA REGION 6 UST CEI CHECKLIST 4/16 March 9th 2017 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Type of integrity test performed: Date: e. Internal Lining combined with cathodic protection (280.21(b)(3)) If CP was not installed at same time as the lining, complete section C.2.d above. f. Other corrosion protection. Specify: Section C Comments: Yes No N/A Yes No N/A Section D Standards for New/Existing UST Piping System (Piping installed after 04/11/2016 must be secondarily contained) (Piping installed after 12/22/88) 1a. For piping installed after 04/11/2016, is it secondarily contained?(280.20) 1b. For piping installed before 04/11/2016 indicate double / single wall Further Explanation in Narrative Section D Not Applicable Yes No N/A Double Wall Single Wall 2. Is piping that routinely contains regulated substances and is in contact with the ground or water Yes No N/A designed, constructed, and protected to prevent corrosion? (280.20(b) new/ 280.21(c) existing) S-p8 3. What method of corrosion protection is used for the piping? S-p8 a. Fiberglass-reinforced plastic piping -FRP (280.20(b)(1)) Yes No N/A b. Non-metallic flexible piping (280.20(b)(4)) Type: Yes No N/A c. Constructed of metal and cathodically protected e.g. coated w/dielectric material, metal piping with anodes, or metal piping with impressed current system. (280.20(b)(2)) Specify: Yes No N/A d. Metal piping without additional corrosion protection measures. (280.20(b)(3)) Specify: Yes No N/A e. Records available to document Corrosion Protection is not necessary. (280.20(b)(3)(ii)) Yes No N/A 4. Are all metal components (flexible connectors, submersible turbine pumps) that routinely contain regulated substances and are in contact with the ground or water designed, constructed, and protected to prevent corrosion? (280.20(B)) S-p8 Yes No N/A a. Constructed of metal and cathodically protected e.g. coated w/dielectric material, metal componets protected with anodes or an impressed current system, contained in dry sumps. (280.20(b)) Specify: Sacrificial Anodes Yes No N/A b. Metal piping components without additional corrosion protection measures. (280.20(b)(3)(ii)) Specify: Yes No N/A 5. Are all impact valves (shear valves) properly installed (moving parts unobstructed, shear valve properly anchored)? (NFPA 30A Chapter 6 Paragraph 3.9) Yes No N/A 6. Have repairs been made to any piping? Yes No Associated tank # ________ Date of repair ____________ a. Were any metal pipe sections or fittings that released product replaced? (280.22(c)) Yes No N/A c. Was the repaired piping tightness tested within 30 days of the completion of the repair (280.33(d)) unless inspected, monitored or otherwise tested? (290.33(d)(1, 2, 3))S-P3 Yes No N/A Section D Comments: b. Were fiberglass pipes and fittings repaired in accordance with manufacturer's specifications? (280.33(c)) Yes No N/A d. Was 50 percent or more of the piping replaced with DW piping during the repair? Yes No N/A EPA REGION 6 UST CEI CHECKLIST 5/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Section E Spill and Overfill for New/Existing UST Systems Further Explanation in (UST systems installed after 12/22/88 are considered new) Narrative Section E Not Applicable 1. Is each tank equipped with Spill Prevention Equipment to prevent a release of product when the transfer hose is detached from the fill pipe? (280.20(c)(1)(i); 280.20(d)) S-p1 Yes No N/A a. Does the spill prevention equipment have liquid tight sides and bottom (not cracked or broken)? (280.20(c)(1)(i)) S-P1 Yes No N/A b. Spill equipment construction c. For double walled spill buckets, is the spill prevention equipment interstitially DW SW monitored? Yes No N/A d. If not interstitially monitored or if single wall, has the spill prevention equipment been tested within the last 3 years? (Required after 10/13/15 for new/replaced; by 10/13/18 for existing. (280.35) Date: Method: Yes No N/A e. Is the spill bucket free of liquids, so that it will contain any overfill? Yes No N/A f. Has the spill bucket check been conducted every 30 days? (280.36(a)(1)(i) Required by 10/13/2018 Unless exception used, explain in comments Yes No N/A g. Has the spill prevention equipment been repaired/replaced since the previous inspection? Replace / Repair Date: See Comments Yes No N/A 2. Is each tank equipped with Overfill Prevention Equipment? (280.20(c)(1)(ii)). S-p2 Yes No N/A 3. Is the Overfill Prevention Equipment designed to: S-p2 a. Automatically shut off flow to the tank when the tank is no more than 95% full? e.g. butterfly valve (280.20(c)(1)(ii)(A)) (device not tampered with or inoperable) Yes No N/A b. Alert transfer operator when tank is no more than 90 % full by restricting flow into the tank (ball float valve) or triggering a high-level alarm (overfill alarm)? (Is the alarm Ball Float Overfill near the fill port? Does it work? If No, explain in Comments) (280.20(c)(1)(ii)(B)) Yes No N/A c. Restrict the flow 30 minutes prior to overfilling or alert the operator one minute before overfilling? (280.20(c)(1)(ii)(C)) d. If ball float valves are used, is the piping system pressurized. Ball float valves are not Yes No N/A allowed for use on suction piping delivery systems (PEI/RP100-2005, Chapter 7.3.3 for New Systems; PEI/RP100-2005, Chapter 7.3.3 for Existing Systems) Yes No N/A 4. Alternative type of Spill or Overfill Prevention Equipment being used? (280.20(c)(2)ii)) Specify: 5. Has the overfill equipment been tested within the past 3 years? Required after 10/13/15 for new/replacement installation, 10/13/18 for existing installations (280.35) Date: Yes No N/A Yes No N/A Section E Comments: Flapper valves installed on 4/15/2016. Need updated Notification to reflect change. SECTION F (installed after 4/11/2016) Section F Under-Dispenser Containment ) (UDC) (Dispensers installed after 4/11/2016) Further Explanation in Narrative Section F Not Applicable 1. For dispensers installed after 4/11/2016 (280.20(f)) or those installed after 10/18/15with IM: Yes No N/A a. Is each new dispenser at a new facility equipped with UDC? b. Is each new dispenser at an existing facility where new pipe (50% or greater) was added to connect the new dispenser to the existing system equipped with UDC? Yes No N/A Yes No N/A C. Is each replacement dispenser at an existing facility where piping (50% or greater) that connects the dispenser to the existing piping is replaced equipped with UDC? Yes No N/A EPA REGION 6 UST CEI CHECKLIST 6/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe 2. Does each UDC sump subject to the 4/11/2016 UDC requirements or installed utilizing IM after 10/13/15 have liquid-tight sides and bottom, and is it maintained free of storm water, debris and regulated substances? (280.20(f)) Yes No N/A 3. If UDC is being used for IM, have the UDC's been tested within 3 (three) years? (Effective for new UDC 4/11/2016 and existing UDC's No Later Than 10/13/18) Yes No N/A Section F Comments: SECTION G (installed after 10-13-2015) Section G Submersible Turbine Pump (STP) Secondary Containment Further Explanation in Narrative Section G Not Applicable 1. For submersible turbine pumps installed after 4/11/16 (280.20) a. Is each new STP at a new facility equipped with liquid tight containment? b. Is each new STP at an existing facility where a new pipe run was added to connect the new STP to the system equipped with liquid tight containment? (280.35(a)(1)) c. Is each replacement STP at an existing facility, where 50% or more of the piping is replaced that connects the STP to the system, equipped with liquid tight containment? (280.35(a)(1)) Yes No N/A Yes No N/A Yes No N/A Yes No N/A 2. Does each STP containment sump subject to the 10/13/2015 STP Secondary Containment requirements have liquid-tight sides and bottom, and maintained free of storm water, debris, and regulated substances? (303.D.5.b) Yes No N/A 3. Are the STP sumps used for piping Interstitial Monitoring? 4. Have STP containment sumps used for IM been tightness tested in the last 3 years (10/13/15 new, No Later Than 10/13/18 existing) Section G Comments: Yes No N/A Yes No N/A Section H Operation and Maintenance of Corrosion Protection Systems Further Explanation in Narrative Section H Not Applicable 1. Is the corrosion protection system continuously operated and maintained to provide corrosion protection to metal components of external portions of the tanks and piping that routinely contain regulated substance and are in contact with the ground or water? Yes No N/A (280.31(a)) S-p5 2. Are the cathodic protection systems inspected by qualified testers?(280.31(b)) S-p5 Yes No N/A 3. Was the cathodic protection system tested within six months after installation? (280.31(b)(1)) Date: S-p4 Yes No N/A 4. Is the system tested at least every three years? (280.31(b)(1)) Date: 09/16/2015 Yes No N/A 5. Does the inspection meet the requirements of a code of practice developed by a nationally recognized association? (280.31(b)(2)) Yes No N/A 6. As outlined in 280.31(b), does the facility have copies of the last two CP inspections? (280.31(d)(2)) Yes No N/A 7. If the UST system has an impressed current, is the rectifier inspected every 60 days (280.31c) S-p6 Yes No N/A 8. As outlined in EPA regulations, does the facility have copies of the last three rectifier inspections? ((280.31(d)(1)) Yes No N/A EPA REGION 6 UST CEI CHECKLIST 7/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe 9. Was the cathodic protection system tested within six months of a repair?(280.33(e)) S-p4 Yes No N/A Section H Comments: SOC - Release Detection Section I Release Detection Requirements for UST System Further Explanation in Narrative Section I Not Applicable 1. Does the facility perform a method of release detection? Check "No" if no release Yes No N/A detection conducted (280.40(a)) S-D1 2. Is the method of release detection capable of detecting a release from any portion of the Yes No N/A tank that routinely contains product? (280.40(a)(1)) S-D2 3. with the manufacturer's instructions including routine maintenance, etc.?(280.40(a)(2)) Is the release detection system installed, calibrated, operated, and maintained in accordance Yes No N/A Does the release detection system meet the performance standards outlined in 280.43 or 4. 280.44? (Check third party certification against equipment or method present)((280.40(a)(3)) Yes No N/A S-D 3 5. Are all USTs monitored at least every 30 days for releases? (280.41 (a)). S-D 5 Yes No N/A Is UST systems subject to the 4/11/16 Secondary Containment Requirements: 6. (Interstitial Montoring) a. Portions of UST system using IM: Tanks Piping Spill Buckets Yes No b. Are monthly records available to verify no leaks to interstice or the environment from tanks? Yes No N/A c. Are monthly records available to verify no leaks to interstice, sump or the environment from piping? Yes No N/A 7. Has Annual testing/inspection of release detection equipment (ATG, probes/sensors, ALLD - simulating lead, vacuum/pressure guages, hand held equipment) been conducted? (280.40(a)(3) required No Later Than 10/13/18 Yes No N/A Section I Comments: Section J Release Detection Record Keeping Further Explanation in Narrative Section J Not Applicable 1. As outlined in 280.34 does the facility maintain all written performance claims and documentation provided by the release detection vendor for 5 years? (280.45(a)) Yes No N/A 2. As outlined in 280.34, does the facility maintain all monitoring results, sampling records, S-D5 equipment testing, calibration and maintenance records, or leak detection equipment repair Yes No N/A records for at least one year? (280.45(b) and (c)) Specify: Binder on Site 3. As outlined in 280.43(c), are all tank tightness-testing records retained until the next test is conducted? ((280.45(b)) 4. As outlined in 280.34, are schedules of required calibration and maintenance for release detection equipment retained for 5 years from date of installation? ((280.45(c)) 5. Are records available to verify water levels in the tanks are checked monthly to 1/8th inch? (280.43(a)(6) Section J Comments: Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 8/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe Section K Release Reporting Suspected Releases Further Explanation in Narrative Section K Not Applicable When a release detection method indicates that a release may have occurred; has the 1. facility notified EPA/State of a suspected release? (280.40(b) and 280.50(c)) S-D4 Yes No N/A Has the facility notified the department of any other suspected release (regulated 2. substance discovered, unusual operating conditions)? (280.50(a) or (b)) Yes No N/A Facility has resolved suspected releases in accordance with procedures outlined in 3. 280.52? S-D4 Yes No N/A Spills and Overfills Has the facility reported, investigated, and cleaned-up any spills and overfills as 1. required by 280.52 through 280.67 Yes No N/A Section K Comments: Section L Release Detection Methods for Tanks (Fill out only the applicable sections, all others can remain blank) Further Explanation in Narrative Section L Not Applicable Inventory Control with Tank Tightness Testing (280.41(a)(1)) S-D5 1. INSTALLED ON or BEFORE 4/11/16 a. Are inputs, withdrawals, amounts in tank recorded daily or on each operating day? (280.43(a)(1)) Yes No N/A b. Is the measuring equipment capable of measuring the level of the product over the full range of the tank's height to the nearest one-eighth of an inch? (280.43(a)(2)) Yes No N/A c. Are inputs reconciled with delivery receipts? (280.43(a)(3)) Yes No N/A d. Are deliveries made through a drop tube which extends to within 1foot of bottom? (280.43(a)(4)) e. Are measurements of water level made to the nearest 1/8 inch at least once a month?(280.43(a)(6)) f. Is the TTT conducted every 5 years as required and is TTT method capable of detecting a 0.1 gal/hr leak rate from any portion of the tank routinely containing product? (280.41(a)(1)) Date of Last Tank Tightness Test: Yes No N/A Yes No N/A Yes No N/A g. TTT conducted following the manufacturer's instructions or third party certification. (280.43(c)) h. Within the 10 year time frame for using IC/TTT? (280.41(a)(1)) Expiration Date: Yes No N/A Yes No N/A 2. Manual Tank Gauging (MTG) (tanks <2000 gal) (281.43(b)) S-D5 Deadline date: a. If tank is >550 gal and < 2000 gal, is tank tightness being conducted every 5 years? (280.41(a)(1)) Date of last tank tightness test: b. Tank size is appropriate for using MTG (280.43(b)) c. Method is being conducted properly (280.43(b)(1) through (5)) d. No liquid is added to or taken out of tank during test. (280.43(b)(1)) e. Equipment is capable of 1/8-in measurement (280.43(b)(3)) f. Within the 10 year time frame for using MTG/TTT for tanks between 550 and 2000 gallons? (280.41(a)(1)) Expiration Date: Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 9/16 March 9th 2017 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe 3. Automatic Tank Gauging (ATG) (280.40(a)&280.43(d)) S-D5 INSTALLED ON or BEFORE 4/11/16 Make and Model: Gilbarco EMC Probe Type: Mag Plus a. Is the ATG capable of detecting a leak of 0.2 gal/hr leak rate? (280.43(d)(1)) S-D3 Yes No N/A b. As the sole method of release detection, the ATG must test the tank at least once per Yes No N/A month in a manner that can detect a 0.2 gal/hr release with a pd > 0.95 and a pfa < 0.05 (280.40(a)(3)) c. The ATG will generate a hard copy which contains the following: S-D3 i. the time and date of the test Yes No N/A ii. the tank identification Yes No N/A iii. the qualitative result either "pass" or "fail" Yes No N/A d. Type of test conducted Tanks 1&2 TT/Tanks 3-6 CSLD 4. External Release Detection Devices a. General Requirements for Release Detection Devices S-D5 INSTALLED ON or BEFORE 4/11/16 i. Do the RDDs meet the general requirements for construction? (280.43(e)(1) &(6) and (f)(7)-(8) ii. RDDs screened from 1 ft below the surface throughout the entire excavation zone? Yes No N/A (280.43(e) & (f)) Yes No N/A iii. Are the RDDs sealed and locked? (280.43(e)(7) and (f)(8)) iv.Are the RDDs installed in backfill? (280.43(e)(1) and 280.43(f)(2)) Type of backfill: Yes No N/A Yes No N/A v. Are RDDs in the correct number and properly positioned? (280.43(e)(6) and (f)(7)) Yes No N/A vi. Does the facility have the paperwork to confirm that the release detection method was properly assessed? (280.45(a) Required After Oct 13, 2018 Yes No N/A b. Vapor Monitoring (280.43(e)) S-D5 INSTALLED ON or BEFORE 4/11/16 i. Is the regulated substance (or tracer) sufficiently volatile to allow vapors to be detected by the monitoring device? (280.43(e)(2)) ii. Vapor monitoring is not affected by high ground water, rainfall, etc. (280.43(e)(3) iii. Does background concentration in excavation zone interfere with method used? (280.43(e)(4)) iv. Is the monitoring device designed and operated to detect any significant increase in concentration above background? (280.43(e)(5)) Yes No N/A Yes No N/A Yes No N/A Yes No N/A c. Groundwater Monitoring (280.43(f)) S-D5 INSTALLED ON or BEFORE 4/11/16 i. Is regulated substance immiscible in water and have a specific gravity less than one? (280.43(f)(1) ii. Water in the monitoring well is never more than 20 feet from the ground surface? (280.43(f)(2)) iii. Does RDD prevent migration of soils into RDD, and can regulated substance enter RDD in both low and high water conditions? (280.43(f)(3)) iv. If RDD installed in native soil, is hydraulic conductivity greater than 0.01 cm/sec? (280.43(f)(2) Yes No N/A Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 10/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe v. Can continuous monitoring device or manual method detect 1/8-in of free product? (280.43(f)(6)) Yes No N/A 5. Interstitial Monitoring (280.43(g) S-D5 REQUIRED FOR TANKS INSTALLED AFTER 4/11/16 a. Describe the UST system which uses IM e.g. double walled tank, secondary barrier: Explain: Yes No N/A b. Can the method detect a release through the inner wall of the tank? (280.43(g)(1) or (3) S-D2 Yes No N/A c. Continuous interstitial monitoring by an automatic leak sensing device that signals to the operator the presence of any regulated substance in the space or sump (701.A.6.a) Yes No N/A Method: OR ii. Manual interstitial monitoring every 30 days by means of a procedure capable of detecting the presence of any regulated substance in the interstitial space or sump (701.A.6.a) Specify Method: Yes No N/A 6. Statistical Inventory Reconciliation(SIR)(280.43(h)) S-D5 For Tanks INSTALLED ON OR BEFORE 4/11/16 a. Can the SIR method detect a release of 0.2gal/hr from any portion of the UST System that routinely contains product with a pd > 0.95 and a pfa < 0.05? (280.43(h)(1)) Did the owner/operator receive the monthly report(s) from the SIR provider/ b. vendor within the 30 day monitoring period? (280.43(h)) c. Did the SIR analysis report include the following information: i. the name of the SIR provider and the name and version of the SIR method; ii the name and address of the facility at which the analysis was performed; iii. a description of the UST system for which the analysis was performed; iv. a quantitative statement, in gallons/hr, for each UST system monitored for the month, of the leak threshold, minimum detectable leak rate, and the indicated leak rate; v. a qualitative statement of "pass," "fail," or "inconclusive" for each UST system monitored Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A d. Method Name: Version: 7. Other Method: (280.43(h)) Specify Method: a. Method can detect 0.2 gal/hr leak rate or a release of 150 gal within a month; & meet the 95/5 probability requirement. (280.43(h)) OR S-D3 b. EPA has approved the method as being as effective as Tank Tightness testing, ATG, vapor monitoring, ground water monitoring, or interstitial monitoring and operator complies with any conditions imposed by the agency. (280.43(h)) Section L Comments: Yes No N/A Yes No N/A Tank Tightness Testing being done on Tanks 1 & 2 (Need updated Notification showing accordingly) EPA REGION 6 UST CEI CHECKLIST 11/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA INSPECTION DATE(S): 02/27/2018 FACILITY NAME: Feather Fuels Tribal Land: Coushatta Tribe Section M Methods of Release Detection for Piping Section M Not Applicable Further Explanation in Narrative Is release detection performed on the UST system's piping? (280.41(b)) Check the appropriate piping system. Yes No N/A 1. Pressurized Piping S-D5 a. Which of the following methods of leak detection does the facility use for pressurized piping? (280.41(b)(1)) i. Automatic Line Leak Detectors (ALLD) installed (one of the following methods is required on all pressurized lines, regardless of line leak detection method used) (280.41(b)(1)(ii)) Yes No N/A MODEL: Red Jacket 1. Automatic flow restrictor, or 2. Automatic shutoff, or MECHANICAL ELECTRONIC Yes No N/A Yes No N/A AND OR 3. Continuous audible or visual alarm Yes No N/A 4. Is a test conducted every 12 months on the line leak detector which simulates a leak according to manufacturer's requirements? (280.44(a)) Date of last test: 3/3/18 Yes No N/A 5. Are records available for performance test for previous 2 years. (starting 10/13/18, 3 years required) Yes No N/A 6. If Electronic, a 3gal/hr test with a PASS or other rate as specified by Manufacturer annually. (Not acceptable after 10/13/2018) Yes No N/A ii. One other method (280.44(b)) (Only appliable if installed on or before 4/11/2016, must use IM afterwards.) S-D5 1. A line tightness test conducted every 12 months (280.44(b)); Dates of last test: S-D5 3/3/2018 Yes No N/A 2. Is LTT method capable of detecting a 0.1 gal/hr leak rate from any portion of the piping routinely containing product? (280.44(b)) S-D3 Yes No N/A 3. If Electronic, is a 0.1 test with PASS conducted annually (280.44(b)) S-D5 Yes No N/A 4. Monthly monitoring? (280.44(c)) Specify Type: S-D5 Yes No N/A 5. If Electronic, is a 0.2 test with PASS conducted monthly (280.44(b)) S-D5 Yes No N/A REQUIRED FOR Piping INSTALLED or REPLACED (>50% TOTAL) AFTER 4/11/16 b. Is Interstitial Monitoring Secondary Containment requirements used (303.D.2.f.i), by either: i. Continuous interstitial monitoring by an automatic leak sensing device that signals to the operator the presence of any regulated substance in the interstitial space or sump Yes No N/A (701.B.4) Must have monthly documentation. Specify Method: OR ii. Manual interstitial monitoring every 30 days by means of a procedure capable of detecting the presence of any regulated substance in the interstitial space or sump (701.B.4) Yes No N/A Specify Method: c. For piping subject to the 4/11/16 Secondary Containment requirements, is all piping interstitial space and/or are all sumps maintained free of water, debris, or anything that could interfere with the leak detection capabilities? (701.B.4.a) Yes No N/A 2. Suction Piping S-D5 a. Which of the following leak detection methods does the facility use for suction piping? (280.44(b)) i. (Safe Suction) No release detection is required if piping is sloped to drain product back into tank and only one check valve is present and located directly below or as close as practicable to the suction pump (280.41(b)(2)) -must have documentation Yes No N/A OR ii. Line tightness test every 3 years? (280.41(b)(2)) Date of last test: Yes No N/A EPA REGION 6 UST CEI CHECKLIST 12/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe OR iii. Monthly monitoring? (280.41(b)(2)) Specify Type: Section M Comments: Yes No N/A Section N Requirements for Temporary Closure (280.70) Further Explanation in Narrative 1. For UST systems in temporary closure; has the facility: a. If greater than 1 inch of liquids remain, is monthly release (280.70(a)) Specify Type of RD performed tanks and piping: b. If applicable, is the Cathodic Protection being maintained? (280.70(a)) Section N Comments: detection Section N Not conducted? Yes S-D7 Yes Applicable No N/A No N/A NON-Significant Operational Compliance Components Section O Temporary Closure Continued Further Explanation in Narrative 1. For UST systems temporarily closed for 3 months or more, did the owner/operator: Not Applicable a. Leave vent line open and functional? (280.70(b)(1)) Yes No N/A b. Cap and secure all other lines, pump, manways, and ancillary equipment? (280.70(b)(2)) Yes No N/A c. Notify the E.P.A of the temporary closure status (UST-REG-01 form)? (280.70(b)(1)) Yes No N/A d. Perform a tank tightness test within five days after the system was brought back into service after being in temporary closure 3 months or more? (903.E) Yes No N/A 2. For any non-upgraded UST system that has been temporarily closed for more than 12 months, has the owner/operator permanently closed the system? ((280.70(c)) Yes No N/A Section O Comments: Section P Additional Paperwork Requirements Not Applicable Further Explanation in Narrative 1. Is the information on the Notice of Registration form current and accurate? (280.22)) 2. Has an amended Registration form been submitted within 30 days of acquiring a UST? (280.22)) 3. Is a copy of the current registration form kept on-site or at the nearest staffed facility? (Not Required.) 4. Has the owner/operator submitted the following information to the department: a. Registration form for all UST systems, including installation certification and installer verification for new tank systems (280.22) b. Reports of all releases, suspected releases, spills and overfills, and confirmed releases (280.34(a)(2)) Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A EPA REGION 6 UST CEI CHECKLIST 13/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe c. Descriptions of corrective action plans, site characterizations, free product removal investigation of soil and groundwater cleanup, and corrective action plan (280.34(a)(3)) d. Notification before permanent closure or change-in-service (280.34(a)(4) e. If new ownership, has a notification of ownership change been submitted within 30 days of acquiring a UST? (280.22)) f. Has notification of a change of storage to regulated substances blended wih greater than 10% ethanol or greater than 20% biodiesel been provided to agency 30 days before beginning storage? (280.32(b)) 5. Has the owner/operator maintained the following documents: a. Results of site assessment conducted at permanent closure (280.34(a)(5) b. Documentation of UST system repairs (280.34(b)(3)) c. Documentation of the type and construction of the tanks, piping, leak detection equipment, corrosion protection equipment, and spill and overfill protection equipment? d. Assessment of suitability for groundwater or vapor monitoring as release detection method. Retain while in use. (Copy of assessment must be available as of 10/13/18) (280.45(a)) e. Three year testing of release prevention equipment and containment sumps, and inspection and/or testing (ball floats, and overfill protection devices). Retain for three years. (280.35(c)(1) f. Annual testing of release detection equipment. Retain for 3 years. (280.45(b)(1) g. Checklists for Monthly walk thru inspections. Checklists contain dates, findings and actions taken. Retain for 1 year. 280.36(b) h. Annual walk thru inspection checklists for RD. Retain for 1 year. 280.36(b) 6. Was the facility able to provide the records in a timely fashion as required by the inspector? (280.34(c) Section P Comments: Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Section Q General Requirements Not Applicable Further Explanation in Narrative 1. Are the products being stored compatible with the materials or liner in the UST system? (280.32) Yes No N/A 2. Documentation of compatibility for fuel with >10% ethanol, >20% biodiesel, or another fuel designation by implementing agency. Retain as long as fuel is used. (280.32(b)(2)) Yes No N/A Section Q Comments: Section R Financial Responsibility Not Applicable Further Explanation in Narrative 1. Can the owner/operators demonstrate financial responsibility for taking corrective action, including 3rd party liability? i.e: how is he going to pay for the cleanup of a release? Yes No N/A (280.94 -280.99)Records - 280.111 What type of financial responsibility is used? Explain: Commerial 2. If Insurance, list company and contact: Ace American Insurance Company Policy Number: G28137655 002 3. Insurance Mailing Address: PO Box 1000, 436 Walnut Street, Philadelphia, PA, 19106 Contact Number: NA E-mail: NA Effective Date of Coverage: 07/01/2017 Expiration Date on Policy: 07/01/2018 Retroactive Date: NA Confirmed Released Policy: Suspected Release Policy: EPA REGION 6 UST CEI CHECKLIST 14/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 FID #: 0365LA FACILITY NAME: Feather Fuels INSPECTION DATE(S): 02/27/2018 Tribal Land: Coushatta Tribe 3. Financial Assurance Documentaion a. Copy of Signed Certification of Financial Responsibility available and current. b. Copy of signed Certitficate of Insurance or Endorsement. Yes No N/A Yes No N/A Section R Comments: Section S Compliance Not Applicable Further Explanation in Narrative Has the facility complied with all of the regulations or any order issued by the implementing agency? If not, this constitutes a violation of the Act. Enforcement Tracking # of Order not in Yes No N/A compliance with: Section S Comments: Operator Training DESIGNATED CLASS A AND CLASS B USTOPERATORS FOR THIS FACILITY: Class A UST Operator: Mailing Address: Class B UST Operator: Mailing Address: Class C UST Operator: Mailing Address: Class C UST Operator: Mailing Address: Comments on Operator Training: (Address) (Address) (Address) (Address) Phone: Phone: Phone: Phone: Date Certified: (City) (State) Date Certified: (City) (State) Date Certified: (City) (State) Date Certified: (City) (State) N/A (Zip) (Zip) (Zip) (Zip) EPA REGION 6 UST CEI CHECKLIST 15/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 Digital Image Log FID #: 0365LA FACILITY NAME: Feather Fuels Image File Date # # ##/##/#### Time 1 2 3 4 5 6 7 8 9 10 11 13 14 15 AM / PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM INSPECTION DATE(S): 02/27/2018 Camera type and ID Orientation Photographer N/E/S/W/Down Description No Photos Taken I certify that the digital images for this inspection were taken and archived according to EPA standard operating procedures and protocols. The digital images have not been altered and are a fair and accurate representation of observations made during the inspection. I certify that the digital media has been in my possession throughout the inspection trip and that I transferred the digital images to a CD-R. Yes No Inspector: Inspector Signature:__________________________________________ EPA REGION 6 UST CEI CHECKLIST 16/16 Note: All questions are to be answered. If unable to determine, write `unknown' and explain in narrative. Use narrative / summary of findings area to describe all areas of concern in greater detail. R6USTCEIForm-001-R0 Attachment Documents A1: Facility Diagram A2: Digital Images A3: Observation Report A4: R6USTCEIForm-001-R0 FID# 0365LA Inspection Date 02/27/2018 Facility Name Feather Fuel FIGURE 1 - SITE AERIAL A1-1 FID# 0365LA Inspection Date 02/27/2018 N Facility Name Feather Fuel Tank 1 12,000 gallons Composite Regular Gasoline No Ethanol Tank 2 12,000 gallons Composite Regular Gasoline No Ethanol Tank 3 12,000 gallons Composite Premium Gasoline Tank 4 12,000 gallons Composite Diesel Pump Fill Port ATG Port FIGURE 2 - TANK DIAGRAM Feather Fuel Facility ID: 0365LA Vapor Recovery Port Interstitial Monitoring Tank Vent Line Construction: Date Created: Ball Float Valve Regular NE Premium Diesel Regular<10% NOT TO SCALE A1-2 FID# 0365LA Inspection Date 02/27/2018 Facility Name Feather Fuel Tank 5A 4,000 gallons N Composite Regular Gasoline No Ethanol Tank 6A 8,000 gallons Composite Diesel Pump Fill Port ATG Port FIGURE 2 - TANK DIAGRAM Feather Fuel Facility ID: 0365LA Vapor Recovery Port Interstitial Monitoring Tank Vent Line Construction: Date Created: Ball Float Valve Regular NE Premium Diesel Regular<10% NOT TO SCALE A1-3