Document wgXoxYaOK3eBz4nQVdZqjrRX3

Compliance Evaluation Inspection Report Oyate General Store June 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 68HERC23F0460 COMPLIANCE EVALUATION INSPECTION REPORT Date of Report: June 19, 2024 Date and Time of Inspection: May 2, 2024, at 2:00 pm MST Weather: Clear and sunny, 56 Fahrenheit Facility Contact/Owner: / Oglala Sioux Tribe Owner Address: P.O, Box 363 Pine Ridge, SD 57770 Facility Address: 29117 US Hwy 18 Oglala, SD 57770 Facility Phone: Facility ID Number: 4070028 Reason for Inspection: Compliance Inspection Inspector(s): , ERG (Lead) , ERG , ERG Oyate General Store CEI Report ii June 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: ATTACHMENT H: EPA REGION 8 UST COMPLIANCE CHECKLIST PHOTOGRAPH LOG TANK LEAK DETECTION RECORDS & ALARM REPORT PIPING LEAK DETECTION RECORDS & ATG CERTIFICATION CATHODIC PROTECTION TESTING RECORDS WALKTHROUGH INSPECTION RECORDS FINANCIAL ASSURANCE DOCUMENTATION NOTICE OF INSPECTION Oyate General Store CEI Report iii June 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 68HERC23F0460, provided assistance to EPA in preparing for, conducting the inspection, and preparing this inspection report. ERG inspected the Oyate General Store facility in Oglala, South Dakota on May 2, 2024. The facility was last inspected on June 16, 2021. Mr. , contract inspector, contacted , representative of Oyate General Store, via telephone on March 28, 2024, to notify the facility about the inspection 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, Mr. introduced himself as a contract inspector for EPA, presented his credentials, and provided an in-brief to , a cashier at Oyate General Store, to explain the purpose of the inspection. Ms. left and was replaced by , also a cashier, partway through the inspection. The inspection team (Mr. , Ms. , and Mr. ) gathered records, interviewed Ms. and Ms. , and conducted a walkthrough of the site including access ports. Mr. concluded with an exit brief and had Ms. sign the Notice of Inspection. Mr. took photographs during the inspection. UST System Description The Oyate General Store facility, located at 29117 US Hwy 18 in Oglala, SD, has one UST. According to the previous EPA inspection report and observations made during the inspection, the tank has a 12,000-gallon capacity and contains regular unleaded gasoline. The tank is STI-P3 construction, but it is unknown whether the tank is double-walled or single-walled. The dispensing system for the tank is pressurized piping with fiberglass-reinforced plastic (FRP) construction. The inspection team completed an EPA Region 8 UST Compliance Inspection Checklist for the USTs while on site which is included in Attachment A. Photograph #6 in Attachment B shows some of the dispensers and an overview of the UST systems. UST System Records The listing of documents reviewed for the Oyate General Store inspection included the following: 1. UST Leak Detection Records and Alarm Report 2. Automatic Tank Gauging and Line Leak Detection Test Records 3. Cathodic Protection Records 4. Walkthrough Inspection Records 5. Financial Assurance Record The facility maintained the available records on site. Employees on site provided the records for the USTs during the inspection. Oyate General Store CEI Report 1 June 2024 Tank Release Detection Releases from the tank are detected by a Franklin Fueling Systems INCON TS-750 Tank Sentinel monitoring system and associated in-tank probe that conducts automatic tank gauging (ATG) of the tank. Attachment C contains a compilation of the available ATG static leak test results for the months of April 2023 through April 2024. The leak test results were only available for six of the previous 12 months, and each of the test results showed a passing leak test. During the inspection, Ms. also informed the inspection team that the ATG system recently started to have issues and was not operating properly. The ATG also printed an alarm report that indicated there was "No Probe Detected" at the time of the inspection (included in Attachment C). Photograph #1 in Attachment B shows the monitoring system interface as well as the printout of the alarm report. Ms. stated that they manually gauge the tank once per day in the morning in order to determine the level. The most recent test for the ATG system occurred in June 2021 according to available records on site. Attachment D includes the passing test record from 2021. Piping Release Detection The tank is installed with pressurized FRP piping, and it is uncertain whether the piping is double-walled or single-walled. The piping is attached to a submersible turbine pump (STP), which is equipped with a mechanical line leak detector (LLD). The LLD was observed on the STP during the inspection. The LLD was most recently tested in June 2021 based on available records. The contractor also performed line tightness testing for the piping (assumed to be June 2021 as well based on contractor name and other documentation, though no date was provided directly on the test form). Attachment D includes the passing test records for the LLD and line tightness testing in June 2021. Photograph #5 in Attachment B shows the STP sump for the tank. The STP sump had mud present up to a level that nearly covered the entire STP. Piping leading to the dispenser from the sump could not be observed due to the mud level. Spill/Overfill Prevention The fill pipe for the UST has a spill bucket surrounding the pipe and a flapper valve in the drop tube. Photographs #2 and #3 in Attachment B show the fill port and spill bucket for the UST. The spill bucket appeared to have approximately three inches of liquid, which appeared to be a mixture of water and product or dirt, present at the time of the inspection. The flapper valve and fill port otherwise appeared in good condition. Oyate General Store did not have test records for the spill and overfill prevention equipment on site at the time of the inspection. Corrosion Protection The tank is single-walled STI-P3 construction, and cathodic protection testing records were available on site from June 2021. Cathodic protection records were not available for any testing prior to 2021. The UST passed cathodic protection tests in June 2021. Attachment E includes the cathodic protection records from the June 2021 test. Oyate General Store CEI Report 2 June 2024 Operator Training No operator training records were provided while onsite. Ms. stated that they do receive training as employees, but it was uncertain whether the training encompassed UST operator requirements. Walkthrough Inspections Oyate General Store had monthly walkthrough inspection records for October, November, and December of 2023, with no issues noted. There were no records of walkthrough inspections conducted for any other months, and annual walkthrough inspections were also not available onsite. Attachment F includes the record for the three months of walkthrough inspections. Financial Assurance Oyate General Store is registered with the state of South Dakota and is covered under the state trust fund. Oyate General Store did not have documentation for covering the $10,000 deductible from the state trust fund. Attachment G includes the state trust fund notification for Oyate General Store. Physical Inspection During the site visit, the inspection team reviewed documents on site and observed the fill port, STP access port, ATG probe, and the ATG monitoring interface for the UST onsite. Photograph #1 in Attachment B shows the interface for the Franklin Fueling Systems INCON TS-750 Tank Sentinel ATG system. The ATG system indicated an alarm that no probe was detected, and tank inventory and leak detection capabilities were not possible at the time of the inspection. The inspection team also observed the spill bucket and fill pipe for the UST. The spill bucket contained approximately three inches of water and sludge material (either product or dirt) but was otherwise in good condition. The drop tube contained the flapper valve. The inspection team also observed the STP sump for the UST. The STP sump had excess mud that nearly covered the STP, and the piping connections were not visible due to the mud. The STP did have a mechanical LLD present. The access ports for the ATG probe was also present, and the ATG port was filled with mud and soil to a high level, though the probe was still seen (see Photograph #4, Attachment B). There were two double-sided pump dispensers on site, but the Oyate General Store representatives stated they did not know where the key was located to open up the dispensers. No monitoring wells were observed at the tank field during the inspection. The vent line is located southeast of the USTs along the building, and no obstructions or concerns were noted for the vent line at the time of the inspection. Oyate General Store CEI Report 3 June 2024 2. SUMMARY The facility has one tank with STI-P3 construction that was installed in October 1999. The tank has a 12,000-gallon capacity and contains regular unleaded gasoline. Passing monthly leak detection test records were available for six of the previous 12 months (May 2023 through April 2024). An annual certification for the ATG system was only available from June 2021. The ATG system was not operating properly at the time of the inspection and had an alarm indicating "No Probe Detected." There are two double-sided dispensers on site that operate with pressurized FRP piping. The STP for the pressurized piping is equipped with a mechanical LLD which most recently passed operational testing (for the LLD) and line tightness testing in June 2021. Records were not available for the LLD or line tightness testing since June 2021. The fill port for the UST is equipped with a spill bucket and a flapper valve in the drop tube as the spill and overfill prevention equipment. Testing records for the spill and overfill prevention equipment were not available on site at the time of the inspection. Oyate General Store did have cathodic protection testing records for the tank from June 2021, which showed passing results. There was no cathodic protection record from prior to June 2021. Oyate General Store did not have records of UST operator trainings or certifications on site at the time of the inspection. Monthly walkthrough inspection records were provided for three months during the past year (October through December 2023), and no annual inspection walkthrough records were available. Oyate General Store is registered with the state of South Dakota and is covered under the state trust fund, but there was no documentation available for coverage of the $10,000 deductible for the state fund. Attachment H contains the Notice of Inspection signed by Ms. . Mr. provided a copy to Ms. and left the premises. Inspector Signature: Date: _June 19, 2024____ Oyate General Store CEI Report 4 June 2024