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HomeMy WebLinkAboutRA-29674_48798_CA_SCH_20221219 3502 Hayes Road • Monroe, North Carolina 28110 113 West Firetower Road, Suite G • Winterville, North Carolina 28590 Phone (704) 845-4010 • (888) 870-4133 • Fax (704) 845-4012 December 19, 2022 Mr. Mark Powers NCDEQ-UST Section Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 Re: Site Check Report Eagles 5 620 Hampton Pointe Boulevard Hillsborough, Orange County North Carolina Facility ID Number: 00-0-0000036955 Incident Number: N/A GRI Project Number: 6280 Dear Mr. Powers, Please find enclosed the referenced report for the abovementioned site. If you have any questions, please contact Ethan Rogerson at 704-845-4010. Sincerely, Geological Resources, Inc. Leslie Maxtone-Graham Administrative Assistant Enclosure Cc: Mr. Kenny Pearce; Guardian Fueling Technologies, file 3502 Hayes Road • Monroe, North Carolina 28110 113 West Firetower Road, Suite G • Winterville, North Carolina 28590 Phone (704) 845-4010 • (888) 870-4133 • Fax (704) 845-4012 Engineering Certification: C-2727 • Geology Certification: C-127 Site Check Report Eagles 5 620 Hampton Pointe Boulevard Hillsborough, Orange County North Carolina Facility ID Number: 00-0-0000036955 Incident Number: N/A GRI Project Number: 6280 Prepared for: Kenny Pearce Guardian Fueling Technologies 5116 Departure Drive Raleigh, North Carolina 27616 December 19, 2022 Ethan Rogerson, G.I.T. Project Manager William Regenthal, P.G. Report Editor ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: December 19, 2022 Eagles 5 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 6280 i EXECUTIVE SUMMARY The Eagles 5 site is located at 620 Hampton Pointe Boulevard in Hillsborough, Orange County, North Carolina. The property operates as a petroleum retail facility and convenience store. The site is covered by concrete, asphalt and grass. There are one 20,000-gallon gasoline and one 20,000-gallon compartmentalized (10,000-gallon gasoline and 10,000-gallon diesel compartments) USTs currently in use at the site with six associated dispenser islands. On December 5, 2022, GRI conducted a site check in the area of the 10,000-gallon diesel UST compartment spill bucket. One soil sample (SS-1) was collected while spill bucket repairs were being made and submitted for UVF analyses of TPH-GRO and TPH-DRO using UVF technology. All of the reported contaminant concentrations were less than the applicable standards. Based on this information, no additional assessment is warranted for this site. ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: December 19, 2022 Eagles 5 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 6280 iii ACRONYMS ACM: Asbestos Containing Materials AFVR: Aggressive Fluid-Vapor Recovery ARR: Acknowledgement of Report Receipt AS: Air Sparging AST: Aboveground Storage Tank ASTM: American Society for Testing and Materials BGS: Below Ground Surface CAP: Corrective Action Plan CFR: Code of Federal Regulations CSA: Comprehensive Site Assessment DPE: Dual Phase Extraction DRO: Total Petroleum Hydrocarbons Diesel Range Organics DWM: Division of Waste Management DWR: Department of Water Resources EPA: Environmental Protection Agency EPH: Extractible Petroleum Hydrocarbons ESA: Environmental Site Assessment GCL: Gross Contamination Level GRI: Geological Resources, Inc. GRO: Total Petroleum Hydrocarbons Gasoline Range Organics LSA: Limited Site Assessment MAC: Maximum Allowable Concentration as specified in T15A NCAC 2L.0202 MADEP: Massachusetts Department of Environmental Protection MCC: Maximum Contaminant Concentrations MMPE: Mobile Multi-Phase Extraction NAPL: Non-Aqueous Phase Liquid, “Free Product” NCDEQ: North Carolina Department of Environmental Quality NCDOT: North Carolina Department of Transportation NFA: Notice of No Further Action NORR: Notice of Regulatory Requirements NOV: Notice of Violation NPDES: National Pollutant Discharge Elimination System NRP: Notice of Residual Petroleum O&M: Operation and Maintenance PAHs: Polynuclear Aromatic Hydrocarbons PCA: Pre-Construction Assessment RAL: Regulatory Action Level SCLs: Soil Cleanup Level SPCC: Spill Prevention Control and Countermeasures SVE: Soil Vapor Extraction SVOCs: Semi-Volatile Organic Compounds SWPPP: Stormwater Pollution Prevention Plan TCLP: Toxicity Characteristic Leaching Procedure (EPA Method SW-846 1311) TOC: Top of Casing TPH: Total Petroleum Hydrocarbons USGS: United States Geological Survey UST: Underground Storage Tank UVF: Ultraviolet Fluorescence VOCs: Volatile Organic Compounds VPH: Volatile Petroleum Hydrocarbons ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: December 19, 2022 Eagles 5 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 6280 TABLE OF CONTENTS EXECUTIVE SUMMARY ....................................................................................................................... i SITE INFORMATION ............................................................................................................................ ii ACRONYMS ....................................................................................................................................... iii A. SITE HISTORY AND CHARACTERIZATION .................................................................................1 B. SITE CHECK PROCEDURES .......................................................................................................2 C. SITE INVESTIGATION ..............................................................................................................2 D. SUMMARY AND CONCLUSIONS ..............................................................................................3 E. LIMITATIONS .........................................................................................................................3 FIGURES Figure 1: Site Location Map Figure 2: Site Map Figure 3: Soil Quality Map TABLES Table 1: UST Owner/Operator Information Table 2: UST System Information Table 3: Summary of Soil Sample Analytical Results APPENDICES Appendix A: Passing Spill Bucket Results Appendix B: UVF Report – Soil Sample ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: December 19, 2022 Eagles 5 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 6280 1 A. SITE HISTORY AND CHARACTERIZATION 1. UST Owner and Operator Information: In accordance with the Site Check Report guidelines, the UST owner and operator information has been summarized in the attached Table 1. 2. UST System Information: In accordance with the Site Check Report guidelines, the UST system information has been summarized in the attached Table 2. There are one 20,000-gallon gasoline and one 20,000-gallon compartmentalized (10,000-gallon gasoline and 10,000-gallon diesel compartments) USTs currently in use at the site with six associated dispenser islands. A copy of the NCDEQ Registered Tank Report is shown below: 3. Non-UST Information: There are currently no ASTs at the site. 4. Comprehensive Description of the Release: A defective spill bucket associated with the 10,000-gallon diesel UST compartment was observed and a site check was required according to NCDEQ. On December 5, 2022, soil sample (SS-1) was collected beneath the spill bucket associated with 10,000- gallon diesel UST compartment while repairs were being completed. All reported contaminant concentrations were less than the applicable standards. ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: December 19, 2022 Eagles 5 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 6280 2 5. Description of the Site Characteristics: The Eagles 5 site is located at 620 Hampton Pointe Boulevard in Hillsborough, Orange County, North Carolina. (Figure 1). The property operates as a petroleum retail facility and convenience store. The site is covered by concrete, asphalt and grass. There are one 20,000-gallon gasoline and one 20,000-gallon compartmentalized (10,000-gallon gasoline and 10,000-gallon diesel compartments) USTs currently in use at the site with six associated dispenser islands. The surrounding properties are commercial. A Site Map has been included as Figure 2. B. SITE CHECK PROCEDURES 1. Results of Tank and Line Tightness Testing: On December 5, 2022, the spill bucket associated with the 10,000-gallon diesel UST compartment received passing test results. Copies of the passing test results are provided as Appendix A. 2. Summary of Site Check Procedure: GRI performed a site check on December 5, 2022, that included the collection of a soil sample (SS-1) beneath the spill bucket associated with 10,000-gallon diesel UST compartment while repairs were being completed. The soil sample was collected at a depth of approximately 3 feet BGS and was submitted for UVF analyses of TPH-GRO and TPH-DRO. 3. Soil Excavation Activities: No soil excavation activities were conducted. C. SITE INVESTIGATION 1. Field Screening: No field screening activities were conducted. 2. Soil Sampling Information: The reported contaminant concentrations were less than the RALs. No free product was noted at the site. A soil quality map is presented as Figure 3. A summary of soil sample analytical results is presented in Table 3. The UVF report is provided as Appendix B. A summary of the soil sampling data from the December 2022 Site Check activities is show below: Sample ID Sample Depth (ft-BGS) Gasoline-Range TPH Diesel-Range TPH RAL (mg/kg) 50 100 Soil to Water MCC (mg/kg) NE NE Residential SCLs (mg/kg) NE NE SS-1 3 13.6 23 ___________________________________________________________________________________________ Prepared by: Geological Resources, Inc. Site Check Report Prepared on: December 19, 2022 Eagles 5 Project Manager: Ethan Rogerson, G.I.T. GRI Project No. 6280 3 3. Ground Water and Surface Water Sampling Information: A ground water sample was not collected as a part of site check activities. 4. Quality-Control Measures: Clean, disposable nitrile gloves were used for the collection of the soil sample. The sample was collected and transferred for UVF analysis following proper chain-of-custody procedures. D. SUMMARY AND CONCLUSIONS  The site is commercial and surrounding properties are commercial.  On December 5, 2022, the spill bucket associated with the 10,000-gallon diesel UST compartment received passing test results.  A Site Check was conducted on December 5, 2022, to determine if a petroleum release had occurred.  One soil sample (SS-1) was collected approximately 3 feet BGS beneath the spill bucket as repairs were being completed. All of the reported contaminant concentrations were less than the applicable standards.  Based on this information, no additional assessment is warranted for this site. E. LIMITATIONS This report has been prepared for the exclusive use of Guardian Fueling Technologies for the specific application to the referenced site in Orange County, North Carolina. The assessment was conducted based on the scope of work and level of effort specified by NCDEQ and with resources adequate only for that scope of work. Our findings have been developed in accordance with generally accepted standards of geology and hydrogeology practices in the State of North Carolina, available information, and our professional judgment. No other warranty is expressed or implied. The data that are presented in this report are indicative of conditions that existed at the precise locations sampled and at the time the samples were collected. In addition, the data obtained from samples would be interpreted as being meaningful with respect to parameters indicated in the laboratory report. No additional information can logically be inferred from these data. FIGURES SITE LOCATIONFigure 1 Site Location Eagles 5620 Hampton Pointe BlvdHillsborough, North CarolinaOrange CountyIncident No. N/AGRI Project No. 6280500 M2000 FTDate: 12/13/2022Location: 36.056054° N -79.081645° W Dad TABLES UST ID Number 1 - 4 Facility ID Number Owner or Operator? Owner/Operator 00-0-0000036955 TABLE 1 UST OWNER/OPERATOR INFORMATION EAGLES 5 (INCIDENT NO. N/A) 620 Hampton Pointe Boulevard, Hillsborough, NC 27278 Unknown Name of Owner or Operator Dates of Ownership / Operation Eagles Enterprise LLC 01/20/2008 - Current Address Telephone Number Page 1 of 1 Date: 12/13/2022 Was Release Associated with UST System? (Yes / No) 1 Gasoline 20,000 2/12/2008 Double Wall FRP Unknown Other Current No 2A Gasoline 10,000 Other Current No 2B Diesel 10,000 Other Current No UnknownDouble Wall FRP2/12/2008 TABLE 2 UST SYSTEM INFORMATION EAGLES 5 (INCIDENT NO. N/A) UST ID No. Current or Most Recent Contents Capacity (gallons) Date Installed Construction Details Tank Dimensions Description of Associated Product Piping and Pumps Status of UST Facility ID #: 00-0-0000036955 Page 1 of 1 Date: 12/12/22 5030/ 8015D 3550/ 8015C Sample IDDate Collected (mm/dd/yy)Sample Depth(ft-BGS)Gasoline-Range TPHDiesel-Range TPH50 100 NE NE NE NE SS-1 12/05/22 3 13.6 23 Notes: • Results reported in mg/kg (milligrams per kilograms) • ft-BGS: feet below ground surface. • RAL: Regulatory Action Level. • MCCs: Maximum Contaminant Concentrations (soils). • SCLs: Soil Cleanup Levels. • < : Less than the method detection limit specified in the laboratory report • Concentrations in bold face type indicate the reported concentrations exceeded the soil-to-water MCCs. • Concentrations in italic type indicate the reported concentrations exceeded the residential SCLs. • NE: Not Established • NR: Not Requested. Residential SCLs (mg/kg) Analytical Method  Facility ID #: 00-0-0000036955 TABLE 3 SUMMARY OF SOIL SAMPLE ANALYTICAL RESULTS EAGLES 5 (INCIDENT NO. N/A) RAL (mg/kg) Soil to Water MCC (mg/kg) Page 1 of 1 APPENDICES APPENDIX A Passing Spill Bucket Results UST-22B Page 1 Annual Leak Detection Equipment Operability Check (Interstitial Sensors) he Testing and Verification of Spill, triggers an alarm, then you must also trigger an alarm condition. Print the alarm reports triggered during the operability check and attach to this form. If the equipment manufacturer (e.g., Veeder Root) requires a training certification to conduct operability checks of their equipment then you must be certified. business and be readily available for inspection. UST FACILITY Owner / Operator Name EAGLES ENTERPRISE LLC Facility Name EAGLES #5 Facility ID#: 00-0-0000036955 Facility Street Address 620 HAMPTON POINT Facility City HILLSBOROUGH County ORANGE CONTRACTOR/PERSON CONDUCTING INSPECTIONS Company Name GUARDIAN FUELING TECHNOLOGIES Phone 919-729-6980 Email Address RALEIGHDISPATCH@GUARDIANFUELTECH.COM I certify, under penalty of law, that the testing data provided on this form documents the UST system equipment was checked in accordance with the d the applicable national industry standards listed in 15A NCAC 2N .407/.0501 and/or 15A NCAC 2N .0900. JUSTIN WHITE 12/05/2022 Print Name of person conducting inspection Signature of person conducting inspection Inspection Date Sensor Location: Enter Location #/Description: Dispenser Spill Bucket Tank Interstice Tank Top and Other Sumps #: L6 DSL FILL Dispenser Spill Bucket Tank Interstice Tank Top and Other Sumps #: Dispenser Spill Bucket Tank Interstice Tank Top and Other Sumps #: Dispenser Spill Bucket Tank Interstice Tank Top and Other Sumps #: Dispenser Spill Bucket Tank Interstice Tank Top and Other Sumps #: Tank Volume (gallons):10,318 Product:DIESEL Sensor Manufacturer/Model:EMCO A1004- 001SEM Type of Sensor Discriminating Non- discriminating Discriminating Non- discriminating Discriminating Non- discriminating Discriminating Non- discriminating Discriminating Non- discriminating Is Sensor Position sensitive? (N/A if No and Pos. Sens. not required) Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Test Liquid Water Product Water Product Water Product Water Product Water Product Is the ATG console clear of any active or recurring warnings or alarms regarding the leak sensor? If the sensor is in alarm and functioning, indicate why. Yes No Yes No Yes No Yes No Yes No Is the sensor alarm circuit operational?Yes No Yes No Yes No Yes No Yes No Has sensor been inspected and in good operating condition?Yes No Yes No Yes No Yes No Yes No If Position Sensitive, does sensor alarm when raised off bottom? Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A When placed in the test liquid, does the sensor trigger an alarm? (If sensor cannot be removed, e.g., Emco Spill bucket sensor then N/R) Yes No N/R Yes No N/R Yes No N/R Yes No N/R Yes No N/R When an alarm is triggered, is the sensor properly identified on the ATG console?Yes No Yes No Yes No Yes No Yes No Sensor mounted at the lowest point of interstice (e.g., within 2 inches of containment sump bottom) (Liquid detecting float sensors only) Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Alarm report attached?Yes No Yes No Yes No Yes No Yes No UST-6D/23A Page 1 Triennial UST Spill Bucket Integrity Testing (Hydrostatic/Vacuum Test) If any periodic test fails, a suspected release report must be submitted on a UST-17A form, UST Suspected Release 24 Hour Notice. The suspected release must be investigated, in accordance with 15A NCAC 2N .0603, and defective equipment repaired or replaced in accordance with 15A NCAC 2N .0404/.0900. Results of the investigation must be submitted on a UST-17B form, UST Suspected Release 7 Day Notice. The primary containment and interstitial space of the spill bucket shall be tested in accordance with the manufacturers written guidelines, PEI/RP100 he Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. The primary and secondary walls are both considered to be tested at the same time if vacuum is used to test the interstice. UST FACILITY Owner / Operator Name EAGLES ENTERPRISE LLC Facility Name EAGLES #5 Facility ID#: 00-0-0000036955 Facility Street Address 620 HAMPTON POINT Facility City HILLSBOROUGH County ORANGE TESTING CONTRACTOR INFORMATION Company Name GUARDIAN FUELING TECHNOLOGIES Phone 919-729-6980 E-mail Address RALEIGHDISPATCH@GUARDIANFUELTECH. I certify, under penalty of law, that the testing data provided on this form documents the UST system equipment was tested in accordance with the and the applicable national industry standards listed in 15A NCAC 2N .406 and/or 15A NCAC 2N .0900. CHRIS DEMEO 12/05/2022 Print Name of person conducting test Signature of person conducting test Test Date Identify Spill Bucket (By Tank Number, Stored Product, etc.)Tank #2B Tank # Tank # Tank # Tank # Tank Size 10,318 Product DIESEL Indicate units for all measurements Bucket Manufacturer/Model EMCO 317S-CM Bucket Depth 12" Construction SW DW SW DW SW DW SW DW SW DW Bucket Installation Type Direct Bury Direct Bury w/Liner Containment sump Direct Bury Direct Bury w/Liner Containment sump Direct Bury Direct Bury w/Liner Containment sump Direct Bury Direct Bury w/Liner Containment sump Direct Bury Direct Bury w/Liner Containment sump Test Type Hydrostatic Vacuum Hydrostatic Vacuum Hydrostatic Vacuum Hydrostatic Vacuum Hydrostatic Vacuum Liquid and debris removed from spill bucket?Yes No Yes No Yes No Yes No Yes No Visual inspection (No cracks, loose parts or separation of the bucket from fill pipe.) Pass Fail Pass Fail Pass Fail Pass Fail Pass Fail Tank riser cap included in test?Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Drain valve included in test?Yes No N/A Yes No N/A Yes No N/A Yes No N/A Yes No N/A Wait time between applying vacuum/water and start of test 30 SECONDS Primary Section Test Hydrostatic: Water level must be within 1.5 inches of top of bucket Vacuum: Apply vacuum of 30 inches WC Begin I End Test Time I I I I I Begin I End Reading I I I I I Secondary Interstice Test Vacuum: Apply vacuum of 15 inches WC Gauge range (with units): 0" - 30" WC (1" UNITS) Begin I End Test Time 1:43pm I 1:44pm I I I I Begin I End Reading -30" WC I -30" WC I I I I Pass/fail criteria: Must pass visual inspection. Pass if: Hydrostatic: Water level drop of less than 1/8 inch in 1 hour; Vacuum single-walled only: Maintain at least 26 inches water column for 1 minute; Vacuum double-walled: Maintain at least 12 inches water column for 1 minute Test Results Pass Fail Pass Fail Pass Fail Pass Fail Pass Fail Comments (include information on repairs made prior to testing, and recommended follow-up for failed tests) Date next Spill Bucket integrity test due (required every 3 years)12/05/2025 NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY, DIVISION OF WASTE MANAGEMENT, UST SECTION 1646 MAIL SERVICE CENTER, RALEIGH, NC 27699-1646 PHONE (919) 707-8171 FAX (919) 715-1117 http://www.wastenotnc.org/11/2022 APPENDIX B UVF Report – Soil Sample 3502 Hayes Road • Monroe, North Carolina 28110 113 West Firetower Road, Suite G • Winterville, North Carolina 28590 Phone (704) 845-4010 • (888) 870-4133 • Fax (704) 845-4012 Engineering Certification: C-2727 • Geology Certification: C-127 UVF Trilogy Analytical Report Samples Collected: December 5, 2022 Samples Analyzed: December 6, 2022 Site Name: Eagles 5 Site Address: 520 Hampton Pointe Boulevard, Hillsborough, NC GRI Project Number: 6280 December 9, 2022 Colton Coolbaugh Operator Technical Procedures Calibration The UFV Trilogy has standard calibrations stored for the following analysis:  GRO  DRO  Total PAH  Target PAH  Heavy PAH Prior to use, calibration standards are used to perform a 5-point verification on the factory stored calibrations for GRO and DRO. The calibration standards used are as follows: GRO  0.5 ppm  1 ppm  3 ppm  5 ppm  10 ppm DRO  0.1 ppm  0.5 ppm  1 ppm  3 ppm  5 ppm Operation Sample Extraction  5mg of soil are weighed into a clean extraction jar  Methanol is added to the extraction jar to create a 2x or 4x dilution o 2x Dilution: 10 mL of methanol o 4x Dilution: 20 mL of methanol  The extraction jar is shaken for several minutes to thoroughly mix the soil with solvent (methanol)  The mixture is allowed to settle for several minutes  A clean syringe is used to draw liquid from the extraction jar  A clean filter is attached to the end of the syringe and the liquid dispensed through the filter into a clean test tube  This liquid is referred to as the extraction Dilution Preparation  An adjustable micropipette is used to precisely measure out the amount of extract needed for the dilution  The measured out amount of the extract is added to a clean test tube and methanol is added dilute the extract. Examples of dilutions are shown below: Extract Amount 500 μL 200 μL 100 μL 50 μL 25 μL Add Solvent to the 5 mL line 5 mL line 5 mL line 5 mL line 5 mL line 2x Extract Dilution Factor 20x 50x 100x 200x 400x 4x Extract Dilution Factor 40x 100x 200x 400x 800x Technical Procedures Sample Analyzation  The dilution is shaken to thoroughly mix, then poured into a clean glass cuvette  The desired module is inserted into the UVF Trilogy and the corresponding factory calibration is selected  “Measure Fluorescence” is pressed on the touchscreen and the reading is recorded  The reading should be between the concentrations of the calibration standards (GRO: 0.5-10 ppm; DRO 0.1-5 ppm) o Reading below the calibration standard range are recorded as below the detection limit  Detection Limit = (lower range of calibration standards range) x dilution factor (i.e. a GRO sample with a 100x dilution factor has a detection limit of 50 ppm) o Readings above the calibration standard range should be further diluted and reanalyzed o Negative readings are an indication of quenching (see below)  The reading is multiplied by the dilution factor to calculate the final concentration  Check suspected contaminated samples for quenching by running additional dilutions o According to the siteLAB Quick Reference Guide: “Quenching” can occur when the detector is swamped by too many hydrocarbons or organic interferences, producing low or negative concentrations. Test the sample at multiple dilutions to confirm results are linear and accurate.” QA/QC Method Blank  A method blank of methanol will be analyzed following calibration and following the last sample analyzed each day Duplicates  One duplicate will be analyzed for every 20 samples  The duplicate will be prepared from the extract of the sample and diluted to the same factor as the sample analyzed Project Name:Date Collected: Project Number:Date Analysed: Project Manager:Operator: Sample ID Matrix Dilution Factor x GRO Output (ppm) =GRO Value (mg/Kg) Dilution Factor x DRO Output (ppm) =DRO Value (mg/Kg) SS-1 Soil 20 0.68 13.6 20 1.15 23 UVF Analytical Report siteLAB UVF Trilogy 12/6/2022 12/5/2022 Colton Coolbaugh Eagles 5 6280 Ethan Rogerson Site: Jacob's Fuel Mart Report Date: 12/9/2022 Page: 1 of 1