Document 0gYjL0YVoDjeQBNMEvxRDBa1n

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 Tier II Facility Inspection Report FACILITY INFORMATION: Name: Arclin USA LLC Physical Address: 475 N. 28th St, Springfield, OR 97477 Phone Number: 541-746-6501 Latitude/Longitude: 44.048889, -122.985556 RMP Facility ID# 1000 0006 1513 FRS ID#: 110000488507 EJ Concerns: No (below 80%) CONTACT INFORMATION (RMP Implementation): Name: Merle Vasbinder Phone Number: 541-221-5722 E-mail: Merle.Vasbinder@arclin.com EMERGENCY CONTACT INFORMATION: Name: Merle Vasbinder Phone Number 24hr: 541-221-5722 E-mail: Merle.Vasbinder@arclin.com Website: arclin.com TRIP DETAILS: Inspection Date: Inspection Time: EPA Inspection Team: June 29, 2022 0900 hours through 1145 hours Terry Garcia, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Tom Vroman, CIH, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: June 18, 1999 Date of Latest Update: May 20, 2019 Process (Program 1, 2, 3) as reported in RMP: Page 1 of 5 Process ID 1000096462 1000096463 1000096464 1000096465 1000096466 1000096467 1000096468 1000096469 1000096470 Description Kettle 2 SF-1 Storage SF-2 Storage SF-3 Storage Kettle 4 Kettle 8 Ammonia Storage Kettle 3 Kettle 7 Process Chemical ID 1000120812 1000120813 1000120814 1000120815 1000120816 1000120817 1000120818 1000120819 1000120820 NAICS Code 325211 325199 325199 325199 325211 325211 325211 325211 325211 Program Level 3 3 3 3 3 3 3 3 3 Chemical Name CAS Number Formaldehyde (solution) 50-00-0 Formaldehyde (solution) 50-00-0 Formaldehyde (solution) 50-00-0 Formaldehyde (solution) 50-00-0 Formaldehyde (solution) 50-00-0 Formaldehyde (solution) 50-00-0 Ammonia (conc 20% or greater) 7664-41-7 Formaldehyde (solution) 50-00-0 Formaldehyde (solution) 50-00-0 Quantity (lbs) 53,000 470,000 580,000 2,000,000 36,000 36,000 30,000 31,000 31,000 PURPOSE: The purpose of this inspection was to determine whether this facility is in compliance with Section 112(r) of the Clean Air Act and Title 40 Code of Federal Regulations (CFR) Part 68, Chemical Accident Prevention Provisions. The facility has been previously inspected in the past 5 years: No Yes If Yes, Date of Last Inspection: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 02/28/2022 No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 02/28/2022 Page 2 of 5 INSPECTION ENTRY: Terry Garcia led the inspection entry. The inspection team met with Gary Johnson at the OFD Foods, LLC main office in Albany, Oregon. The team arrived at the facility at 09:00 and was joined by the following facility and contracted personnel: Name Merle Vasbinder Wayne Thornton Todd Hughes Kalina Hentze-Davis Bryan Murray Caitlin Ditullio Title Plant Manager Operations Supervisor HSE Leader HSE Leader Plant Engineer Process Engineer Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes The facility is a first responder: If No, Responding Agency: Eugene-Springfield Fire Department No Yes The inspection team was escorted to a conference room located in the facilit office building. Introductions were made by Terry Garcia, who provided a summary of the risk management program (RMP) and explained the purpose of the visit. Each team member presented his/her credentials. measures that should be taken during the site tour. Gary Johnson gave a brief description of the facility, operations, and personal protective equipment required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives (such as a union representative) have the right to participate in the RMP inspection, and that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: If Yes, Name of Union: No Yes An employee representative present during the facility visit: If Yes, Name/Title: No Yes GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by Arclin USA LLC (Arclin). Arclin uses formaldehyde and aqueous ammonia at their Springfield, Oregon facility to manufacture resins for use in plastics manufacturing. The facility utilizes chemicals to manufacture formaldehyde on site. The RMP covered chemicals on site are formaldehyde and aqueous ammonia (20% concentration or greater) that are stored in tanks and managed in kettles during manufacturing processes. Additional chemicals observed on site not covered by RMP rule include molybdenum, methanol, phenols, and sulfuric acid. The facility manufactures formaldehyde at two operational formaldehyde plants on site, SF-2 and SF-3. SF-2 is a silver process plant constructed in 1975 and serves as an auxiliary plant used occasionally to Page 3 of 5 meet increased demand for product. SF-3 is a molybdenum oxide process plant constructed in 1989 and serves as the main manufacturing plant, operating 24 hours a day, 7 days a week. A tank farm stores the formaldehyde manufactured at the respective plants. Formaldehyde Plant SF-1 was built in 1968 and was taken out of operation in 2013. The facility manufactures resins at the Resin Plant, located at the northeast corner of the facility. Kettles hold various chemical mixtures which produce different types of plastics and resins. One resin manufacturing process in Kettle K2 utilizes aqueous ammonia, which arrives via truck delivery and is stored in a storage tank on the east side of the property. Arclin has 41 employees at the facility. Twenty-six employees work in the plant, with 15 of those employees trained as operators in the covered processes. There are no process modifications in the formaldehyde or aqueous ammonia processes. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 915 hours to 1015 hours. The EPA Inspection Team (EPA) was escorted by facility representatives Merle Vasbinder, Wayne Thornton, Todd Hughes, and Kalina Hentze-Davis. Facility representatives provided an overview of chemical manufacturing processes (Photos 1, 2) before guiding a tour of the facility (Photo 3). EPA observed formaldehyde plants SF-2 and SF-3, the Transfer Station, the Resin Plant, and exterior areas of the facility. EPA observed process areas of SF-2 (Photos 4, 5) and SF-3 (Photos 6, 7). The formaldehyde made in these plants are stored in above ground storage tanks on the southern end of the property (Photo 8). EPA observed RMP covered operations at the Transfer Station at the facility. Safety features observed in this area include an eyewash, emergency stops, and grounding wires (Photos 9, 10, 11). Aqueous ammonia arrives via truck at this area and is transferred to a pressurized storage tank in an exterior area of the facility (Photo 12). Safety features on the aqueous ammonia storage tank include pressure relief valves (Photo 13), gauges and NFPA placarding (Photos 14, 15), an emergency washing station, and ammonia detectors (Photo 16). Lines transfer liquid ammonia (Photos 17, 18) and methanol (Photo 19) to processes in the Resin Plant. The Resin Plant includes multiple kettles which contain a variety of chemicals used to manufacture plastics and resins (Photos 20, 21, 22). Kettle K2 in the Resin Plant utilizes the aqueous ammonia in a resin manufacturing process (Photo 20). Kettles K3 and K7 utilize phenols to manufacture plastics (Photo 21); this process creates an explosive atmosphere, and the room is equipped with Class 1 electronic equipment (Photo 22). EPA observed areas of the facility exterior and a windsock (Photo 23), and sulfuric acid storage containers (Photo 24) adjacent to the Resin Plant. Plant operations are coordinated through the Control Room (Photo 25) where operators observe and control plant operations. The Control Room has operators have standard operating procedures via network, hard copy and computer terminal. Page 4 of 5 INFORMATION COLLECTED FROM FACILITY: 1. Arclin USA LLC PSM and RMP Audit (conducted by AECOM) (9 pages) 2. Operators Training Records (2 pages) 3. Operator training certifications (2 pages) 4. Aqueous Ammonia Tank Inspection (conducted by EMI Integrity Services 3/28/18) (4 pages) 5. EMI Integrity Services Inspector Certification for Cameron Pinto (1 page) 6. Kettle 2 Inspection report (conducted by EMI Integrity Services 5/24/19) (3 pages) AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. The annual certification of the 2021 standard operating procedures (SOPs) for formaldehyde and aqueous ammonia process were not provided. [68.69(c)]. Arclin stated they were working on the annual certification of the 2022 SOPs at time of the inspection. On 9/15/2022 Arclin provided documentation on the completion of the annual certification of the 2022 SOPs. 2. Initial training documentation did not include emphasis on safety and health hazards, emergency . [68.71(a)(1)]. Arclin was unable to locate the initial training records for four operators (Will Waddell - 01/04/1999, Bruce Sutherland 01/02/2000, Mark Westerkamp 04/16/2001, Anthony Teal - 08/11/2014). DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. These documents will still be reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. Contractor evaluations for all PSM related activities. 2. Mechanical Integrity Audit results and any findings for the Ammonia storage vessel. The MI audit was work in progress at the time of the inspection. 3. Incident investigation reports for NRC#1223980 and NRC# 1338868 were provided with a complete causal, root cause and corrective actions post investigation. INSPECTION REPORT CERTIFICATION: This is to certify that Terry Garcia, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report. __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 5 of 5 Attachment A - Photo Log Site Name: Arclin USA LLC City, State: Springfield OR Photographer: Tom Vroman File Picture 1.jpg Picture2.jpg Picture3.jpg Picture4.jpg Picture5.jpg Picture6.jpg Picture7.jpg Picutre8.jpg Picture9.jpg Picture10.jpg Picture11.jpg Photo Layout ID 1 2 3 4 5 6 7 8 9 10 11 Picture 12.jpg 12 Picture13.jpg 13 Picture14.jpg 14 Picture15.jpg 15 Picture16.jpg 16 Picture17.jpg 17 Picture18.jpg 18 Picutre19.jpg 19 Picture20.jpg 20 Picture21.jpg 21 Picture22.jpg 22 Picture23.jpg 23 Picture24.jpg 24 Picture25.jpg 25 Date 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 6/29/2022 Time 8:55 AM 8:57 AM 9:18 AM 9:20 AM 9:21 AM 9:24 AM 9:25 AM 9:26 AM 9:26 AM 9:27 AM 9:28 AM 9:29 AM 9:30 AM 9:31 AM 9:32 AM 9:32 AM 9:33 AM 9:34 AM 9:35 AM 9:38 AM 9:40 AM 9:45 AM 9:46 AM 9:48 AM 9:54 AM Description Slide of facility summary, presented during morning briefing Slide summarizing organizational structure, presented during morning briefing Overview of facility and tanks, northwest corner of the facility SF-2 silver process formaldehyde plant SF-2 silver process formaldehyde plant, alternate view SF-3 molybdenum oxide process formaldehyde plant SF-3 molybdenum oxide process formaldehyde plant SF-3 Tank Farm adjacent to SF-3 formaldehyde plant Transfer Station with eyewash, emergency stops, grounding wires Aqueous ammonia transfer lines, Transfer Station Transfer Station with eyewash, emergency stops, grounding wires, alternate view Aqueous ammonia storage tank, NFPA placard, pressure relief valve, emergency washing station at facility exterior Aqueous ammonia tank pressure relief valve, facility exterior Aqueous ammonia tank pressure gauge and NFPA placard, facility exterior Aqueous ammonia tank NFPA placard, facility exterior Emergency washing station and NH3 alarms at liquid ammonia tank, facility exterior Transfer lines connecting aqueous ammonia storage vessel to Kettle K2, facility exterior Aqueous ammonia transfer lines, facility exterior Methanol transfer station, facility exterior Kettle K2 incorporates aqueous ammonia in the resin manufacturing process, Resin Plant Kettles K3 and K7 containing phenols, Resin Plant Placard designating flammable atmosphere, facility exterior Windsock on top of tank, facility exterior Sulfuric acid storage, facility exterior Control Room Page 1 of 1