Document 1085NQ57X2kB0EJrMewoZGozo

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: Forrest Paint Co. Physical Address: 1011 McKinley Street Eugene, Oregon 97402 Phone Number: 541-746-6501 Latitude/Longitude: 44.048982, -123.129200 RMP Facility ID# 1000 0007 5027 FRS ID#: 110000488259 EJ Concerns: Yes (90%) CONTACT INFORMATION (RMP Implementation): Name: Justin Roudabush Phone Number: 541-342-1821 E-mail: jroudabush@forrestpaint.com EMERGENCY CONTACT INFORMATION: Name: Mike DeHaven Phone Number 24hr: 541-688-7719 E-mail: mdehaven@forrestpaint.com Website: forrestpaint.com TRIP DETAILS: Inspection Date: Inspection Time: EPA Inspection Team: June 30, 2022 0900 hours through 1145 hours Edward Johannes, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Tom Vroman, CIH, Weston Solutions, Inc., EPA START Contractor August 19, 2022 Page 1 of 6 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: June 21, 1999 Date of Latest Update: October 15, 2021 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000119794 1000119794 Description Aerosol Propellant Aerosol Propellant Process Chemical ID 1000120812 1000120813 NAICS Code 32551 32551 Program Level 3 3 Chemical Name CAS Number Propane 74-98-6 Butane 106-97-8 Quantity (lbs) 21,000 16,000 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? No Yes If Yes, Date the Tier II was submitted: February 24, 2022 If No, calendar year of the most recent Tier II: Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: February 24, 2022 INSPECTION ENTRY: Edward Johannes led the inspection entry. The EPA Inspection Team (EPA) met with facility representative Mark Kruger, EHS Manager at the Forrest Paint Company main office in Eugene, Oregon. EPA arrived at the facility at 0900 hours and was joined by the following facility personnel: Mike Dehaven Justin Roudabush Mike Grandy Michael Carstens Name Title Vice President Environmental Specialist President Maintenance Mechanic Page 2 of 6 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 Facility representatives escorted EPA personnel to a conference room located in the facility's office building. Introductions were made by Edward Johannes, who provided a summary of the risk management program (RMP) and explained the purpose of the visit. Each team member presented his/her credentials. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Justin Roudabush gave a brief description of the facility, the covered process, operations, and personal protective equipment required for the inspection. 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 Forrest Paint Company (Forrest Paint). Forrest Paint mainly produces coatings, aerosol paints, paints, and related specialty products that largely used by manufacturers of original equipment (OEM) and other industrial applications. RMP covered processes consists of partially filling of aerosol paint cans with an odorless and highly flammable liquefied petroleum gas (LPG) mixture called A-70. This propellant gas mixture consists of 57% propane and 42% n-butane. Because of its use in aerosol paint cans no odor (ethyl mercaptan) is added to this mixture that would allow the detection of leaks to be decerned by the sense of smell. A-70 is transported and stored as a liquid under pressure of more than 100 psi. A-70 is delivered by trucks every six weeks to Forrest Paint. The equipment involved in the covered process includes eight high pressure storage tanks with a combined maximum capacity of 8,096 gallons (88% maximum fill level) of liquid A-70, pumps and pipelines that transport the liquid A-70 under high pressure to and from the storage tanks, and the Gasser Head Room where A-70 is delivered by pipeline to two aerosol gassing stations. These stations are where aerosol paint cans are partially filled with liquid A-70 after being filled with paint. One gassing station is part of an automated conveyor system where aerosol paint cans are automatically partially filled with liquid A-70 at a twin head filling table. The automated filling station table is located in the Aerosol Gassing Room, which is a 6 ft. by 6 ft. cinder block building constructed with a blowout roof. The other gassing station is in the Aerosol Fill Room and is used for small orders where the aerosol paint cans are partially filled individually by hand at a table with liquid A-70. Page 3 of 6 Forrest Paint has approximately 125 full-time employees, of which ten are trained as operators. The propellant mixture process typically operates from 0500 hours to 1330 hours, Monday through Friday. ON-SITE OBSERVATIONS: The facility inspection was conducted from 0915 hours to 0945 hours. EPA personnel was escorted by Mark Kruger, Justin Roudabush, and Mike Grandy. Eight tanks storing A-70 were observed and are located on the north side of the facility (Photos 1-5). The storage tanks are protected by steel bollards and concrete jersey barriers from vehicles (Photo 1). The tank storage area has a posted NFPA placard and is equipped with an emergency shut-off button (Photo 2). The liquid A-70 is transported and pumped under high pressure through a pipeline under a road from the tank storage area to the Gasser Head Room, where aerosol paint cans are partially filled at two gasser stations (Photos 4, 7, 8, 10). This pipeline is not properly marked where it comes out of the ground (Photos 7 and 8). An emergency shut-off button is located at the Gasser Head Room (Photo 8). The exhaust ventilation for the Gasser Head Room is equipped with an LPG level detector (Photo 11). The gas detector is connected to audio visual alarm indicators, one is on the westside of the building (Photo 13) and the other is on the southside of the building (Photo 14). Both alarms flash green with an atmosphere < 20% of the lower explosive limit (LEL), yellow between 20-40% of the LEL, and red when it reaches > 40% of the LEL. Standard operating procedures (SOPs) are posted on the inside of the entry door of the Gasser Head Room (Photo 15). The facility has above ground storage tanks for isopropanol that are located inside a concrete catch basin (Photo 3). These tanks are not part of the RMP covered process but were visited as part of the EPCRA inspection. INFORMATION COLLECTED FROM FACILITY: 1. Forrest Paint written RMP Program (125 pages) 2. Operator SOP training (1 page) 3. RMP 3-year Audit Review (dated March 31, 2021) (3 pages) 4. Equipment Data Sheet (dated May 6, 1999) (1 page) 5. Monthly Tank Inspection forms (8 pages) 6. PSM and RMP Document Review (conducted by Steve Williams, CHMM dated April 5, 2021) (3 pages) 7. Three Year Audit Sign-in Sheet (dated June 17, 2021) (1 page) 8. PSM and RMP Document Review (conducted by Steve Williams, CHMM dated April 5, 2021) (3 pages) 9. PSM/RMP New Employee Check List (4 pages) 10. PSM Training Checklist (all dated June 29, 2022) (16 pages) 11. Filled September Equipment Inspection Forms (dated September 8, 2022) (7 pages) 12. Filled November Equipment Inspection Forms (dated November 8, 2022) (6 pages) 13. Process Safety Information (dated June 24, 2022) (5 pages) 14. Operating Procedures (dated November 8, 2022) (20 pages) 15. Mechanical Integrity of Equipment (dated November 8, 2022) (9 pages) 16. LPG Employee Licenses (3 pages) 17. Simplified Process Flow Diagram (dated March 1, 1999) (12 pages) 18. Equipment Data Sheet (dated November 6, 1998) (59 pages) 19. Inspection/test of sensors and safety systems (with calibration date). (2 pages) Page 4 of 6 AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Forrest Paint did not provide documentation on the process chemistry [68.65(c)(1)(ii)]. 2. Forrest Paint did not provide documentation on the electrical classification [68.65(d) (1)(iii)]. 3. Forrest Paint did not provide documentation on relief system design and design basis for internal, external and pressure relief valves of the covered process [68.65(d)(1)(iv)]. 4. Forrest Paint did not provide documentation on design codes and standards employed of the process equipment for the covered process [68.65(d)(1)(vi)]. 5. Forrest Paint did not provide documentation that the process equipment design complies with the recognized and generally accepted good engineering practices of the for the covered process [68.65(d)(2)]. 6. A June 24, 2022, PHA was not performed by a team with expertise in engineering and process operations [68.67(d)]. 7. Forrest Paint has not addressed the June 24, 2022, PHA recommendations [68.67(e)]. 8. Forrest Paint has not updated and revalidated their PHA every five years [68.67(f)]. 9. Forrest Paint provided initial training documentation (PSM New Employee Checklist) for Byron Sanders (hired 2017), Samantha Pierce (hired 2019), Michael Conrad (hired 2019), and Tom O'Malley (hired 2020). The PSM New Employee Checklist does not address training in the overview of the covered process and the operating procedures (i.e., initial startup, normal startup, normal shutdown) [68.71(a)(1)]. 10. Forrest Paint was unable to provide documentation on the inspection and testing on the buried high-pressure pipeline transporting liquid A-70 under a roadway from eight high pressure storage tanks to a Gasser Head Room. The buried pipeline installed in 1998 is inaccessible for inspection [68.73(d)(1), (4)]. 11. The frequency of tests and/or replacement are not consistent with manufacturer's recommendations for the internal and external relief valves [68.73(d)(1), (2), (3), (4)]. Forrest Paint has not performed requalifier tests on the internal and external relief valves since they were installed in 1998. Reference the maintenance procedure in CGA S-1.1, 2022, Sixteenth Edition, Pressure Relief Device Standards-Part 1- Cylinders for Compressed Gases. 12. Forrest Paint did not perform appropriate checks and inspections to assure LPG sensors were installed properly and consistent with design specifications [68.73(f)(2)]. According to the LPG sensor calibration log provided by Forrest Paint, they were looking for certified company to perform the calibration of the sensors in the Aerosol Fill Room and warehouse on August 9, 2019. These sensors were not calibrated until June 1, 2022 (the only record in the log). According to a notation in the calibration log the sensors need to be calibrated every 2 years. Page 5 of 6 13. Forrest Paint did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected [68.79 (d)]. The June 21, 2021, compliance audit list of findings has no documentation that corrections of deficiencies have been resolved and completed. 14. Forrest Paint was unable to provide performance evaluation documentation for their contractors, Oregon Electric and Areopres [68.87(b)(5)]. 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 RMP related activities 2. Offsite consequence analysis (OCA) map with impacted populations. INSPECTION REPORT CERTIFICATION: This is to certify that I, Edward Johannes, 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 6 of 6