Document 2JLJKKgoR2aYwMr73j5XQVDjR

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report CITCO Water Lexington, Kentucky May 11, 2021 1.0 Introduction The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA. The focus of this inspection was to assess the RMP for the chemical manufacturing process at the CITCO Water (CITCO) facility located in Lexington, Fayette County, Kentucky. This facility was selected for inspection because it hasn't been inspected within the last five years under the RMP. The inspection, which was conducted on May 11, 2021, consisted of an examination of program documentation as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Numerous documents were provided for review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The CITCO facility is located in Lexington, Kentucky. The facility stores and distributes chlorine and sulfur dioxide (SO2). The process is regulated as program level 3. According to facility records, the facility has a maximum of 50,000 pounds of chlorine and 30,600 pounds of sulfur dioxide on site. The chemical storage processes at the facility are subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1. TABLE 1: Inspection Information Summary Inspection Team Lead Inspector: Jordan Noles, EPA Inspector: Om Devkota, EPA Date of Facility Visit: May 11, 2021 Facility Identification Name: CITCO Water Street Address: 740 Enterprise Drive City: Lexington County: Fayette EPA Facility ID No: 1000 0019 7495 Dun & Bradstreet (D&B) No: 5017918 State: Kentucky Zip: 40510 Latitude: 38.061917 Longitude: -084.552417 Name, address, and phone of corporate parent company: Owner/Operator: CITCO Water Mailing Address: 4034 Altizer Avenue City: Huntington State: West Virginia Zip: 25722 Phone: (304) 523-3484 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Rick Parks Title: Director of Operations Phone: (859) 255-0852 Email: rick.parks@citcowater.com Name and title of emergency contact: Name: Marc H. Templeton Title: Vice President Kentucky Operations Day phone: (859) 255-0852 24-hour Phone: (859) 619-0038 Email: marc.templeton@cithornburg.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Rick Park Title: Director of Operations Phone: (859) 255-0852 Email: rick.parks@citcowaer.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: November 20, 2006 Date of most recent submissions: December 30, 2016 Process: Chlorine Storage Process ID: 1000077018 Process: Sulfur Dioxide Storage Process ID: 1000095666 Program Level as reported in RMP: 2 NAICS code: 49319 (Other Warehouse and Storage) 2 3.0 Observations The inspection of the CITCO facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 3) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection included discussions with the facility representatives regarding a myriad of issues related to the operation of its chemical process, the facility's RMP, a review of paperwork associated with the facility's most recent Risk Management Plan, and a tour of the facility. An inspection in-brief and out-brief were conducted. Observations from the RMP inspection at the CITCO facility are discussed below: 1. 40 C.F.R. 68.160(b)(7) requires the registration to include, for each covered process, the name and CAS number of each regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits, the five or six-digit NAICS code that most closely corresponds to the process, and the Program level of the process. o The facility is registered as a program level 2. It should be registered as program level 3. Facility representatives stated the covered process is registered as program level 2, because it qualifies for OSHA's process safety management (PSM) retail exemption, which would only require the program to register as level 2 in RMP. However, according to the PSM preamble, the retail exemption only applies to certain industries that sell small quantities of chemicals to the end user. One-ton cylinders of chlorine are too large for the facility to qualify for OSHA's retail exemption. 2. 40 C.F.R. 68.48(b) requires the owner or operator ensure that the process is designed and maintained in compliance with recognized and generally accepted good engineering practices (RAGAGEP). 40 C.F.R. 68.65(d)(2) requires the owner or operator to document that equipment complies with RAGAGEP. o At the time of inspection, EPA inspectors observed no protection from rolling to the oneton cylinders of chlorine and SO2 stored outside the warehouse. According to Cl Pamphlet 17 section 2.6.7, ton containers, which weigh between 1,300 lb. (590 kg) and 1,650 lb. (750 kg) when empty, are always stored in the horizontal position, above the ground or floor, on steel, concrete or other suitable supports. Individual ton containers or the ton containers at each end of a row of ton containers should be chocked to prevent rolling. o The one-ton chlorine/SO2 cylinders were not protected from vehicular traffic or other physical damage. NFPA 55, Section 7.1.9.3.2 requires the compressed gas cylinders to be protected from vehicular traffic. o Full and empty chlorine and SO2 cylinders stored in an aisle of the warehouse and outside were not labeled. Labeling the cylinder as "Empty Cylinders" or "Full Cylinders" would avoid confusion during the emergency response. Furthermore, facility representatives provided the inspection team with The Chlorine Institute's Pamphlet 91, "Checklist for Chlorine Packaging Plants, Chlorine Distributors, and Tank Car Users of Chlorine" as an industry standard that the facility uses. The checklist asks the following questions: 3  Are the cylinders and containers protected from in-plant traffic? (forklifts, trucks, etc.) Are the storage areas equipped with cylinder and ton container securing methods? Are the cylinders and containers properly identified? (signage, placards, labels, marked, etc.) Inspection Report, Prepared by: ____________________________ Jordan Noles, Inspector North Air Enforcement Section Air Enforcement Branch U.S. EPA Region 4 __July 08, 2021_____ Date Approved by: JASON Digitally signed by JASON DRESSLER Date: 2021.07.08 08:20:46 _D__R_E_S__S_L_E_R______-0_4_'00_'_________ Jason Dressler, Chief North Air Enforcement Section Air Enforcement Branch U.S. EPA Region 4 __July 08, 2021_____ Date 4