Document 2RnbNmaojYz2m53m6kDNBGEK6

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Tippecanoe Laboratories, Lafayette, Indiana FROM: Jason Schenandoah, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Tippecanoe Laboratories (Tippecanoe) Facility Location: 1650 Lilly Rd, Lafayette, IN 47909 Date of Inspection: October 24, 2023 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Sasa Dunovic, Environmental Engineer Other Attendees: 1. Additional attendees are listed in Appendix A to this report . Contact Email Address: mckenzie.temme@evonik.com Purpose of Inspection: To ensure compliance with the Chemical Accident Prevention Provisions (CAPP) at 40 C.F.R. Part 68. Facility Type: Chemical manufacturing facility Regulations Central to Inspection: The CAPP, specifically the Risk Management Plan (RMP). Arrival Time: 10:00 am Departure Time: 5:40 pm Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Tippecanoe personnel unless otherwise noted. Process Description: Tippecanoe operates various chemical manufacturing processes to create chemicals for special additives, nutrition and care, and smart materials. In addition to chemical manufacturing, Tippecanoe operates solvent recovery and a waste incineration process. The focus of this inspection was on a fermentation process utilizing anhydrous ammonia and storage of hydrochloric acid in solution. Ammonia is consumed in the fermentation process in one of 14 tanks to make the necessary chemicals for each batch. The hydrochloric acid in solution is stored in totes in a warehouse building separate from any chemical manufacturing process. TOUR INFORMATION EPA Tour of the Facility: Yes Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW RMP documents in the following categories were reviewed during the inspection: Management Offsite consequence analysis (OCA) Process Safety Information (PSI) Process Hazard Analysis (PHA) Operating Procedures Training Mechanical Integrity Page 2 of 6  Management of Change Pre-startup Safety Review Incident Investigation Compliance Audits Employee Participation Hot Work Permit Emergency Response RMP submittals The following observations were made during the records review process: PSI The process flow diagram for the ammonia process was a piping and instrumentation diagram with sections highlighted. Training The last two operator three-year refresher trainings occurred in November 2017 and late March and early April 2021. A software system is used to initiate training as it becomes necessary, it did not occur for the 2021 training. Management of Change The management of change procedure does not address whether training is necessary based on the change. The changes are communicated to the operators prior to restarting the process, but there is no documentation of the communications. Incident Investigation A recommendation was made to add a preventative maintenance task to the monthly checks on the ammonia system to include peanut pressure relief valve checks. At the time of the inspection, it had been over a year since the recommendation had been created and the procedure had not been implanted yet. No formal communications to operators for incident reports is conducted. Emergency Response Tabletop and field exercises documentation did not contain a list of participants. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Page 3 of 6 DIGITAL SIGNATURES JASON Digitally signed by JASON SCHENANDOAH SCHENANDOAH Date: 2023.12.20 Report Author: ______________11_:1_7:4_1_-0_6'_00_' ____________ Section Supervisor: NATHAN Digitally signed by NATHAN FRANK _F_R_A__N_K_______1_4:_13_:0_6 _-0_6'0_0'______________ Date: 2023.12.20 Page 4 of 6 APPENDICES AND ATTACHMENTS Appendix A: Sign in sheet Facility Name: Tippecanoe Laboratories Facility Location: 1650 Lilly Rd, Lafayette, IN 47909 Date of Inspection: October 24, 2023 Page 5 of 6 APPENDIX A: SIGN-IN SHEET Facility Name: Tippecanoe Laboratories Facility Location: 1650 Lilly Rd, Lafayette, IN 47909 Date of Inspection: October 24, 2023 Page 6 of 6