Document 2q4YX885wy9yvbYgkJprYmaOL

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 25063 CENTER RIDGE ROAD WESTLAKE, OHIO 44145 MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Gaston Branch, Gaston, Indiana FROM: Danny Nguyen, Risk Management Program (RMP) Inspector WECAB, Multimedia Section THRU: Mr. Brooke Furio, Section Supervisor WECAB, Multimedia Section TO: File BASIC INFORMATION Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana 47342 Date of Inspection: December 14, 2023 EPA Inspector(s): 1. Danny Nguyen, RMP Inspector, USEPA Region 5 2. Sasa Dunovic, RMP Inspector, USEPA Region 5 Other Attendees: 1. Marty Clock, Plant Manager, Gaston Branch 2. Cory Cocanower, Risk Management of Central Indiana Contact Email Address: coryc@agbest.com Purpose of Inspection: Compliance with the prevention of accidental release provisions found in Section 112(r) of the Clean Air Act (CAA), 42 U.S.C. 7414(r) Facility Type: Support activities for crop production Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 Regulations Central to Inspection: The Chemical Accident Prevention Provisions at 40 C.F.R. Part 68 Arrival Time: 9:55 AM (December 14, 2023) Departure Time: 5:55 PM (December 14, 2023) 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 the Gaston Branch representatives unless otherwise noted. Process Description: The parent company for the Gaston Branch facility is AgBest LLC. Gaston Branch is one of three agriculture facilities in Indiana with the main office located in Granville, Indiana. The facility has eight full time employees along with several hired seasonal employees. The facility operates 7:30AM to 4:30PM Monday through Friday. During the Summer, the facility operates on weekends to meet seasonal demands. The Gaston Branch site receives all their bulk ammonia through third party tanker trucks. Ninety percent of the ammonia is brought in during April through May months. Ten percent is delivered from June to July to support corn production. Truck drivers are responsible for unloading ammonia from their tanker trucks to one of the two outdoor ammonia storage tanks using their own unloading equipment. Capacity of the above ground storage tanks are 18,000 and 30,000 gallons (hereafter "storage tanks"). There is not an auto-shutoff or active monitoring for overfilling the storage tanks. The storage tanks are not equipped with bleeder valves. The truck driver looks at the volume indicator to monitor current tank level and ensures the tank does not overfill beyond 85% of the total capacity. Tanker trucks can unload ammonia at any time of day or night whether an operator is on-site or not. There is a single unloading point that serves both storage tanks. The unloading connection is equipped with a back valve. It Page 2 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 was stated that only anhydrous ammonia from the tanker truck would be spilled if the unloading hose broke. The unloading and storage area is not equipped with ammonia sensors or alarms, and it is not actively monitored. The Gaston Branch operators unload ammonia from the storage tanks and fill the ammonia into approximately 88 on-site 1000-gallon nurse tanks to be provided as product to support corn and crop production. The Gaston Branch reports as RMP program level 2 facility. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: Storage tanks were seventy seven percent full at the time of the inspection. Pipes around the storage tanks were corroded. It was observed that paint was excessively peeling off the storage tanks. Labels on the storage tanks were observed to be peeling off. No permanent or portable eye wash was available in the maintenance shop where ammonia could be present. Loading and unloading of ammonia is the responsibility of the truck drivers and could be done at any time of the day or night without a site operator present. No safeguards or administrative controls to prevent overfilling of the storage tanks. No ammonia sensors, alarms, or active monitoring in the storage tanks area. A public walk and pathway were observed next to the property and storage tank. Part of the wooden fence separating the public path from the site property was not intact. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW The following records were provided by the Facility representatives electronically to USEPA prior to the inspection and are filed on a secure One Drive folder provided by EPA Inspector Danny Nguyen under the folder "Gaston Branch Document Folder": 2015-02-26 SDS Sheet - Anhydrous Ammonia.pdf 2019-05-21 Operating Procedures - Gaston.docx 2019-05-21 Maintenance Manual - Gaston.pdf Page 3 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 Base Manual.pdf Maintenance Manual Base Document.docx 2020-04-20 USEPA Incident Investigation Form - Gaston NH3.pdf 2020-04-20 Notes From Incident - Cory.docx 2020-04-20 Notes From Incident - Cory.pdf 2020-04-20 NRC Confirmation Email - Gaston NH3.pdf 2020-04-20 USEPA RMP Incident Investigation Form - Gaston NH3.pdf 2020-04-22 Map of Incident and Sample Points - Gaston.pdf 2020-04-22 SARA Title III Report - Gaston.pdf 5 Year Incident Review - Gaston.docx 2023-01-01 Emergency Action Plan - Gaston.pdf Anhydrous Ammonia Incident Investigation Form.pdf Marplot Map - Population Count - Gaston.pdf Marplot Map - Worst Case Scenario - Gaston.pdf RMP Comp - Worst Case - Gaston.pdf Worst Case Base Document.docx Alternate Case Base Document.docx Marplot Map - Alternate Case Scenario - Gaston.pdf Marplot Map - Population Count - Gaston.pdf RMP Comp - Alternate Case - Gaston.pdf 2015-08-16 Compliance Audit - Gaston.pdf 2017-01-27 Compliance Audit - Gaston.pdf 2019-05-30 Compliance Audit - Gaston.pdf 2022-05-11 Compliance Audit - Gaston.pdf 2017-01-27 Hazard Review - Gaston.pdf 2019-05-21 Hazard Review - Gaston.pdf 2016-08-29 Integrity Testing NH3 System Part 1 - Gaston.pdf 2016-08-29 Integrity Testing NH3 System Part 2 - Gaston.pdf 2016-08-29 Tank Testing 18k no NB - Gaston.pdf 2016-08-29 Tank Testing NB77200 - Gaston.pdf 2017-06-22 OISC Inspection Report.pdf 2019-04-16 Bulk Storage Inspection - Gaston.pdf 2020-05-26 Annual Bulk Storage Inspection - Gaston.pdf 2021-03-22 Annual Bulk Storage Inspection - Gaston.pdf 2021-09-29 OISC Bulk Storage and Nurse Tanks Inspection - Gaston.pdf 2022-05-09 Bulk NH3 Storage Inspection - Gaston.pdf 1956 U1A Report for Bulk Tank - Gaston.pdf 1956 U1A Report for Bulk Tank - Gaston.pdf 1976 U1A Report for Bulk Tank - Gaston.pdf 2019-05-21 Executive Summary - Gaston.docx Training Documents (19 total documents) 2019-06-04 Submission Certification - Gaston.pdf 2020-04-22 Voluntary Update Certification - Gaston.pdf Page 4 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 The following observations were made during the records review process: Training: No documentation was provided that each employee operating a process had been trained or tested competent in the operating procedures. Emergency Response (ER): No documentation was provided of coordination of response needs with local emergency planning and response organizations. No documentation was provided of annual coordination with local emergency planning and response organizations. Incident Investigation: Incident investigations did not have a participant list to ensure team consists of at least one person knowledgeable in the process and other persons with appropriate knowledge and experience to thoroughly investigate. There were no recommendations from the incident investigation, so the resolutions and corrective actions were nonexistent. Maintenance: The third-party contractors do all the maintenance at the site. The facility employees conduct a routine maintenance on the system's equipment and periodically replace pressure relief valves. No documentation was provided of training for employees involved in maintaining the integrity of the process. Mechanical integrity audits have not been conducted on the system's equipment except for the annual visual observations. Safety Information (SI): There was no documentation provided or certification that equipment complies with recognized and generally accepted good engineering practices. Operating Procedures (OPs): There were no initial startup, temporary operations, or normal shutdown procedures in the operating procedures. Page 5 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 EPA was informed that there are no temporary operations at the site, that initial startup and normal shutdowns are part of normal operations therefore covered in normal operations procedures. OPs have not been updated as necessary whenever a major change has occurred and prior to startup of changed process. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Areas of Concern: All observations identified above in the records review section. Pipes around the storage tanks were corroded. It was observed that paint was excessively peeling off the storage tanks. Labels on the storage tanks were observed to be peeling off. No permanent or portable eye wash was available in the maintenance shop where ammonia could be present. Loading and unloading of ammonia is the responsibility of the truck drivers and could be done at any time of the day or night without a site operator present. No safeguards or administrative controls to prevent overfilling of the storage tanks. No ammonia sensors, alarms, or active monitoring in the storage tanks area. A public walk and pathway were observed next to the property and storage tank. Part of the wooden fence separating the public path from the site property was not intact. Page 6 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 POST INSPECTON COMMUNICATION Communication Log (Post Inspection): 12-15-23 Email: Mr. Cory Cocanower provided update of storage tank testing and inspection standards. 12-15-23 Email: Mr. Cory Cocanower provided update of references to agriculture exemption for storage tank inspection and testing. 12-15-23 Email: Mr. Cory Cocanower provided piping photos of new paint on storage tank and process piping (photos provided). DIGITAL SIGNATURES Report Author: Digitally signed by DANNY DANNY NGUYEN NGUYEN Date: 2024.02.12 20:30:37 -05'00' __________________________________ Section Supervisor: Digitally signed by BROOKE BROOKE FURIO FURIO Date: 2024.02.13 07:43:25 -05'00' __________________________________ Appendices and Attachments Page 7 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 1. Appendix A: Digital Image Log Page 8 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Danny Nguyen 2. Archival Record Location: OneDrive/Desktop/Multi Media Section/112(r)/Inspections/Gaston Branch 14 Dec 2023/Photos Image Number 1 File Name DSCN0460.jpg Date and Time (incl. Time zone and DST) 12/14/2023 / 2:01PM Eastern Description of Image Outdoor ammonia storage tank and sign with pipe color legend 2 DSCN0461.jpg 12/14/2023 / Outdoor ammonia storage tank with peeling paint 2:01PM Eastern 3 DSCN0462.jpg 12/14/2023 / Corroded process piping 2:01PM Eastern 4 DSCN0463.jpg 12/14/2023 / Corroded process piping 4:02PM Eastern 5 DSCN0464.jpg 12/14/2023 / Corroded process piping 2:02PM Eastern 6 DSCN0465.jpg 12/14/2023 / Peeling and faded ammonia storage tank label 2:02PM Eastern 7 DSCN0466.jpg 12/14/2023 / Nurse tanks used for ammonia storage 2:06PM Eastern 8 DSCN0467.jpg 12/14/2023 / Piping and hoses at loading and unloading station 2:13PM Eastern 9 DSCN0468.jpg 12/14/2023 / Piping and hoses at loading and unloading station 2:14PM Eastern 10 DSCN0469.jpg 12/14/2023 / Ammonia storage tank volume indicator 2:20PM Eastern 11 DSCN0470.jpg 12/14/2023 / Public walkway next to process equipment with 2:28PM Eastern broken fencing around site property The following digital images were provided by the facility post inspection: Page 9 of 10 Facility Name: Gaston Branch Facility Location: 430 South Sycamore Street, Gaston, Indiana, 47342 Date of Inspection: December 14, 2023 1. Inspector Name: Danny Nguyen 2. Archival Record Location: OneDrive/Desktop/Multi Media Section/112(r)/Inspections/Gaston Branch 14 Dec 2023/Photos Image Number 1 2 File Name pro-KcJDXrjq.jpeg Pro-oRfWK1de.jpeg Date and Time (incl. Time zone and DST) Emailed on 12/15/2023 Emailed on 12/15/2023 Description of Image Cleaned up piping Cleaned up piping 3 pro-yraVpLOn.jpeg Emailed on Cleaned up piping 12/15/2023 Page 10 of 10