Document 2qokm6prGEBEENzK7qbvb9225

A EPAUniltd SIOI.. ~ EnYironmental Protecljon ~,.. Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 09/11-14/2018 Air Risk Management Program, CAA 112(r) Accident Prevention Provisions 40 CFR 68 Company Name: BASF Corporation Facility Name: BASF Corporation Facility Physical Location: 602 Copper Road (city, state, zip code) Freeport, Texas 77541 Mailing address: 602 Copper Road (city, state, zip code) Freeport, Texas 77541 County/Parish: Brazoria Facil ity Contact: Deb Dalley FRS Number: 979-415-8103 - 110000463392 Media .Number: RMP: 1000 00111951 NAICS: 325211;325199;325311 Personnel participating in inspection: Lauren Hampton BASF Susan Boyer BASF John Shoemaker BASF Scott Kolb BASF Ron Barksdale BASF Beth Holland BASF I EHS Director - Deb Dalley Marie Stucky EPA Inspector: EPA Lead Inspector Signature/Date Supervisor Supervisor Signature/Date BASF EPA Region 6- 6EN-AS - .L- ~t}-1....._~ ___ Marie Stucky /- L 1tk Samuel Tates EHS Specialist EHS Specialist CPN Production Director EHS Team leader Site Services Director Vice President Operations EHS Director Inspector ll J' I ZotB Date IJ/ I I 2018 Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION BASF Corporation- Freeport, Texas 9/11-14/2018 PURPOSE OF THE INSPECTION I, EPA Region 6 inspector Marie Stucky, arrived at BASF Corporation (BASF) at 7:35AM on September 11, 2018, for an announced inspection. I met with Deb Dalley and others listed on Page 1 of this report. I presented my credentials and informed them that this was an EPA inspection to determine compliance with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions in 40 C.F .R. Part 68. The scope of the inspection is a partial compliance evaluation (PCE) and included an evaluation of the complia nee of the facility with CAA Section 112(r) and the Chemical Accident Prevention Provisions 40 C.F.R. Part 68. On August 30, 2018, BASF received an inspection notice announcement email from me, which outlined the directions of conducting an inspection on September 11-14, 2018 . The email also contained a list of documents for BASF to gather for review during the inspection . BASF is not a union facility. FACILITY DESCRIPTION BASF is in Freeport, Texas. According to https://www.basf.com/us/en/company/aboutus/Locatio ns/featured-sites/Freeport. htm I: "The BASF Freeport site was founded in Southeast Texas in 1958 as BASF's first manufacturing site outside Europe. The Freeport site employs more than 850 employees and almost 850 contractors. Currently, the Freeport facility produces 26 different products in 26 plants. The Freeport site produces raw materials that are used to make products people use every day such as: diapers, fertilizers, food packaging, paints, playing cards, carpets, fishing line, glue sticks, sticky note pads, wood finishes, oven bags and more." Section II- OBSERVATIONS 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- I observed that BASF is a stationary source that has an Air Operating Permit and more than a threshold quantity of a regulated substances in a process; therefore, these regulations are applicable. BASF submitted a Risk Management Plan (RMP) that describes the process containing flammable and toxic chemicals held at more than a threshold quantity. The processes are Program 3 because the facility is subject to OSHA's Process Safety Management Standard (29 C.F.R. 1910.119) and is a chemical manufacturing facility with NAICS Codes of 325211, 325199, and 325311 . 2