Document 37L1oK7OEJyQqkvOxeMgD8EDJ

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: Carlisle Construction Materials, LLC Physical Address: 19727 57th Avenue East, Puyallup, Washington 98375 Phone Number: (253) 271-3045 Latitude/Longitude: 47.076185, -122.351422 RMP Facility ID# 1000 0021 9612 FRS ID#: 110054934675 EJ Concerns: No/62 percentile CONTACT INFORMATION (RMP Implementation): Name: Shawn Osler Phone Number: (253) 271-3045 E-mail: shawn.osler@carlisleccm.com EMERGENCY CONTACT INFORMATION: Name: Shawn Osler Phone (24-hr): (253) 973-7074 E-mail: shawn.osler@carlisleccm.com Website: www.carlisleconstructionmaterials.com TRIP DETAILS: Inspection Date: Inspection Time: Inspectors: June 16, 2021 09:00 through 11:45 Bob Hales, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Ed Johannes, US EPA Region 10 SEE Grantee, EPCRA Inspector Carman Marquez, US EPA Region 10, RMP Inspector in Training REPORT DATE Page 1 of 5 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: October 29, 2012 Date of Latest Update: November 15, 2019 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000104494 1000104494 Description Pentane Process Pentane Process Process Chemical ID 1000130874 1000130875 NAICS Code 32615 32615 Program Level 3 3 Chemical Name CAS Number Pentane (109-66-0) Isopentane [Butane, 2methyl] (78-78-4) Quantity (lbs) 131,500 130,250 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: If Yes, Date of Last Inspection: No Yes The facility is High Risk: Joint EPCRA inspection: No No Yes Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: 11336 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 2020 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 3/1/2021 If No, calendar year of the most recent Tier II: No Yes Did the facility submit a Tier II to the LEPC and local fire department? If Yes, Date the Tier II was submitted: 3/1/2021 No Yes INSPECTION ENTRY: Bob Hales led the inspection entry. The inspection team met with Shawn Osler and Scott Redding at the Carlisle Construction Materials LLC manufacturing facility in Puyallup Washington. The team arrived at the facility at 09:00 and was joined by the following facility personnel: Shawn Osler Scott Redding Name Title Plant Manager Environmental Manager Page 2 of 5 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: No Yes The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Bob Hales, 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. Scott Redding gave a brief description of the facility, operations, and personal protective equipment required for the tour. 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 process and is owned and operated by Carlisle Construction Materials, LLC. The Hunter Panels facility located in Puyallup, Washington manufacturers rigid polyisocyanurate foam insulating panels for use in commercial and industrial roofing applications. The company employs approximately 75 people at the facility. Hunter Panels occupies an approximate 400,000 square foot facility in Pierce County, Washington. Hunter Panels is a sister division of Insulfoam. Both divisions are part of Carlisle Construction Materials, LLC. The polyisocyanurate foam insulating panels are produced by reacting a polyol (POLY) in a blend including a flame retardant and catalyst with polymeric diphenylmethane diisocyanate (ISO). Pentane material is used as an expanding or blowing agent in the production of the panels. Different varieties of pentane material can be used including various blends of n-pentane, isopentane, and cyclopentane. Isopentane and n-pentane are regulated under the Risk Management Program (RMP) Rule with a 10,000-pound threshold. The facility receives a liquid pentane blend via tank truck and stores it in a 25,000-gallon aboveground pressure vessel for use in the production process. The storage vessel has a storage capacity of 130,250 to 155,332 pounds depending upon which pentane blend is used. The combination of various isomers of pentane is simply referred to as pentane. No distinction is made to exclude a possible cyclopentane portion of the blend from the reported regulated substance. Their current Risk Management Plan (RMP) reported a maximum intended inventory of 131,500 pounds of npentane and 130,250 pounds of isopentane. The facility stores a maximum quantity of 155,332 pounds of cyclopentane which is not a regulated substance. Page 3 of 5 ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 09:30 to 10:15. The inspection team was escorted by Mr. Osler and Mr. Redding. The inspection team observed the pentane unloading station (photo #1), the pentane storage vessel (photo # 2), the storage tank pressure relief valve (photo # 3), the transfer piping and pumps for the unloading operations (photo # 5), the storage tank pressure relief valve and the pressure relief valve isolation valve (photo # 3 and 6), the pentane gas detector at the unloading rack (photo # 8), the pentane tank overflow detector ( photo # 10), the pentane gas detector in the secondary containment for the pentane tank (photo # 11), the transfer station e-stop (photo # 12), the e-stop for the entire process (photo #13), the process e-stop at the building exit (photo # 15), the e-stop cable on the production floor (photo # 18), the finished foam conveyer (photo # 19), the pentane piping penetration from the outside storage to the process machinery (photo # 20), the pentane injection and mixing room ( photo # 21), and the pentane gas detector at the end of the process (photo #23). The expansion process machinery is provided with forced air explosion proof ventilation equipment. All of the photographs that were taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at the Carlisle Construction Materials, LLC, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a closing conference to Mr. Osler and Mr. Redding. INFORMATION COLLECTED FROM FACILITY: No additional information was collected from the facility. AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. During the tour of the facility and the covered process it was observed that they have installed an isolation valve between the pentane tank and the tank safety relief valve. 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. The standard that was followed for the installation of the isolation valve below the pentane tank safety pressure relief valve. Page 4 of 5 INSPECTION REPORT CERTIFICATION: This is to certify that I, Bob Hales, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: Hales, Bob Digitally signed by Hales, Bob ______________________________D_a_t_e_: _2_0_2_1_.0_8_._1_6_1_2_:_4_5_:5_6__-_0_7_'0_0_'_ Inspector Signature Digitally signed by JAVIER JAVIER MORALES MORALES ______________________________D__a_te_:_2_0_2_1_._0_8_.1_9__1_1_:1_5_:_2_3_-_0_7_'0_0_'_ RMP Coordinator/Approval ERIN WILLIAMS Digitally signed by ERIN WILLIAMS Date: 2021.08.19 11:04:03 -07'00' __________________________________________________________ EPCRA Coordinator/Approval Digitally signed by Jennifer A Jennifer A Sullivan Sullivan ______________________________D__a_te_:_2_0_2_1_._0_8_.1_9__1_2_:3_6_:5__2_-_0_7_'0_0_'_ Land Enforcement Section Chief/Approval Page 5 of 5