Document 3Qdn4jLJj0xv2X88eVGXgD2E3

EPA Inspection Report - PagePage 1 of 5 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/3-5/2024 Air Clean Air Act (CAA) Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions - Risk Management Program (RMP) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Airgas, Inc. Airgas USA, LLC 4344 South Main Street Pearland, Texas 77581 259 N. Radnor-Chester Road Radnor, PA 19087 Harris County 713-433-3998 Trae Gressett Trae.gressett@airgas.com Area Plant Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000463720 RMP 1000 0003 6962 42469 Personnel participating in inspection: Dan Farris Airgas USA Vu Truong Airgas USA Trae Gressett Airgas USA Sherronda Phelps US EPA Airgas VP HSE IMS Manager Area Plant Manager CAA Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date Sherronda Phelps 08/06/2024 Date SAMUEL TATES Date: 2024.08.08 15:23:29 -05'00' Digitally signed by SAMUEL TATES Samuel Tates Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - PagePage 2 of 5 Section I - INTRODUCTION Airgas, Inc. / Airgas USA, LLC Inspection Date: 06/03/2024 PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector, Sherronda Phelps, arrived at the Airgas USA (Airgas Pearland) facility at 9:00 AM on June 3, 2024, for an announced inspection. I met with Trae Gressett, Area Plant Manager, and other facility personnel at the opening conference. I presented my credentials to all present and informed them that this was an EPA inspection to determine compliance with the federal Chemical Accident Prevention Program. The scope of the inspection was a partial compliance evaluation (PCE), which included an assessment of the facility's compliance with the Clean Air Act (CAA) Section 112(r), the General Duty Clause CAA 112(r)(1), and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68, CAA 112 (r)(7). Pursuant to section 112(r)(6)(L) of the CAA, an employee representative was invited to participate in the inspection; however, this site is a non-union facility. FACILITY DESCRIPTION According to the facility's executive summary, the Airgas Specialty Gases facility handles gases that are repackaged from storage vessels into tube trailers and cylinders. Airgas Houston handles Butane, Isobutane, 2-Methylpropene, Propane, 1-Butene, Propylene, Ethylene, Ethyl Chloride and Methyl Chloride (toxic) at this location. Both flammable and toxic substances being handled meet the threshold quantity as determined under 40 CFR 68.115. The facility employs approximately 10 full-time employees (FTE's). Section II - OBSERVATIONS The initial documentation review began in person with Trae Gresset, Area Plant Manager, Vu Truong, IMS Manager, Josh Bevan, Project Engineer and Lance Rodriguez, Safety Manager. 40 C.F.R. Part 68 - CHEMICAL ACCIDENT PREVENTION PROVISION Subpart A - General 40 C.F.R. 68.10 Applicability - Airgas Pearland is a stationary source that has more than a threshold quantity of regulated substances in their process. The last submittal was made July 31, 2020, due to the five-year resubmission date. Airgas Pearland is a RMP Program 3 facility. The facility is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119). 40 C.F.R. 68.12 General requirements - Airgas Pearland submitted their most recent RMP submission on July 31, 2020. The regulated substances Butane, Isobutane, 2-Methylpropene, Propane, 1-Butene, Propylene, Ethylene, Ethyl Chloride and Methyl Chloride are the regulated substances listed over the threshold quantity for the RMP Program Level 3 processes. 40 C.F.R. 68.15 Management - Airgas Pearland developed a management system to oversee the implementation of the risk management program elements. Airgas Pearland provided an organizational 2 EPA Inspection Report - PagePage 3 of 5 Airgas, Inc. / Airgas USA, LLC Inspection Date: 06/03/2024 chart that outlined the positions to implement the individual elements of the RMP, as required by this subpart. Subpart B - Hazard Assessment 40 C.F.R. 68.20 Applicability - Airgas Pearland operates a RMP program level 3 process which is subject to this subpart and thus is required to prepare a worst-case release scenario analysis and complete the five-year accident history. I reviewed the documentation provided to make this analysis and identified no areas of concern with this subpart. 40 C.F.R. 68.36 Review and update - Airgas Pearland understands documentation associated with the worst-case scenarios that should be updated and reviewed at least every five years and are anticipating a review in 2025. 40 C.F.R. 68.39 Documentation - Airgas Pearland operates a RMP program level 3 process which is subject to this subpart and thus is required to prepare a worst-case release scenario analysis and complete the five-year accident history. I reviewed the documentation provided to make this analysis and identified no areas of concern with information pertaining to this subpart to include the Offsite Consequence Analysis (OCA) data. The facility used the EPA Model RMP*CompTM. 40 C.F.R. 68.42 Five-year accident history - Airgas Pearland did not report any accidental release(s) in their RMP that resulted in deaths, injuries, or property damage. Subpart D - Program 3 Prevention Program 40 C.F.R. 68.65 Process safety information - I reviewed various sections of the process safety information for the RMP covered processes at Airgas Pearland. 40 C.F.R. 68.67 Process Hazard Analysis (PHA) - I reviewed the last PHA completed August 29, 2023. The PHA study was conducted using What-if, Checklist, and the Hazard and Operability Analysis (HAZOP) method via the Airgas Internal Risk group. 40 C.F.R. 68.69 Operating procedures - I reviewed several operating procedures for the process. I reviewed and discussed with Airgas Pearland personnel operating procedures, which included, the Standard Operating Procedure (SOP) certification procedure, confined space entry, and lockout/tag out procedures. Airgas Pearland certified that the operating procedures were current, accurate, and that the procedures were reviewed as often as necessary, as required by this subpart, and used a single certification document for operating procedures annually. 40 C.F.R. 68.71 Training - I requested and was provided the training files for several employees at different experience levels. I reviewed the training transcript history of several employees to check for refresher training and the initial trainings required. Airgas Pearland is implementing the necessary training program as required. Training is a combination of in-class, computer based as well as on the job training. Airgas makes use of Training Tracker to monitor the completion dates of all training. 40 C.F.R. 68.73 Mechanical integrity - I reviewed mechanical integrity records for randomly, selected inspections of RMP covered process equipment and the written procedure for 3 EPA Inspection Report - PagePage 4 of 5 Airgas, Inc. / Airgas USA, LLC Inspection Date: 06/03/2024 maintaining the integrity of the process. There were no past due or overdue inspection items noted. 40 C.F.R. 68.75 Management of change (MOC) - Airgas Pearland has a written procedure for MOC and the documentation with site personnel. The MOCs were implemented using an electronic system. I reviewed several MOCs to evaluate the implementation of the procedures in place. 40 C.F.R. 68.77 Pre-startup safety review - Airgas Pearland provided documentation regarding prestartup safety review. I reviewed several PSSR's while on site to follow the implementation of this element. No areas of concern were noted here. 40 C.F.R. 68.79 Compliance audits - Airgas Pearland conducted a PSM/RMP compliance audit of the facility in June of 2021 and February of 2024. Action Items from the audit were placed in the electronic tracking system titled, Intelex. I followed up on several items from the most recent audit to observe follow through and implementation of each action item created. Airgas brought each action item to a close in a timely manner as required by the regulation. 40 C.F.R. 68.81 Incident investigation - I reviewed a list of incident reports/investigations for all incidents, which resulted in, or could have reasonably resulted in, a catastrophic release of a regulated substance for the last five years. Airgas Pearland did not have any incident reports/investigations that met these criteria. 40 C.F.R. 68.83 Employee participation - Airgas Pearland implemented the requirements of this subpart. There were no areas of concern noted. 40 C.F.R. 68.85 Hot work permit - Airgas Pearland discussed the process for conducting hot work onsite. The facility has had no recent hot work to occur onsite within the last two years. 40 C.F.R. 68.87 Contractors - Airgas Pearland makes use of a tiered system when selecting contractors to bring onsite. Airgas Houston makes certain that all contractors that may work onsite have been trained on the potential hazards related to both the process equipment and the work that the contractor may perform. Contractors must sign in and sign out daily to track their presence while onsite. Subpart E - Emergency Response 40 C.F.R. 68.90 Applicability - Airgas Pearland employees are not first responders. 40 C.F.R. 68.95 Emergency response program - I reviewed Airgas Pearland Emergency Action Plan, and the plan addresses all the needed information. Subpart G - Risk Management Plan 40 C.F.R. 68.190 Updates - There have been no recent additions or upgrades to the unit that would have triggered an update to the Risk Management Plan. 40 C.F.R. 68.195 Required corrections -The next RMP re-submission is due by July 31, 2025, unless an update or correction is required by 40 C.F.R. 68.190 and 68.195. 4 EPA Inspection Report - PagePage 5 of 5 Airgas, Inc. / Airgas USA, LLC Inspection Date: 06/03/2024 Section III - AREAS OF CONCERN There were no areas of concern noted from this inspection. Closing Meeting- EPA Region 6 inspector, Sherronda Phelps, conducted a closing conference at Airgas Pearland on June 5, 2024, for the inspection. During the closing conference, Sherronda Phelps, reviewed the elements covered during the inspection and any suggested recommendations made during the inspection. However, there were no AOC's to be noted from this inspection. Section IV - FOLLOW UP There was no additional information provided. Section V - LIST OF APPENDICES There are no photos, videos, or other appendices to share. 5