Document 4JvomXVqwYBqv52bwakoDZBVR
United States Environmental Protection Agency / Region 4
Risk Management Program Inspection Report
Blanchard Terminal Company LLC - Nashville 51st Nashville, Tennessee January 31, 2024
1.0 Introduction
The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA.
The focus of this inspection was to assess the RMP for the butane blending process at the Blanchard Terminal Company LLC - Nashville 51st (BTC) facility located in Nashville, Davidson County, Tennessee. This facility was selected for inspection because it had never been inspected under the RMP. The inspection, which was conducted on January 31, 2024, consisted of an examination of program documentation, as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Requested program documents were provided for further review off-site. This report will provide a background of the facility and a listing of observations.
2.0 Background
The BTC facility is located in Nashville, Tennessee. This facility uses butane for fuel blending purposes. The process is regulated as program level 3. According to facility records, the facility has a maximum of 251,606 pounds of butane on site. The butane process at the facility is subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1.
TABLE 1: Inspection Information Summary
Inspection Team
Lead Inspector: Justin Stark, U.S. EPA Inspector: Jordan Noles, U.S. EPA Inspector: Callie Sotolongo (Inspector-In-Training), U.S. EPA Date of Facility Visit: January 31, 2023
Facility Identification
Name: Blanchard Terminal Company LLC - Nashville 51st
Street Address: 1409 51st Avenue North
City: Nashville
County: Davidson State: Tennessee
EPA Facility ID No: 1000 0021 6946
Dun & Bradstreet (D&B) No: 78697868
Latitude: 36.165820
Longitude: -86.848150
Zip: 37209
Name, address and phone of corporate parent company:
Owner/Operator: MPLX Terminals, LLC.
Mailing Address: 539 South Main Street
City: Findlay
State: Ohio
Zip: 45840
Phone: 419-422-2121
Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Angela Brown Title: Terminals HESS Manager Phone: (419)-421-2629 Email: asbrown@marathonpetroleum.com
Name and title of emergency contact: Name: David Schmidt Title: Terminal Manager Day phone: (515) 297-3521 24-hour Phone: (502) 264-1494 Email: drschmidt@marathonpetroleum.com
Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Steve Strayer Title: Sr. HES Professional Phone: (419)-701-1560 Email: StStrayer@marathonpetroleum.com
Name: Dale Hildebrandt (Energy Transfer) Title: Sr. PSM Specialist Phone: (210)-502-3100 Email: dale.hildebrandt@energytransfer.com
Note: This is not a union facility.
Page 2 of 4 Blanchard Terminal Company LLC - Nashville 51st, Nashville, TN CAA 112 (r), Risk Management Program, Inspection Report
Date and Program Levels of Submitted Risk Management Plan Date of initial submission: February 22, 2012 Date of most recent submissions: March 08, 2021 Process: Butane Blending Process ID: 1000114542 Program Level as reported in RMP: 3 NAICS code: 42471 (Petroleum Bulk Stations and Terminals)
3.0 Observations The inspection of the BTC facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 3) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection began with an opening discussion of facility operations. The discussion was followed by a tour of the facility's gas processing areas. EPA inspectors then requested paperwork associated with the facility's Risk Management Plan (RMPlan). The documents were reviewed by EPA inspectors on-site and provided for review off-site. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the BTC facility are discussed below:
No compliance issues were observed during the inspection.
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Inspection Report,
Prepared by:
JUSTIN
Digitally signed by JUSTIN STARK
_S_T_A_R_K______14_:17_:1_6 -_04_'00_' ___________ Date: 2024.03.25
Justin Stark, Inspector
North Air Enforcement Section
U.S. EPA Region 4
Approved by:
Digitally signed by JASON
JASON DRESSLER DRESSLER
______________________D_a_te_: _20_2_4_.0_3._25_1_6_:2_2_:3_8_-0_4_'0_0_' Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4
Page 4 of 4 Blanchard Terminal Company LLC - Nashville 51st, Nashville, TN CAA 112 (r), Risk Management Program, Inspection Report