Document 6bpnpjX8QBx0QwQoLn218Kwgm

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 06/19/2018-06/21/2018 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Clariant Corporation Clariant Clear Lake Plant 9502 Bayport Blvd. Pasadena, Texas 77507 (same as above) (same as above) Harris Donald Bartlett donald.bartlett@clariant.com I Site Manager FRS Number: Identification/Permit Number: Media Number: NAICS: 110067040703 New Source Review Permit No. 22872 RMP EPA Facility Identifier: 100000201872 325613 =Surface Active Agent Manufacturing Personnel participating in inspection: Tony Robledo US EPA/6EN-AS Donald Bartlett Clariant Corporation EPA Lead Inspector Signature/Date -- ,..... LJv Tony Robledo Inspector Site Manager ~cJln.-"") (214) 665-8182 (281) 546-9410 7/t7/ts Date Supervisor Signature/Date e. ,. Samuel Tates 1ch ?f,? /l-ore Date 6ENFORM-019-R6 (10/6/14) 1 Clariant Clear Lake Plant Inspection Dates 06/19/18-06/21/18 Section I -INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo arrived at the Clariant Clear Lake Plant (Ciariant) at approximately 9:00a.m. on June 19, 2018, for an announced inspection. I conducted an opening meeting with the following persons in attendance as identified in Table 1. Table 1: Opening Meeting Attendance Name . ... Position . . ... .. .. Donald Bartlett Operations Manager Karleen Francis Terrell Williams Fernando Colombo Safety Environmental Officer Regional Project Manager Regional Operations Andre Pollard Chris Smart Tony Robledo Process Excellence Manager Operations Specialist Inspector & Enforcement Officer EPA Region 6 I presented my credentials to all attendees at the opening meeting, and informed them that this EPA inspection was to determine compliance with Clean Air Act Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the compliance with 40 C.F.R. Part 68- Chemical Accident Prevention Provisions. FACILITY DESCRIPTION The Clariant facility uses ethylene oxide and sulfur dioxide to produce a wide variety of soaps, detergents and agricultural products for use in consumer and industrial products. The ethoxylation unit produces products in reactors through the controlled reaction of ethylene oxide with various longchained alcohols, ethers, polyols, fatty acids, or sodium bisulfite. Other raw materials are used to control the reaction and produce on-spec products. Raw materials come in through rail and truck unloading. The ethoxylation of raw materials is accomplished in a batch process. A portion of material will be converted from liquid to solid flakes or powders in a new solids handling facility. Finished produ.cts are shipped out via truck and rail as well. The facility has about 35 full-time employees. There are no listed flammable substances, only toxics- ethylene oxide and sulfur dioxide (anhydrous), which exceed their respective threshold quantities stored at this facility. Section II- OBSERVATIONS I conducted a walk-through of the facility on June 20,2018, accompanied by Clariant personnel to observe the facility process, equipment, pressure vessels, storage tanks, and operation. I observed no visible spills, leaks, or air emissions. The facility grounds appeared to be well maintained. 2 Clariant Clear Lake Plant Inspection Dates 06/19/18-06/21/18 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- Clariant is an owner and operator of a stationary source that has more than a threshold quantity of regulated toxic substances, listed in 40 C.F.R. 68.130, in a process, and as such is subject to these Chemical Accident Prevention Provisions. Clariant listed the NAICS code (325613) surface active agent manufacturing, as the process in its Risk Management Plan (RMP). The Clariant facility process is also subject to the Occupational Safety and Health Administration (OSHA) process safety management standard, 29 C.F.R. 1910.119. These factors make the process at the Clariant facility a Program 3 subject to 40 C.F.R. 68.10(d). 40 C.F.R. 68.12 General Requirements- Clariant re-submitted a RMP five-year update on April 4, 2018. This submittal lists a covered process for Program 3. This requires the facility to develop and implement a management system, conduct a hazard assessment, implement the prevention requirements of 40 C.F.R. 68.65- 68.87, develop and implement an emergency response program, and submit the data elements from 40 C.F.R. 68.175 in their RMP. 40 C.F.R. 68.1S Management- Clariant has an established management system to oversee the implementation of the risk management program elements, and has assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements. Clariant facility personnel provided job descriptions which documents the persons responsible for implementing individual requirements of the RMP as required by this subpart. Subpart B- Hazard Assessment 40 C.F.R. 68.20 Applicability- Clariant is an owner or operator of a stationary source subject to this subpart with a Program 3 process that must prepare an offsite consequence analysis as provided in 68.25 of this subpart, complete the five-year accident history as provided in 68.42, and comply with all sections in this subpart for this process. 40 C.F.R. 68.22 Offsite Consequence Analysis Parameters -I requested documentation of the offsite consequences analysis. I reviewed the documentation provided and had a discussion with appropriate Clariant facility personnel. Clariant applied the offsite consequence analysis parameters as required by this subpart. 40 C.F.R. 68.25 Worst-Case Release Scenario Analysis- Clariant identified and reported a worst-case release scenario analysis for the RMP covered toxic substances. I requested documentation of the worst-case release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Clariant facility personnel. Clariant selected a sulfur dioxide tank for the worst-case release scenario. Clariant used EPA's RMP* Comp'" to determine the distance to the endpoint in the worst-case release scenario. Clariant used the proper endpoints for toxics as required by this subpart. 40 C.F.R. 68.28 Alternative Release Scenario Analysis- Clariant identified and reported an alternative release scenario for the RMP covered toxic substances. I requested documentation of the alternative release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Clariant facility personnel. Clariant selected two alternative release scenarios from its covered process, one containing sulfur dioxide and the other one containing ethylene oxide. Clariant used EPA's RMP* 3