Document 7MnvMd5pw88bZKa8G7a5D40x6

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Ardent Mills Chattanooga, Tennessee March 31, 2022 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 chlorine storage and use in the flour bleaching process at the Ardent Mills facility located in Chattanooga, Hamilton County, Tennessee. This facility was selected for inspection because it had never been inspected under the RMP. The inspection, which was conducted on March 31, 2022, 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 Ardent Mills facility is located in Chattanooga, Tennessee. The facility uses chlorine in the flour milling process as a way to whiten the flour. The process is regulated as program level 3. According to facility records, the facility has a maximum of 12,000 pounds of chlorine on site. The chlorine storage and use 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-In-Training: Bethany Terpin, EPA Inspector: Jordan Noles, EPA Inspector-In-Training: Chet Gala, EPA Date of Facility Visit: March 31, 2022 Facility Identification Name: Ardent Mills Street Address: 1B Riverside Lane City: Chattanooga County: Hamilton EPA Facility ID No: 1000 0013 4302 Dun & Bradstreet (D&B) No: 622781300 Latitude: 35.0811868 Longitude: -085.272378 State: Tennessee Zip: 37406 Name, address and phone of corporate parent company: Owner/Operator: Ardent Mills, LLC Mailing Address: 1875 Lawrence Street, Suite 1200 City: Denver State: Colorado Zip: 80202 Phone: (866) 994-3069 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Matt Trancucci Title: Plant Manager Phone: (423) 697-6236 Email: Matt.Trancucci@ArdentMills.com Name and title of emergency contact: Name: Matt Trancucci Title: Plant Manager Day phone: (423) 697-6236 24-hour Phone: (478) 258-4601 Email: Matt.Trancucci@ArdentMills.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Matt Trancucci Title: Plant Manager Phone: (423) 697-6236 Email: Matt.Trancucci@ArdentMills.com Name: Al Hargis Title: Head Miller Phone: (423) 834-1714 Email: don.hargis@ardentmills.com Name: Kenneth Hill Title: Maintenance Manager Phone: (423) 618-0874 Email: Kenneth.hill@ardentmills.com Page 2 of 5 Ardent Mills, Chattanooga, TN CAA 112 (r), Risk Management Program, Inspection Report Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: September 11, 2014 Date of most recent submissions: August 19, 2021 Process: Flour Bleaching Process ID: 1000118349 Program Level as reported in RMP: 3 NAICS code: 311211 (Flour Milling) 3.0 Observations The inspection of the Ardent Mills 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 chlorine storage areas and the flour bleaching process in the mill. EPA inspectors then requested paperwork associated with the facility's Risk Management Plan (RMPlan). The documents were reviewed by EPA inspectors on-site and later off-site. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Ardent Mills facility are discussed below: 1. 40 C.F.R. 68.39(a) requires the owner or operator to maintain the following records on the offsite consequence analyses: For worst-case scenarios, a description of the vessel or pipeline and substance selected, assumptions and parameters used, and the rationale for selection; assumptions shall include use of any administrative controls and any passive mitigation that were assumed to limit the quantity that could be released. Documentation shall include the anticipated effect of the controls and mitigation on the release quantity and rate. At the time of the inspection, facility representatives were not able to provide documentation of the items listed above on the offsite consequence analysis for worst-case scenarios. 2. 40 C.F.R. 68.39(b) requires the owner or operator to maintain the following records on the offsite consequence analyses: For alternative release scenarios, a description of the scenarios identified, assumptions and parameters used, and the rationale for the selection of specific scenarios; assumptions shall include use of any administrative controls and any mitigation that were assumed to limit the quantity that could be released. Documentation shall include the effect of the controls and mitigation on the release quantity and rate. At the time of the inspection, facility representatives were not able to provide documentation of the items listed above on the offsite consequence analysis for alternative release scenarios. Page 3 of 5 Ardent Mills, Chattanooga, TN CAA 112 (r), Risk Management Program, Inspection Report 3. 40 C.F.R. 68.39(e) requires the owner or operator to maintain the following records on the offsite consequence analyses: Data used to estimate population and environmental receptors potentially affected. At the time of the inspection, there were no records provided on the data used to estimate population and environmental receptors potentially affected. 4. 40 C.F.R. 68.67(e) requires the owner or operator to establish a system to promptly address the team's findings and recommendations from the Process Hazard Analysis (PHA); assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; and communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. At the time of the inspection, the PHA completed in 2021 had a list of recommendations and completion dates, but it did not include a schedule of when actions were to be completed. Therefore, there is no way to assure that recommendations were resolved in a timely manner. 5. 40 C.F.R. 68.69(a)(2) requires the owner or operator to develop and implement written operating procedures that address consequences of deviations and steps required to correct or avoid deviation. At the time of the inspection, none of the operating procedures addressed consequences of deviations or steps required to correct or avoid deviation. 6. 40 C.F.R. 68.69(c) requires the owner or operator to certify annually that operating procedures are current and accurate. At the time of the inspection, there was no evidence that the facility certifies operating procedures annually. 7. 40 C.F.R. 68.79(d) requires the owner or operator to promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. At the time of the inspection, the compliance audit completed in 2019 did not have an action plan to respond to the findings of the audit, and it did not document that deficiencies had been corrected. Page 4 of 5 Ardent Mills, Chattanooga, TN CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, Prepared by: Digitally signed by BETHANY BETHANY TERPIN TERPIN __________________________D_a_te: 2022.05.2_0_1_4_:5_1_:_38__-0_4_'0_0_'_ Bethany Terpin, Inspector-In-Training Date North Air Enforcement Section U.S. EPA Region 4 Digitally signed by JORDAN JORDAN NOLES NOLES Date: 2022.05.23 15:00:05 -04'00' ____________________________ ______________ Jordan Noles, Inspector Date North Air Enforcement Section U.S. EPA Region 4 Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER ___________________________D_ate: 2022.05.2_4_0_7_:3_2_:5_7_-_0_4'_0_0'__ Jason Dressler, Section Chief Date North Air Enforcement Section U.S. EPA Region 4 Page 5 of 5 Ardent Mills, Chattanooga, TN CAA 112 (r), Risk Management Program, Inspection Report