Document 7RDaR9QjYxmNqBDBYzRNwN7Yj

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Brenntag Mid-South, Inc. Henderson, Kentucky August 10, 2023 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 chemical distribution process at the Brenntag Mid-South, Inc., facility located in Henderson, Henderson County, Kentucky. This facility was selected for inspection because it hadn't been inspected under the RMP within the last five years. The inspection, which was conducted on August 10, 2023, 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 Brenntag Mid-South, Inc., facility is located in Henderson, Kentucky. The facility stores, repackages, and distributes chemicals such as cyclohexylamine, chlorine, sulfur dioxide, anhydrous ammonia, aqua ammonia, and hydrofluoric acid. Each chemical is regulated under its own program level and the processes are regulated as program level 2 and program level 3. In addition to repackaging chemicals for distribution, the facility also manufactures bleach by mixing chlorine with sodium hydroxide. The chemical distribution 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: Jordan Noles Inspector: Chet Gala Inspector-in-Training: Justin Stark Date of Facility Visit: August 10, 2023 Facility Identification Name: Brenntag Mid-South, Inc. Street Address: 1405 Highway 136 West City: Henderson County: Henderson EPA Facility ID No: 100000044034 Dun & Bradstreet (D&B) No: 41167107 Latitude: 37.810556 Longitude: -087.654833 State: Kentucky Zip: 42420 Name, address and phone of corporate parent company: Owner/Operator: Brenntag North America Mailing Address: 5083 Pottsville City: Loveland State: Colorado Zip: 80538 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Mike Theising Title: Operations Manager Phone: (270) 860-5984 Email: michael.theising@brenntag.com Name and title of emergency contact: Name: Mike Theising Title: Operations Manager Day phone: (270) 830-1369 24-hour Phone: (270) 860-5984 Email: michael.theising@brenntag.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Joe Pryor Title: SRQ Manager Phone: (270) 577-1956 Email: joe.pryor@brenntag.com Name: Mike Theising Title: Operations Manager Phone: (270) 860-5984 Email: michael.theising@brenntag.com Name: Jacob Miller Title: SRQ Coordinator Phone: (270) 454-4194 Email: jwmiller@brenntag.com Page 2 of 6 Brenntag Mid-South, Inc., Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report Name: Bill Wilson Title: Regional Operations Manager Phone: (270) 860-5681 Email: bwilson@brenntag.com Name: Alex Fruit Title: Production Manager Phone: (270) 860-7039 Email: afruit@brenntag.com Name: Bryon Mason Title: Director QSHE Phone: (270) 724-8380 Email: bmason@brenntag.com Name: John Warner Title: Regulatory Compliance Manager Phone: (270) 748-6210 Email: john.warner@brenntag.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: June 17, 1999 Date of most recent submissions: November 18, 2021 Process ID 1000121073 Process Description Cyclohexylamine Process Chemical ID 1000151518 Process Program Level Level 2 Chemical Name CAS Number Cyclohexylamine 108-91-8 Quantity (lbs) 50,000 1000121074 Chlorine Storage 1000151519 Level 3 Chlorine 7782-50-5 1,800,000 1000121075 1000121076 1000121077 1000121078 Sulfur Dioxide Storage Anhydrous Ammonia Aqua Ammonia 1000151520 1000151521 1000151522 Level 3 Level 3 Level 3 Hydrofluoric Acid 1000151523 Cont. Level 3 Sulfur Dioxide (anhydrous) 7446-09-5 Ammonia (anhydrous) 7664-41-7 Ammonia (conc 20% or greater) 7664-41-7 Hydrogen fluoride/Hydroflu oric acid (conc 50% or greater) 7664-39-3 1,500,000 265,000 350,000 17,000 Page 3 of 6 Brenntag Mid-South, Inc., Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report Flammable / Toxic Toxic Toxic Toxic Toxic Toxic Toxic 3.0 Observations The inspection of the Brenntag Mid-South, Inc., facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 2/3) 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 chemical distribution process area. 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 Brenntag Mid-South, Inc., facility are discussed below: 1. 40 C.F.R. 68.39(a) requires the owner or operator to maintain records on the offsite consequence analyses for worst-case scenarios, including a description of the vessel or pipeline and substance selected as worst case, 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. Facility representatives provided the worst-case scenario; however, the rationale for selecting the scenario was not included in the documents. 2. 40 C.F.R. 68.39(b) requires the owner or operator to maintain records on the offsite consequence analyses for alternative release scenarios, including 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. Facility representatives provided the alternative release scenario; however, the rationale for selecting the scenario was not included in the documents. 3. 40 C.F.R. 68.65(d)(2) requires the owner or operator to document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP). At the time of the inspection, the pipes around the two 30,000-gallon ammonia tanks and the sulfur dioxide tank were not consistently labeled. Some pipes had direction of flow, but the contents labeling is lacking on the pipes. The ammonia piping should be labeled/colored in accordance with the Pipe Marking Guide, American National Standard Institute/American Society of Mechanical Engineers (ANSI/ASME) A13.1 - 2007 Standard for the Identification of Pipes. Page 4 of 6 Brenntag Mid-South, Inc., Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report 4. 40 C.F.R. 68.73(e) requires the owner or operator to correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in 40 C.F.R. 68.65) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. Facility representatives provided the inspection team with inspection reports for Ammonia Tanks AA-1 and AA-2. The reports were generated from external inspections and ultrasonic (UT) testing that were conducted on the two 30,000gallon ammonia tanks on November 02, 2021, by a third-party company, Applied Technical Services. The results from the tests indicate the thickness is below the minimum allowable value on three components for each ammonia tank and one on the sulfur dioxide tank. Observation 2 in the "Observation" column on page 6, "Recommendations" of each report states, "Multiple shell and head readings were at or below the required minimum thickness. Pitting was present throughout the exterior ranging from 1/32" - 1/16"." Under the "Recommended Action" column, the report states, "Re-rate the vessel using an allowable stress based off the latest edition of the ASME Code Per API-510 8.2 (i.e. 3.5 a design factor vs. the original 4.0 design factor). -OR- Re-rate the vessel to a lower MAWP." This recommendation has a priority ranking of one (1) - "High likelihood/consequence of failure (or) Critical code/standard deficiency (or) May not be fit for service without action. After the inspection, facility representatives reached out to another contractor, PK Mechanical LLC (PK), to assist with determining if a re-rate of the vessel would be acceptable for the two ammonia tanks. The facility drafted a document labeled Memorandum for Record: Mechanical Integrity. The document states, "PK conducted calculations and determined that re-rating our tanks to allowable stress values of the latest ASME design code (rather than the original ASME design code - ASME Sec VIII Div. 1 1993 Edition w/ Winter 1984 Addenda) would be safe. ...PK Mechanical is submitting a formal request for re-rate on our behalf. After official review and pressure testing of vessels, the tanks will be officially re-rated to new allowable stress values." It has been nearly two years since the UT tests were performed on the anhydrous ammonia vessels and the facility did not take action until after the RMP inspection on August 10, 2023. Page 5 of 6 Brenntag Mid-South, Inc., Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, Prepared by: JORDAN Digitally signed by JORDAN NOLES Date: 2023.10.16 _N_O__L_E_S_______1_1:_29_:2_1 _-0_4'0_0'________ Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 Approved by: JASON Digitally signed by JASON DRESSLER Date: 2023.10.16 _D_R__E_S_S__L_E_R___1_0:_44_:3_1 -_04_'0_0'______________________ Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4 Page 6 of 6 Brenntag Mid-South, Inc., Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report