Document 99XnDyLz75oo1Z9aNNaV9zeO7

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Inspection Report FACILITY INFORMATION: Name: Pratum Co-op Physical Address: 28410 Milliron Road, Junction City, OR 97448 Phone Number: (541) 998-1121 Latitude/Longitude: 44.170872/-123.229875 RMP Facility ID# 100000052774 FRS ID#: 110070864192 EJ Concerns: No (Below 80%) CONTACT INFORMATION (RMP Implementation): Name: Michael Kesling Phone Number: (541) 998-1121 E-mail: mkesling@pratumcoop.com EMERGENCY CONTACT INFORMATION: Name: Michael Kesling Phone (24-hr): (541) 501-1596 E-mail: mkesling@pratumcoop.com TRIP DETAILS: Inspection Date: February 6, 2024 Inspection Time: 0900 hours through 0940 hours EPA Inspection Team: Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Robert Faries, Weston Solutions, Inc., EPA START Contractor Ken Valder, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: August 5, 1999 Date of Latest Update: December 18, 2020 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID 1000113499 S&H/Fertilizer Blend 1000141802 NAICS Code 325314 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 139,915 Page 1 of 4 PURPOSE: The purpose of this inspection was to determine if this facility is in compliance with Section 112(r) of the Clean Air Act and Title 40 Code of Federal Regulations (CFR) Part 68, Chemical Accident Prevention Provisions. The facility has been previously inspected in the past 5 years: No Yes The facility is High Risk: No Yes Joint EPCRA inspection: No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? No Yes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: February 17, 2023 No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: February 17, 2023 INSPECTION ENTRY: Peter Phillips led the inspection entry. The EPA Inspection Team (EPA) met with facility representatives Mandy Rebel, Maryhelen Sams, Michael Kesling at the Pratum Co-op facility in Junction City, Oregon. EPA arrived at the facility at 0900 and was joined by the following facility personnel: Name Mandy Rebel Maryhelen Sams Michael Kesling Title, Organization Compliance Director, Pratum Co-op Safety Director, Pratum Co-op Site Manager, Pratum Co-op Was a state/county/or local emergency representative present? No Yes The facility is a first responder: If No, Responding Agency: Junction City Fire Department No Yes Facility representatives escorted EPA to a conference room located in the facility's office building. Lead Inspector Peter Phillips, introduced all parties present, provided a summary of the Risk Management Program (RMP), and explained the purpose of the visit. Each EPA Inspector presented their credentials. EPA requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Michael Kesling gave a brief description of the facility, operations, and personal protective equipment required for the tour. Page 2 of 4 Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives (such as a union representative) have the right to participate in the RMP inspection, and that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: An employee representative present during the facility visit: No Yes No Yes GENERAL INFORMATION: The facility is regulated under RMP rule as a Program Level 3 facility and is owned and operated by Pratum Co-op. The facility's operations included agricultural chemical handling, storage, blending, retail sales, and distribution. Anhydrous ammonia was stored in a 30,000-gallon pressure vessel. Due to financial inefficiencies and market pressures Pratum Co-op chose to decommission the anhydrous ammonia pressure vessel and cease ammonia blending operations. On December 27, 2023, Central Washington Refrigeration performed the required maintenance to decommission the pressure vessel. On January 3, 2024, Pratum Co-op submitted a Risk Management Program De-Registration Form to the EPA. ON-SITE OBSERVATIONS: EPA toured the facility from approximately 0910 hours to 0930 hours, escorted by facility representatives Michael Kesling, Mandy Rebel, and Maryhelen Sams. The facility lead the inspection team out of the main office building into the west lot. EPA observed the decommissioned anhydrous ammonia pressure vessel and confirmed it had been decommissioned and marked appropriately (Photos 1-4). After viewing the empty tank, EPA made their way to the south lot, passing an emergency eyewash and shower station as well as a fire extinguisher (Photo 5). The south lot contained the tank farm surrounded by a secondary containment (Photos 6-8). The team entered the chemical storage building and observed various products and EPCRA chemicals (Photos 9-10). An eyewash station and flammable storage area were also located in the chemical storage building (Photo 11). Upon exiting the chemical storage building the inspection team made their way to the main shop, passing a product loading area (Photo 12). A windsock was observed on the southeast corner of the building and used oil tanks were marked next to the main entrance (Photo 13). Within the main shop were several products including herbicides and other EPRCA chemicals. Spill control materials were also observed in the main shop (Photos 14 & 15). After touring the RMP-covered process areas at the facility, EPA returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Michael Kesling, Mandy Rebel, and Maryhelen Sams. Page 3 of 4 INFORMATION COLLECTED FROM FACILITY: 1. Risk Management Program De-Registration Form 2. Management of Change Determination Form 3. 2022 Emergency and Hazardous Chemical Inventory 4. Sign-in Sheet AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: No areas of concern were identified during the inspection. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: No additional documents were requested at the time of the inspection. INSPECTION REPORT CERTIFICATION: This is to certify that I, Peter Phillips, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 4 of 4