Document Eq8v2pv1RnYEyxZegVd57jgv4

Clean Air Act - Risk Management Program - Section 112(r) Emergency Planning Community Right-to-Know Act - Sections 302, 311 and 312 On-site Compliance Inspection Report Avantor Sciences, VWR International PURPOSE The purpose of this On-site Compliance Inspection was to determine compliance with the Clean Air Act Section 112(r) Risk Management Program and the Emergency Planning and Community Right to Know Act Sections 302, 311, and 312. CAA Section 112(r) requires facilities that hold chemicals over threshold quantities to have a Risk Management Program. EPCRA Section 311 requires facilities that hold chemicals above the reporting threshold to submit copies of the SDSs or a list of these chemicals to the State Emergency Response Commission, the Local Emergency Planning Committee, and the local fire department. EPCRA Section 312 requires the Annual Chemical Inventory Reports (Tier II) for the current calendar year to be submitted by March 1 of the following year. The Tier II is required to be submitted to the SERC, LEPC, and fire department. EPCRA Section 302 requires any facility that has any EHS above the threshold planning quantities to notify the SERC and LEPC. LEPCs should also include the EHS(s) in their emergency response plans. Facilities covered under EPCRA Section 312 are required to indicate on the Tier II if they are subject to EPCRA Section 302 emergency planning requirements. COMPANY INFORMATION Name: Avantor Sciences Mailing Address: 12350 SW Tualatin Rd. #B Tualatin, OR, 97062 Website: aventorsciences.com FACILITY INFORMATION Name: VWR International, LLC. Mailing Address: 12350 SW Tualatin Rd. #B Tualatin, OR, 97062 Latitude/Longitude: 45.387681; -122.802810 RMP Facility ID#: 1000 0023 1661 EPCRA Tier II ID#: 62200 FRS ID#: 110018492031 EJ Concerns: Yes (94%) Page 1 of 6 CONTACT INFORMATION (RMP Implementation) Name: Matt Lyster Title: Service Center Manager Phone Number: 503-404-2211 E-mail: matthew.lyster@aventorsciences.com EMERGENCY CONTACT INFORMATION Name: Matt Lyster Title: Service Center Manager Phone Number: 503-550-0410 E-mail: matthew.lyster@aventorsciences.com INSPECTION DETAILS Inspection Date: Inspection Time: Inspectors: 3/15/2024 0850 hours - 1120 hours Mhara Coffman, US EPA R10, Lead RMP/EPCRA Inspector Terry Garcia, US EPA R10, RMP/EPCRA Inspector Peter Phillips, US EPA R10, RMP/EPCRA Inspector Edward Johannes, US EPA R10, RMP/EPCRA Inspector Thomas Vroman, CIH, Weston Solutions, Inc., EPA START Contractor On March 1, 2024, EPA emailed a Notice of Inspection Letter to the facility informing them of a planned RMP and EPCRA inspection. The letter included 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. A copy of the letter must be provided to the employee representatives and the letter posted in a manner accessible to employees in the facility. Is the facility unionized? If yes, name of union: Was an employee representative present during the inspection? If yes, name/title: Yes No Yes No GENERAL INFORMATION The facility is regulated under the Risk Management Program as a Program Level 2 facility and is owned and operated by Avantor Sciences. There are eight full-time employees on site. VWR International, LLC is a warehousing and distribution company, that receives, stores, and loads RMP-regulated chemicals for delivery to customers. The two RMP-regulated chemicals at the facility are hydrofluoric acid (HF) (concentrations over 50%), and hydrochloric acid (HCl) (anhydrous). These covered chemicals are stored in a segregated Corrosive Room with other non-RMP-regulated corrosives. Page 2 of 6 DATE AND PROGRAM LEVELS OF SUBMITTED RMP Initial Submission Date: March 28, 2016 Date of Latest Update: March 26, 2021 Has the facility been inspected in the past 5 years? Yes No If yes, date of last inspection: Homeland Security inspection on February 20, 2020 Is the facility High Risk? Yes No Process (as reported in the RMP) Process ID Description 1000115437 1000115437 Warehouse Warehouse Process Chemical ID 1000144325 1000144326 NAICS Code Program Level 2 2 Chemical Name CAS Number 7664-39-3 7647-01-0 Quantity (lbs.) 15,000 30,000 CAA TITLE V AIR PERMIT Does the facility have a CAA Title V Permit? If yes, permit number: Yes No EMERGENCY RELEASE / ACCIDENT HISTORY Did an RPM reportable release occur in the past 5 years? Did a CERCLA/EPCRA reportable release occur in the past 5 years? If either yes, date and description of release: Yes No Yes No EPCRA 312 - TIER II REPORT Was the 2023 Tier II report submitted to the SERC? If yes, date Tier II was submitted: February 15, 2024 Yes No Was the 2023 Tier II submitted to the LEPC/fire department? If yes, date Tier II was submitted: February 15, 2024 Yes No Is the facility subject to EPCRA Section 302? If yes, is it correctly checked on the Tier II? Yes No Yes No Is the subject to RMP correctly checked on the Tier II? Is RMP facility ID correct on the Tier II? Yes No Yes No Page 3 of 6 EPCRA CHEMICALS OVER THRESHOLD According to the most recent Tier II, the facility stores the following hazardous chemicals over the reporting threshold. See the attached Tier II, Attachment C, for inventory amounts. Chemical Name Chloroform Hydrochloric Acid Solution Hydrofluoric Acid Sulfuric Acid EHS (Yes or No) Yes Yes Yes Yes CAS Number 67-66-3 7647-01-0 7664-39-3 7664-93-9 EPCRA 311 - SDSs EHS onsite are chloroform, hydrochloric acid solution, hydrofluoric acid, and sulfuric acid. See Attachment B for SDSs and chemical information on each EHS stored over the reporting threshold at the Facility. EPCRA 302 - LEPC Coordination VWR Inc. last contacted the LEPC in 2022. LEPC Agency: Washington County LEPC Program Contact: Chad Oyler Title: Chair Address: 1400 SW Walnut Street Suite 241, MS 30 Hillsboro, Oregon 97123 Phone Number: (510) 857-7982 Email: Chad.oyler@lamresearch.com Website: https://www.oregon.gov/osfm/pages/default.aspx INSPECTION ENTRY Mhara Coffman led the inspection entry. The inspection team met with Marc Gonzales at the VWR International LLC facility in Tualatin, OR. The team arrived at the facility at 0900 hours and was joined by the following facility personnel: Name Marc Gonzales Matt Lyster Steve Mayhew (virtual attendee) Ralph Garcia (virtual attendee) Maria Cedillo (virtual attendee) Vik Lakhan (virtual attendee) Title EHS Manager SC Manager Regulatory Manager Distribution Director Distribution Manager Inventory Manager Were any SERC, LEPC or fire department representative present? Yes No If yes, names and titles of representatives: Mary Ann Christian, Office of State Fire Marshall LEPC Coordinator Is the facility a first responder? Page 4 of 6 Yes No If no, responding agency: Tualatin Vally Fire and Recure The inspection team was escorted to a conference room. Introductions were made by Mhara Coffman, who provided a summary of the risk management program and explained the purpose of the visit. Each team member 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. Facility representatives informed the inspection team that they would be required to wear a high-visibility vest and closed-toed shoes. FACILITY TOUR / ON-SITE OBSERVATIONS The facility tour was conducted from approximately 0930 hours to 1000 hours. The inspection team was escorted by Matthew Lyster and Marc Gonzales. The inspection team observed the Corrosive Room where the facility stores RMP-regulated chemicals on shelves (Photo 1). The Corrosive Room stores containers of HCl product (Photos 2 and 3), HF product (Photo 4), and non-RMP-regulated corrosive products (Photo 5) and is equipped with a ventilation system on a backup generator. The Corrosive Room includes a hazardous waste disposal staging area (Photo 6), an emergency shower and eye wash (Photo 7) and posted checklists for corrosive inventory (Photo 8) and hazardous waste disposal (Photo 9). EPA observed spill control supplies (Photo 10) and NFPA placarding (Photo 11) immediately outside the Corrosive Room. The Corrosive Room does not have any chemical sensors or alarm systems. EPCRA-regulated lead acid batteries power the facility's forklifts and are staged in a designated Battery Recharge Area of the facility (Photos 12 and 13). An emergency eye wash station is located at the Warehouse Entry (Photo 14). Photographs were taken of the warehousing and distribution operations. The photographs are included in Attachment A. After touring the RMP-covered process areas and the EPCRA chemical storage areas, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Mark Gonzales and Matt Lyster. INFORMATION COLLECTED FROM FACILITY 1. Warehouse Evacuation Routes Map 2. Administrative Offices Evacuation Routes Map 3. Hazard Review Revalidation: Recommended Actions section. Page 5 of 6 AREAS OF CONCERNS The following is a list of areas of concern identified. 1. VWR International LLC did not provide documentation on the emergency coordination activities required by 68.93 that was in effect since September 21, 2018. [68.10(b)]. VWR International LLC did not conduct emergency coordination in 2021 and 2023. 2. VWR International LLC did not ensure that hazard review problems identified were resolved in a timely manner. [68.50(c)]. A 2021 hazard review finding 21HR01 recommended maintaining emergency coordination documentation with other RMP records. There were no emergency coordination records for 2021 and 2023 on file. FOLLOW-UP DOCUMENTS REQUESTED The following documents were unable to be located during the inspection by the facility representatives. The documents were requested to be sent to EPA by March 28, 2024. These documents were reviewed after the inspection to determine compliance with Section 112(r) of the Clean Air Act. 1. 2018 and 2021 Compliance Audit certification pages 2. Emergency Response Plan (particularly the date it was drafted and finalized) 3. Completed operator training form ON-SITE INSPECTION REPORT CERTIFICATION This is to certify that I, Mhara Coffman, as the lead inspector for the On-site Compliance Inspection and that I have verified the accuracy of the information in this report. __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator Signature __________________________________________________________ EPCRA Coordinator Signature __________________________________________________________ Land Enforcement Section Chief Signature ATTACHMENTS A. Photographs (Photo Log and Layout) B. Tier II Report Page 6 of 6 Attachment A - Photo Log Site Name: Avantor Sciences, VWR International LLC City, State: Tualatin, OR Photographer: Tom Vroman File Photo1.jpg Photo2.jpg Photo3.jpg Photo4.jpg Photo5.jpg Photo6.jpg Photo7.jpg Photo8.jpg Photo9.jpg Photo10.jpg Photo11.jpg Photo12.jpg Photo13.jpg Photo14.jpg Photo Layout ID Date 1 3/15/2024 2 3/15/2024 3 3/15/2024 4 3/15/2024 5 3/15/2024 6 3/15/2024 7 3/15/2024 8 3/15/2024 9 3/15/2024 10 3/15/2024 11 3/15/2024 12 3/15/2024 13 3/15/2024 14 3/15/2024 Time 9:40 AM 9:40 AM 9:40 AM 9:41 AM 9:44 AM 9:44 AM 9:45 AM 9:45 AM 9:46 AM 9:47 AM 9:47 AM 9:48 AM 9:49 AM 9:49 AM Description Corrosive Room; Shelf storage of corrosives Corrosive Room; HCl storage Corrosive Room; HCl storage Corrosive Room; HF storage (top left box) Corrosive Room; Non-RMP-regulated corrosives Corrosive Room; Hazardous waste disposal staging area Corrosive Room; Emergency shower and eyewash Corrosive Room; Corrosive room checklist Corrosive Room; Hazardous waste disposal checklist Outside Corrosive Room; Spill control supplies Outside Corrosive Room; NFPA placard Battery Recharge Area; Recharging for lead-acid batteries Battery Recharge Area; Emergency shower and eyewash Warehouse Entry; Emergency eyewash