Document LKk1LQJLwYZNE15YXez8e7YK3

SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 CLEAN AIR ACT INSPECTION REPORT MacroSource, LLC - Creve Coeur, Creve Coeur, Illinois Charles Hall, Environmental Engineer AECAB (MN-OH) Brian Dickens, Section Chief AECAB (MN-OH) File, MacroSource, LLC - Creve Coeur, Creve Coeur, Illinois BASIC INFORMATION Facility Name: MacroSource, LLC - Creve Coeur, Facility Location: 1139 Wesley Road, Creve Coeur, Illinois Date of Inspection: 25 July 2023 EPA Inspectors: 1. Charlie Hall, U.S. EPA, Region 5, Air Enforcement and Compliance Assurance Branch, MN/OH Air Enforcement and Compliance Assurance Section 2. Silvia Palomo, U.S. EPA, Region 5, Emergency Response Branch 1, Chemical Emergency Preparedness & Prevention Section Other Attendees: 1. Ryan Christopherson, Terminal Manager 2. Chad Hahn, Director of Operations 3. Michael Henry, Director of Engineering 4. Joshua Mills, Superintendent 5. Randall Sanders, Operations Team Contact Email Address: Michael.Henry@macrosource.com Purpose of Inspection: CAA 112(r) inspection Facility Type: Nitrogenous Fertilizer Manufacturing Regulations Central to Inspection: 40 C.F.R. Part 68 Arrival Time: 07:50 hrs CDT Departure Time: 10:15 hrs CDT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection. Sent Small Business Resource Information Sheet to Michael Henry by e-mail on July 31, 2023 Small Business Resource Information Sheet not provided. Provided CBI warning to facility. The following information was obtained verbally from the facility representatives. Process Description: The facility stores anhydrous ammonia as a compressed liquid in on-site storage tanks or the facility brings anhydrous ammonia to the facility in tank trucks or railcars. In the aqua mixer, liquid anhydrous ammonia from the Anhydrous Ammonia Storage reacts with water to form aqueous ammonia. The aqueous ammonia then flows into the shell and tube heat exchangers. The aqueous ammonia from the aqua mixer then flows to a shell and tube heat exchanger where the aqueous ammonia is cooled by water flowing on the shell side. The aqueous ammonia then flows to the aqueous ammonia storage tanks. The facility pumps the finished aqueous ammonia solution through the shell and tube heat exchanger and to the aqueous ammonia storage tanks. Staff Interview: The staff interview used the RMP Program Level 3 Process Checklist as an outline and focused on questions B23, B32, D3, D5, D14-18, D19-24, D26, D27, D28, D29, D31, D32, D38, D39, D40, D41, D42-46, D47-54, D58-61, D66, E1, G2, G3, G4, G5, G7, and H2. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: The RMP Program Level 3 Process Checklist (Appendix B) summarizes the observations of whether MacroSource has the required documents in its Risk Management Plan. Photos and/or Videos were taken during the inspection. Field Measurements were not taken during the inspection. Page 2 of 3 RECORDS REVIEW Before the inspection, the inspector requested the following documents: 1. Management structure in terms of RMP and who has responsibility for the different program elements and how that is documented; 2. Off-site Consequence Analysis supporting documentation; 3. Process Safety Information; 4. Process Hazard Analysis; 5. Operating Procedures specific to the covered process; 6. Lockout/Tagout procedures; 7. Training documentation on employees who operate and maintain the covered process; 8. Mechanical Integrity program procedures; 9. Management of Change written procedures; 10. Pre-Startup Safety Reviews completed in the covered process areas; 11. Compliance Audits, the two most recent audits, audit reports, findings of the audits, and how these findings have been resolved or corrected. (if applicable); 12. Incident Investigations performed for each of the covered processes, reports from the investigations, documentation on how the report findings and recommendations were addressed and resolved; 13. Employee participation plan of action regarding the implementation of the employee participation; 14. Hot work permit program/policy, examples of active permits issued for the processes; 15. Contractor policy, a list of contractors who have worked on or near the covered processes within the past two years, documentation on the safety performance and programs evaluated when selecting a contractor, work practices that control the entrance/exit or present of contractors, documentation on how applicable provisions of the emergency response program are explained to contractors; and 16. Emergency Response Plan or Emergency Action Plan. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Requested documents: The inspectors did not request additional documents. Concerns: The inspectors did not point out deficiencies or concerns during the inspection. DIGITAL SIGNATURES CHARLES Report Author: HALL Digitally signed by CHARLES HALL Date: 2023.08.11 09:03:57 -05'00' Brian Dickens Date: 2023.08.14 13:37:49 -05'00' Digitally signed by Brian Dickens Section Chief: Page 3 of 3 APPENDICES AND ATTACHMENTS A. Digital Image Log B. RMP Program 3 Checklist Facility Name: MacroSource, LLC - Creve Coeur Facility Location: 1139 Wesley Road, Creve Coeur, Illinois Date of Inspection: 25 July 2023 APPENDIX A: DIGITAL IMAGE LOG Photographer: Charles Hall Camera: Olympus Tough TG-6 EPA Bar Code: SZ4061 Image File Name Date and Time Description of Image Number 1 P7250082.jpg 07/25/2023 10:43 hrs Ammonia unloading 2 P7250083.jpg 07/25/2023 10:46 hrs Ammonia Unloading. Manual shutoff and Emergency Shutoff valves on each liquid and vapor line. Appendix A Page 1 of 4 Facility Name: MacroSource, LLC - Creve Coeur Facility Location: 1139 Wesley Road, Creve Coeur, Illinois Date of Inspection: 25 July 2023 Image File Name Date and Time Description of Image Number 3 P7250084.jpg 07/25/2023 10:48 hrs East end of ammonia bullet and ammonia sensor. Grind spots for thickness ntests. 4 P7250085.jpg 07/25/2023 10:48 hrs Internal safety valve actuator (black) Emergency shut off valve (red) Appendix A Page 2 of 4 Facility Name: MacroSource, LLC - Creve Coeur Facility Location: 1139 Wesley Road, Creve Coeur, Illinois Date of Inspection: 25 July 2023 Image File Name Date and Time Description of Image Number 5 P7250086.jpg 07/25/2023 10:55 hrs Piping (white) to ammonia bullet 6 P7250087.jpg 07/25/2023 10:55 hrs Unloading area with containment. Appendix A Page 3 of 4 Facility Name: MacroSource, LLC - Creve Coeur Facility Location: 1139 Wesley Road, Creve Coeur, Illinois Date of Inspection: 25 July 2023 Image File Name Date and Time Description of Image Number 7 P7250088.jpg 07/25/2023 10:57 hrs Reactor and heat exchanger 8 P7250089.jpg 07/25/2023 11:05 hrs Ammonia bullet. Pressure relief valves on top left. Ammonia sensor in middle of tank. Appendix A Page 4 of 4 Facility Name: MacroSource, LLC - Creve Coeur Facility Location: 1139 Wesley Road, Creve Coeur, Illinois Date of Inspection: 25 July 2023 APPENDIX B: RMP PROGRAM 3 CHECKLIST Appendix B