Document MM4G7mJxK5a2jJbE5Bk63mqpk

UNITED STATES UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 ENVIRONMENTAL 1200 Sixth Avenue, Suite 155 Seattle, WA 98101ENFORCEMENT & PROTECTIONCOMPLIANCE ASSURADINVISICON E Clean Air Act - Section 112 (r) Risk Management Program and EPCRA 312 - - Tier II Facility Inspection Report FACILITY INFORMATION: Name:Univar Anchorage Physical Address:590 East 100th Avenue, Anchorage, AK 99515 Phone Number:(907) 529-6775 Latitude / Longitude: 61.13000 / -149.872778 RMP Facility ID #100000218702 FRS ID #:110000554196 EJ Concerns:Yes - Greater Than 80 Percent CONTACT INFORMATION (RMP Implementation): Name:Lowell Upton, Branch Operations Manager Phone Number:(907) 529-6775 E-mail:lowell.upton@univarsolutions.com EMERGENCY CONTACT INFORMATION: Name:Lowell Upton, Branch Operations Manager Phone (24-hr):(907) 529-6775 E-mail:lowell.upton@univarsolutions.com Website:www.fruitsmart.com TRIP DETAILS: Inspection Date:9/12/2023 Inspection Time:09:00 through 13:45 Inspectors:Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP / EPCRA Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP / EPCRA Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP / EPCRA Inspector Erin Williams, US EPA Region 10, EPCRA Program Coordinator DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date:11/15/2012 Date of Latest Update:11/17/2022 Page 1 of 5 Process (Program 1, 2, 3) as reported in RMP: Process IDDescription Process NAICS Program Chemical Name Quantity Chemical IDCodeLevelCAS Number(lbs) Products Ammonia, Aqueous 1000128391 Merchant 1000160971 42469 240,000 Wholesalers (7664-41-7) PURPOSE: The purpose of this inspection was to determine whether 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:NoYes If Yes, Date of Last Inspection: The facility is High Risk:NoYes Joint EPCRA inspection:NoYes CAA TITLE V AIR PERMIT: Does the facility have a CAA Title V Permit?NoYes If Yes, Permit Number RELEASE / ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years?NoYes If Yes, Date and Description of the Release: EPCRA TIER II REPORTING: Did the facility submit the [Enter Year] Tier II report to the SERC?NoYes If Yes, Date the Tier II was submitted:1/30/2023 via E-Plan Did the facility submit a Tier II to the LEPC and local fire department? NoYes If Yes, Date the Tier II was submitted:1/30/2023 via E-Plan INSPECTION ENTRY: Peter Phillips led the inspection entry. The inspection team met with Lowell Upton at the Univar facility in Anchorage, Alaska. The team arrived at the facility at 9:00 am and was joined by the following facility personnel: Name Title Jared CarlingRegulatory Manager Lowell UptonOperations Manager Was a state / county / or local emergency representative present?NoYes If Yes, Name and Title of Representative: The facility is a first responder:NoYes If No, Responding Agency Anchorage Fire Department The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Peter Phillips, who provided a summary of the risk management program Page 2 of 5 (RMP) and explained the purpose of the visit. Each team member presented his / her credentials. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Mr. Upton gave a brief description of the facility, operations, and personal protective equipment required for the tour. 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: If Yes, Name of Union No Yes An employee representative present during the facility visit: If Yes, Name / Title No Yes GENERAL INFORMATION: Univar Solutions, USA Inc. was founded in 1924 and supplies chemical raw materials to the food industry, chemical compounders, pharmaceuticals, mining, forest products, oil and gas producers, electronics, coatings and many other key industries. The Univar Solutions, USA Inc. (Univar) facility located in Anchorage, Alaska is a wholesale chemical distributor serving various U.S. industries. The facility process is regulated under the Risk Management Program as a Program Level 2. The Anchorage facility's primary activities cover chemical storage and distribution. In their RMP dated November 17, 2022, Univar reported a regulated substance of aqueous ammonia (conc. 29%) that exceeds the threshold quantity of 20,000 pounds for ammonia (conc. 20% or greater). A tanker railcar of aqueous ammonia (conc. 29%) is delivered from the Alaska Railroad yard to the site during a transfer operation. The tanker railcar contains approximately 173,000 lbs. (23,000 gallons) of aqueous ammonia (conc. 29%). The aqueous ammonia (conc. 29%) is transferred into 37,608-pound (5,000 gallon) ISO container for immediate delivery to their customers. The fixed transfer lines contain an estimated 150 lbs. (20 gallons) of aqueous ammonia (conc. 29%). The facility contains a maximum of twenty 330-gallon Intermediate Bulk Containers (IBC) to store aqueous ammonia (conc. 29%) on site. The total quantity of aqueous ammonia (conc. 29%) stored is 49,639 pounds (6,600 gallons). There are presently no modifications to the process. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 09:45 am to 10:15 am. The inspection team was escorted by Mr. Upton and Mr. Carling. The inspection team observed the following aqua ammonia process area and EPCRA chemical storage areas: 1. EPCRA interior chemical storage area EPCRA interior flammable storage area EPCRA exterior flammable area 4. 2. 3. 5. 6. EPCRA exterior chemical tank farm EPCRA interior heated tank farm (20 tanks) Rail spurs (A and B, RMP covered process) Page 3 of 5 EPCRA Observations: The facility tour began with observation of the interior EPCRA chemical storage warehouse (photos 1- 4). Chemicals were organized neatly on racks, and the floor was free of obstructions. A chemical compatibility chart (photo 5) was posted in this area, as well as in the interior and exterior flammable material storage areas. All flammable storage containers were properly labeled with hazard placards (photos 7-9). The inspection team then proceeded to the exterior tank farm containing ethanol, kerosene, and aircraft deicing fluid tanks enclosed within a secondary containment wall (photo 10). No breaches in the containment wall were observed. An emergency shower and eye wash station were located outside (photo 16). The tour continued to the heated interior tank farm comprised of twenty 15,000-gallon tanks for storage of EPCRA chemicals requiring regulated temperatures (photo 19). All tanks displayed National Fire Protection Association (NFPA) 704 hazard identification markings (photo 19). RMP Observations: The Risk Management Plan (RMP) covered process at the facility is the transloading of 29% aqueous ammonia from railcars into 330-gallon Intermediate Bulk Containers (IBCs). No railcars were present on site during the inspection. The inspection team observed the two rail spurs, labeled Spur A and Spur B, used for transloading (photo 13). The aqueous ammonia is offloaded from the railcar via a fixed transfer pump (photo 11). The facility requires three operators to perform the transfer with two safety spotters and one transfer operator. The product flows from flexible hoses into a fixed piping system and then into the IBCs (photo 12 and 13). Univar stated that their flexible hoses are tested annually and replaced every five years. An emergency shutdown button (photo 17) and emergency shower / eye wash station (photo 15) are located within the transfer area. The rail spurs are secured with a locking gate (photo 14). Photographs were taken of the aqua ammonia transloading area and chemical storage area. The photographs that were taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at the Univar Anchorage facility, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Mr. Upton and Mr. Carling. INFORMATION COLLECTED FROM FACILITY: 1. Business cards 2. Facility site plan 3. Fire department walk through email 4. Hazard Communication Visitor Checklist AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Hazard Review [68.50]: Univar Anchorage could not produce a completed Hazard Review. The 2019 Hazard Review document dated 8/1/2019 was a partial review that did not include task assignments by name, due dates, and completion dates for eleven (11) open findings. Page 4 of 5 2. Maintenance [68.56]: Univar Anchorage could not produce written maintenance procedures identifying the recognized and generally accepted good engineering practices (RAGAGEP) being followed to maintain and inspect process equipment. 3. Maintenance [68.56]: Univar Anchorage could not produce training records for their personnel engaged in maintaining and inspecting process equipment. 4. Maintenance [68.56]: Univar Anchorage could not produce inspecting and testing documentation that process equipment (pumps and piping) were being maintained and inspected. DOCUMENTS REQUESTED INCLUDED IN REPORT: The following documents were requested during the inspection are included in this report. These documents were reviewed to determine compliance with Section 112 (r) of the Clean Air Act. 1. Hazard Assessment documentation 2. Maintenance training records: The facility supplied a roster of personnel requiring general training subjects but did not specify details for maintenance and inspection training related to the covered process. 3. General maintenance policy 4. Inspection and testing records for pumps and piping: The facility provided a manual for the pump. 5. RAGAEPS for maintenance equipment and inspections: The facility provided general RAGAEPS for process equipment. 6. 2019 Hazard Review including tracking of open findings. Univar Anchorage provided the documents listed above via mail on September 25, 2023. 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: PETER PHILLIPS (Affiliate) Inspector Signature Digitally signed by PETER PHILLIPS (Affiliate) Date: 2024.01.12 13:26:19 -08'00 ' Digitally signed by JAVIER JAVIER MORALES MORALES Date: 2024.01.17 09:09:22 -08'00 ' RMP Coordinator / Approval Digitally signed by ERIN WILLIAMS ERIN WILLIAMS Date: 2024.01.16 11:26:17 -08'00 ' EPCRA Coordinator / Approval Land Enforcement Section Chief / Approval Page 5 of 5 Attachment A-Photo Log Site Name: Univar Anchorage City, State: Anchorage, AK Photographer: Peter Phillips Flle Date Time Description 19/12/2023 9:46 AMChemical storage 29/12/2023 9:46 AMChemical storage 39/12/2023 9:47 AMChemical storage 4 9/12/2023 9:47 AMChemical storage 5 9/12/2023 9:49 AMChemical storage 69/12/2023 9:49 AMChemical storage bleach 7 9/12/2023 9:52 AMChemical storage flammables 8 9/12/2023 9:53 AMChemical storage flammables exterior 9 9/12/2023 9:54 AMChemical storage flammable exterior empty vessels 10 9/12/2023 9:56 AMTank farm with deicing fluid, methanol, and kerosene 11 9/12/2023 9:58 AMHoses from rail spur tested annually 12 9/12/2023 9:58 AMHoses from rail spur tested annually 13 9/12/2023 10:01 AM Rail spurs, A and B 14 9/12/2023 10:02 AM Rail spurs, A and B gate 15 9/12/2023 10:02 AM Rail spurs, A and B emergency shower 16 9/12/2023 10:06 AM Emergency shower at the tank farm 17 9/12/2023 10:06 AM Emergency stop for aqua ammonia 18 9/12/2023 10:07 AMOSHA fall restraint system. 19 9/12/2023 10:08 AM Heated tank farm, 15,000 gallon (20 tanks)