Document NELXGOrkVJ2dRwak1E59yndgR

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Simplot Grower Solutions Mayfield, Kentucky July 26, 2022 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 a fertilizer distribution process at the Simplot Grower Solutions (Simplot) facility located in Mayfield, Graves County, Kentucky. This facility was selected for inspection because it has never been inspected under the RMP. The inspection, which was conducted on July 26, 2022, consisted of a discussion of and request for program documentation, as well as a site review of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Documents were provided for review. This report will provide a background of the facility and a listing of observations. 2.0 Background The Simplot facility is located in Mayfield, Kentucky. This facility stores and distributes anhydrous ammonia to end users. The facility was previously owned by two different companies and has been in use since 2012. The facility was purchased by Simplot in January of 2020. Simplot inherited seven (7) 30,000-gallon anhydrous ammonia tanks. The process is regulated as program level 2. According to facility records, the facility has the capacity for a maximum of 1,400,000 pounds of anhydrous ammonia on site; however, the tanks are only filled to 80% at any time. Facility representatives stated the facility hasn't had power since December 2021 when a tornado hit the town of Mayfield. The ammonia tanks were not damaged, but Simplot had the tanks inspected to be safe. Simplot decided to shut down the Mayfield site in early 2022 and sold all of the remaining anhydrous ammonia. There is currently no or a minimal amount of ammonia in any of the seven tanks. Additionally, there are no functioning nurse tanks at the facility. Simplot ultimately deregistered the facility on August 17, 2022. The ammonia process at the facility was 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, EPA Inspector-In-Training: Chetan Gala, EPA Date of Facility Visit: July 26, 2022 Facility Identification Name: Simplot Grower Solutions - Mayfield Street Address: 521 South 16th Street City: Mayfield County: Graves State: Kentucky EPA Facility ID No: 1000 0016 2441 Dun & Bradstreet (D&B) No: N/A Latitude: 36.736309 Longitude: -088.651996 Zip: 42066 Name, address and phone of corporate parent company: Owner/Operator: Simplot Ab Retail Inc Mailing Address: 1099 W Front St. City: Boise State: Idaho Zip: 83702 Phone: (970) 506-8000 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Barry Newsome Title: Location Manager Email: Barry.Newsome@Simplot.com Name and title of emergency contact: Name: Bob Williams Title: Location Office Coordinator Day phone: (270) 247-8643 24-hour Phone: (270) 349-0052 Email: Bob.Williams@Simplot.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Anthony Rossi Title: EHS Manager Phone: (208) 780-0658 Email: Anthony.Rossi@Simplot.com Page 2 of 4 Simplot Grower Solution, Mayfield, KY CAA 112 (r), Risk Management Program, Inspection Report Name: Barry Newsome Title: Location Manager Phone: (986) 200-2644 Email: Barry.Newsome@Simplot.com Name: Lee Simmons Title: Regional Operations Manager Phone: (731) 414-4994 Email: Lee.Simmons@Simplot.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: September 29, 1999 (as Graves County Coop) Date of most recent submission: June 04, 2019 Deregistered: August 17, 2022 Process as reported in RMP: Ammonia Storage and Transfer Process: Fertilizer distribution Process ID: 1000104730 Program Level as reported in RMP: 2 NAICS code: 42491 (Farm Supplies Merchant Wholesalers) 3.0 Observations The inspection of the Simplot facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 2) 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. EPA inspectors requested paperwork associated with the facility's Risk Management Plan (RMPlan). The documents were reviewed by EPA inspectors on-site and later off-site. The discussion was followed by a tour of the facility's anhydrous ammonia tanks and associated piping. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Simplot's facility are discussed below: 1. 40 C.F.R. 68.50(c) requires the owner or operator to document the results of the Hazard Review and ensure that problems identified are resolved in a timely manner. At the time of the inspection, facility representatives could not produce the action items derived from the 2019 Hazard Review, which was completed by the previous owner. The facility did send an "Ammonia Action Log" after the inspection. This document did have some of the action items identified in the Page 3 of 4 Simplot Grower Solution, Mayfield, KY CAA 112 (r), Risk Management Program, Inspection Report 2019 Hazard Review, but not all of them. In addition, there were no estimated completion dates listed in the column labelled as such. The action items on this document did have a column labelled "Completion Date;" these dates were filled out as completed. 2. 40 C.F.R. 68.93(a) requires coordination with local emergency planning and response organizations to occur at least annually, and more frequently, if necessary, to address changes: at the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan. Facility representatives did produce a letter to the Fire Department dated July 23, 2021, in an attempt to coordinate the emergency action plan. This was the only letter the facility could provide, so there is no way for the inspection team to be sure there was coordination in 2020, when Simplot purchased the facility. Inspection Report, Prepared by: Digitally signed by JORDAN JORDAN NOLES NOLES ___________________________D_ate: 2022.09_.1_6_1_0_:_3_9:_0_6_-_04_'_0_0' Jordan Noles, Inspector Date North Air Enforcement Section U.S. EPA Region 4 Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER __________________________D__ate: 2022.09._16__1_2:_2_8_:1_7_-_0_4'_0_0'_ Jason Dressler, Section Chief Date North Air Enforcement Section U.S. EPA Region 4 Page 4 of 4 Simplot Grower Solution, Mayfield, KY CAA 112 (r), Risk Management Program, Inspection Report