Document Ne4a8veaMYLzVZ6xdZQX45pGy

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: Solenis - Portland Plant Physical Address: 3366 NW Yeon Avenue Phone Number: 503-224-1200 Latitude/Longitude: (45.5473, -122.7091) RMP Facility ID# 1000 0015 4888 FRS ID#: 110069500463 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Lauren M Wilcox Phone Number: (971) 271-1803 E-mail: lmwilcox@solenis.com EMERGENCY CONTACT INFORMATION: Name: Lauren M Wilcox Phone (24-hr): (971) 271-1803 E-mail: lmwilcox@solenis.com Website: www.solenis.com TRIP DETAILS: Inspection Date: March 16, 2023 Inspection Time: 0945 hours through 1100 hours EPA Inspection Team: Mhara Coffman, US EPA Region 10, Lead RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector EPCRA Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Taylor Law, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: July 19, 1999 Date of Latest Update: April 8, 2022 Process (Program 1, 2, 3) as reported in RMP: May 23, 2023 Page 1 of 5 Process ID 1000124609 1000124610 Description Kymene production use Process Chemicals Process Chemical ID 1000155730 1000155784 NAICS Code 1000125981 Program Level 3 1000126018 3 Chemical Name CAS Number 106-89-8, Epichlorohydrin 108-91-8, Cyclohexylamine Quantity (lbs) 686,000 22,000 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: If Yes, Date of Last Inspection: December 7, 2021 No Yes The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the [Enter Year] Tier II report to the SERC? No Yes If Yes, Date the Tier II was submitted: 2-28-23 If No, calendar year of the most recent Tier II: Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 2-28-23 INSPECTION ENTRY: Mhara Coffman led the inspection entry. The EPA Inspection Team (EPA) met with facility representatives Blane Peterson, Aaron Turner, Travis Russell, Sydney Stauffer, Chris Hendry, and Jennifer Labreque at the Solenis - Portland Plant facility in Portland, Oregon. EPA arrived at the facility at 0845 hours and was joined by the following facility personnel: Name Blane Peterson Aaron Turner Travis Russell Chris Hendry Sydney Stauffer Jennifer Labreque Plant Manager Solenis Process Engineer - Solenis EH&S Supervisor Plant Engineer ARC Safety consultant Quality Manager Title Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: Bryan Profit Page 2 of 5 No Yes The facility is a first responder: If No, Responding Agency: Portland Fire Department No Yes Facility representatives escorted EPA office. Lead Inspector Mhara Coffman, introduced all parties present, provided a summary of the Risk Management Program (RMP), and explained the purpose of the visit. Each EPA Inspector presented his/her credentials. should be taken during the site tour. Blane Peterson Plant Manager 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: Union #701 No Yes An employee representative present during the facility visit: No Yes If Yes, Name/Title: Hal Carlston, Union Representative, International Brotherhood of Operational Engineers GENERAL INFORMATION: The facility is regulated under RMP regulations as a Program Level 3 facility and is owned and operated by Solenis LCC. Solenis LLC began ownership and Kymene production at the facility in 2014. The facility main function is Kymene (a wet strength resin) production for paper material structural integrity. Epichlorohydrin is received at the facility by one railcar or four trucks a month. Then the epichlorohydrin undergoes a reaction with other process chemicals to form the Kymene. The Kymene is then transported off location by five tanker trucks per week to Solenis clients. There are 30 full-time employees on site. The facility operates a 24/5 schedule with three operators. ON-SITE OBSERVATIONS: EPA toured the facility from approximately 0930 hours to 1030 hours, escorted by facility representatives Blane Peterson Plant Manager. During the tour, EPA observed the Kymene production chemical process at several areas of the facility including the Epichlorohydrin Loading Area (photos 1-5), the epichlorohydin tank (Tank 67) at the Tank Farm (photos 6-20), the Process Chemical Building housing chemical transfer lines and the Kymene reactor (photos 21-37), the Cyclohexylamine Storage Area (photo 38), and the Kymene Truck Loading Areas (photos 39-40). The facility maintains 686,000 pounds of Kymene and 22,000 pounds of cyclohexylamine on site in support of chemical manufacturing processes. EPA inspected RMP covered processes at several areas of the facility including the Epichlorohydrin Loading Area, Tank Farm, Process Chemical Building, an exterior chemical staging area where the facility stores drums of cyclohexylamine, and the Kymene Loading Areas 1 and 2. Page 3 of 5 The facility maintains lower explosive limit (LEL) and four gas detection systems at the Tank Farm, Epichlorohydrin Loading Area, in the Process Chemical Building, and at the facility Entrance Gate. The LEL detectors alarm at 3.5% LEL, and the system performs automatic shutdown at 5.5 % LEL. EPA observed the Epichlorohydrin Loading Area where epichlorohydrin arrives by rail. The facility pumps epichlorohydrin via transfer lines to Tank 67 for use in Kymene production (photos 1-5). The facility stores epichlorohydrin in Tank 67, located in the Tank Farm. EPA observed Tank 67 components and safety features including chemical transfer lines, an eye wash station, secondary containment, hazardous communication (hazcom) signage, LEL detection system with alarms (photos 620). EPA observed manufacturing processes in the Process Chemical Building, where transfer lines transport epichlorohydrin and other chemicals for the Kymene manufacturing process. Manufacturing system components and safety features include chemical transfer lines and valves, the Process Chemical Reactor, LEL and four gas detection systems with alarms, eye wash stations, and hazcom signage (photos 21-37). EPA observed an exterior chemical staging area where the facility stores 22,000 pounds of drums of cyclohexylamine. The cyclohexylamine is stored in 55-gallon steel drums staged atop secondary containment (photo 38). Product transfer lines carry the finished Kymene to the Kymene Loading Areas 1 and 2, where tanker trucks accept the finished product for shipment (photos 39-40). Photographs taken during the inspection are included as Attachment A- Photo Layout. 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 Plant Manager Blane Peterson, Travis Russell, and Sydney Stauffer. INFORMATION COLLECTED FROM FACILITY: 1. Kymene Manufacturing Process document 2. Solenis Plant rules documentation 3. Solenis Plant Map 4. Solenis Plant Management Organization Chart AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Owner/operator has not promptly determined and documented an appropriate response to each of the findings of the audit and documented correction of deficiencies. [68.79(d)]. Compliance audit completed on April 29, 2022 identified two 2019 Action Items (AIs) not addressed promptly, AI #052019-031 due 12/31/2019 was not closed until 1/20/2020; AI #2019054-008 was due 7/13/2019 and not closed until 8/8/2019. 2. The owner/operator did not submit correct emergency contact information within 30 days of contact information change. [68.195(b)]. Facility did not update emergency contact and registration information to reflect responsibility delegated from Lauren Wilcox and assumed by Travis Russel on October 24, 2022 within 30 days of the change. Page 4 of 5 DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. These documents will still be reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. Tier II reports INSPECTION REPORT CERTIFICATION: This is to certify that I, Mhara Coffman, 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 5 of 5 Site Name: City, State: Photographer: Solenis - Portland Plant Portland, Oregon Taylor Law File Photo Layout ID Date Time (IMG_"number" format) Description 1 7214 3/16/2023 09:38am Epichlorohydrin Loading Area , hot work permit clearance and confirmation prior to taking pictures of facility 2 7215 3/16/2023 09:39am Epichlorohydrin Loading Area, overview 3 7216 3/16/2023 09:39am Epichlorohydrin Loading Area, overview, view of chemical transfer lines and pump 4 7217 3/16/2023 09:39am Epichlorohydrin Loading Area, overview 5 7218 3/16/2023 09:40am Epichlorohydrin Loading Area, process chemical building exterior 6 7220 3/16/2023 09:43am Tank Farm, eyewash station 7 7221 3/16/2023 09:47am Tank Farm, overview 8 7222 3/16/2023 09:47am Tank Farm, Tank 67 containing epichlorohydrin 9 7223 3/16/2023 09:48am Tank Farm, piping and secondary containment for Tank 67 10 7224 3/16/2023 09:48am Tank Farm, Tank 67 hazard communication (hazcom) signage 11 7225 3/16/2023 09:48am Tank Farm, overview of Tank 67 safety ladder and chemical transfer lines 12 7226 3/16/2023 09:48am Tank Farm, closeup of chemical transfer lines on Tank 67 13 7227 3/16/2023 09:49am Tank Farm, storm drain outside Tank 67 secondary containment 14 7228 3/16/2023 09:49am Tank Farm, pump and LEL at Tank 67 secondary containment 15 7229 3/16/2023 09:50am Tank Farm, view of Tank 67 base 16 7230 3/16/2023 09:51am Tank Farm, Tank 67 hazcom signage 17 7231 3/16/2023 09:52am Tank Farm, overview of Tank 67 18 7232 3/16/2023 09:52am Tank Farm, safety signage on Tank 67 secondary containment 19 7233 3/16/2023 09:52am Tank Farm, Tank 67 nitrogen blanket alarm signage 20 7234 3/16/2023 09:52am Tank Farm, LEL detection system at Tank 67 secondary containment 21 7235 3/16/2023 09:56am Process Chemical Building, chemical transfer lines and system components 22 7236 3/16/2023 10:00am Process Chemical Building, chemical transfer lines and system components 23 7237 3/16/2023 10:00am Process Chemical Building, chemical transfer lines and system components 24 7238 3/16/2023 10:01am Process Chemical Building, chemical transfer lines and system components 25 7239 3/16/2023 10:01am Process Chemical Building, air intake 26 7240 3/16/2023 10:02am Process Chemical Building, chemical transfer lines and system components 27 7241 3/16/2023 10:02am Process Chemical Building, eyewash stations 28 7242 3/16/2023 10:03am Process Chemical Building, Process Chemical Reactor 29 7243 3/16/2023 10:05am Process Chemical Building, Process Chemical Reactor 30 7244 3/16/2023 10:08am Process Chemical Building, chemical process lines with tags 31 7245 3/16/2023 10:08am Process Chemical Building, 4 gas detector on ground floor 32 7246 3/16/2023 10:10am Process Chemical Building, 4 gas detector on ground floor 33 7247 3/16/2023 10:10am Process Chemical Building, 4 gas detector readout display 34 7248 3/16/2023 10:10am Process Chemical Building, 4 gas detector readout display 35 7249 3/16/2023 10:11am Process Chemical Building, chemical transfer lines and system components, eye wash station 36 7250 3/16/2023 10:11am Process Chemical Building, chemical transfer lines and system components 37 7251 3/16/2023 10:12am Process Chemical Building, chemical transfer lines and system components 38 7252 3/16/2023 10:12am Exterior Chemical Staging Area, cyclohexylamine drums with secondary containment 39 7253 3/16/2023 10:15am Kymene Truck loading area. 40 7254 3/16/2023 10:17am Second Kymene truck loading area.