Document RJe7VoGZNMpRXEg27pdq86VoX

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: Tristar Transload PNW Inc. Physical Address: 3702 NW Gateway Ave, Vancouver, WA 98666 Phone Number: 360-823-1000 Latitude/Longitude: 45.648751, -122.720350 RMP Facility ID# 1000 0023 4542 FRS ID#: 110070070348 EJ Concerns: Yes (above 80%) CONTACT INFORMATION (RMP Implementation): Name: Peter Howe Phone Number: 360-823-1000 E-mail: peter@tristarpnw.com EMERGENCY CONTACT INFORMATION: Name: Peter Howe Phone (24-hr): 503-807-2952 E-mail: peter@tristarpnw.com Website: tristarpnw.com TRIP DETAILS: Inspection Date: Inspection Time: Inspectors: April 1, 2022 09:00 through 11:45 Edward Johannes, US EPA Region 10 SEE Grantee, Lead RMP Inspector Bob Hales, US EPA Region 10 SEE Grantee, RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Tom Vroman, Weston Solutions, Inc., EPA START Contractor Page 1 of 5 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: November 28, 2018 Date of Latest Update: November 28, 2018 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000092477 Description LPG Railcar Staging and Transfer Process Chemical ID 1000115727 NAICS Code 49311 Program Level 3 Chemical Name CAS Number Propane (74-98-6) Quantity (lbs) 3,100,000 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: No Yes If Yes, Date of Last Inspection: 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 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 3/30/2022 If No, calendar year of the most recent Tier II: No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 4/12/2022 INSPECTION ENTRY: Edward Johannes led the inspection entry. The inspection team met with Xavier Aguilera at the Tristar Transload facility in Vancouver, Washington. The team arrived at the facility at 09:00 hours and was joined by the following facility personnel: Peter Howe Xavier Aguilera Greg Enders Name Title President Consultant Yard Supervisor Page 2 of 5 Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes The facility is a first responder: If No, Responding Agency: Vancouver Fire Department No Yes The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Edward Johannes, who provided a summary of the risk management program (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. Greg Enders and Xavier Aguilera 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: The facility is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by Tristar Transload PNW Inc. (Tristar). The facility stores propane in railcars staged in the facility yard. Tristar is responsible for transferring bulk propane from railcars using leased transloading equipment. Tristar previously transloaded butane, and the butane process ended in March 2020. There are eleven full-time employees on site, two of whom are responsible for transloading propane. Tristar receives railcars via a railway spur to the property. The railcars are stored on the Tristar property, on both the east and west side of NW Gateway Avenue. Tristar employees operate leased transloading carts, transferring propane between trucks and railcars. Tristar is responsible for maintaining the transloading carts. There are no process modifications that impact the transloading process. Page 3 of 5 ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 09:30 hours to 10:00 hours. The EPA inspection team was escorted by Xavier Aguilar and Greg Enders. The inspection team observed both east and west rail yards and the equipment used in the process. Tristar was not performing the transloading process during the inspection. Tristar operates two transloaders, identified as P1 and P2. Transloader P1 was used earlier in the day, and remained connected to the railcar. Transloader P1 was equipped with four emergency stops on the ground level (photos 7, 9, 10, and 12) and one at the top of the staircase (photo 19). The hoses on transloader P1 were inspected on 3/28/22 and were marked with the inspection date (photos 4, 5, and 16). The grounding cable was still attached to the railcar (photo 11). Tristar employees showed the inspectors the air monitoring device they use during transloading (photo 13). Transloader P2 was locked out of service, as the hoses were being inspected by a third party vendor. 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 Tristar Transloading PNW Inc, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Peter Howe and Xavier Aguilar. INFORMATION COLLECTED FROM FACILITY: 1. Propane Standard Operating Procedure Dated 7/16/18 (7 pages) 2. Propane & Butane Transloading Safety Information (2 pages) 3. Tristar Transload Butane Railcar Storage and Transloading First Responder Orientation Session Roster (1 page) 4. RMP Process Specific Information Section 1.17 Dated 1/2/2018 (1 page) 5. Facility Operator and Maintenance Training Summary Sheet Dated 9/1/2020 AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. The owner or operator did not train each employee involved in maintaining the on-going integrity of process equipment [68.73(c)]. 2. The owner or operator did not certify annually that the operating procedures are current and accurate and that the procedures have been reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources [68.69(c)] 3. The owner or operator had not submitted their 2021 Tier II to the LEPC and local fire department. 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 and with Section 312 of the Emergency Planning and Community Right to Know Act (EPCRA). 1. Contractor evaluations from contracted maintenance provider. 2. Initial and refresher training. 3. Copy of 2021 submittal of Tier II to the LEPC and local fire department. Page 4 of 5 INSPECTION REPORT CERTIFICATION: This is to certify that I, Edward Johannes, 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