Document V3M7qdaDo7DMQdLoX06rgap3K

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 - Tier II Facility Inspection Report FACILITY INFORMATION: Name: Wilbur-Ellis Company (Fairfield, WA) Physical Address: 404 North 1st St., Fairfield, WA 99012 Phone Number: (509) 283-2411 Latitude/Longitude: 47.390050/-117.173405 RMP Facility ID# 100000092776 FRS ID#: 110015514059 EJ Concerns: No (Below 80%) CONTACT INFORMATION (RMP Implementation): Name: Junior Thies Phone Number: (509) 283-2411 E-mail: JThies@wilburellis.com EMERGENCY CONTACT INFORMATION: Name: Junior Thies Phone (24-hr): (509) 951-6281 E-mail: JThies@wilburellis.com Website: http://ag.wilburellis.com/Locations/Pages/Fairfield.aspx TRIP DETAILS: Inspection Date: July 14, 2023 Inspection Time: 0815 through 1000 hours EPA Inspection Team: Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Mhara Coffman, US EPA Region 10, RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Mike Wolski, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: June 21, 1999 Date of Latest Update: May 6, 2019 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID NAICS Code 1000098192 Anhydrous Ammonia 1000123185 42491 Program Level 2 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 210,000 Page 1 of 5 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: No Yes The facility is High Risk: No Yes Joint EPCRA inspection: No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? No Yes If Yes, Date and Description of the Release: 25 lbs. released on 7/11/2022, but below threshold for EPCRA reportable release. EPCRA TIER II REPORTING: Did the facility submit the 2023 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 02/17/2023 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: 02/17/2023 INSPECTION ENTRY: Peter Phillips led the inspection entry. The EPA Inspection Team (EPA) met with facility representatives Pam Simonson, Chris Phillips, and Kelvin Smith at the Wilber-Ellis facility in Fairfield, Washington. Assistant Fire Chief Devin Billington of Spokane County Fire District 2 accompanied EPA during the inspection. EPA arrived at the facility at 0815 hours and was joined by the following facility personnel: Name Pam Simonson Chris Phillips Kelvin Smith Title, Organization EHSS Regional Manager/Wilber-Ellis Operations Manager/Wilber-Ellis Service/Wilber-Ellis Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: Devin Billington Assistant Fire Chief No Yes The facility is a first responder: If No, Responding Agency: Spokane County Fire District 2 No Yes Facility representatives escorted EPA to a conference room located in the facility's office building. Lead Inspector Peter Phillips, 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. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Boots, and Safety high visibility vests are required. Chris/Pam gave Page 2 of 5 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 RMP rule a Program Level 2 facility and is owned and operated by WilberEllis Company. The facility is a retail shop which sells fertilizer, pesticides, and herbicides to farmers. Product arrives at the facility via delivery truck and is transferred to tanks on site. The retail shop is regulated under RMP rule as a Level 2 Process facility maintaining 210,000 pounds of anhydrous ammonia, and currently maintains one 30,000-gallon capacity tank of anhydrous ammonia on site. The facility also chemicals regulated under EPCRA rule, including 9,000 gallons of aqueous ammonia (20% concentration) managed in two above ground tanks, and stores pesticides and herbicides regulated under EPCRA rule in a small warehouse on site. There are twelve full-time employees on site, five of whom are operators. The facility is open from 0700 to 1600 hours Monday through Friday, and offers extended retail hours and days from September through November. ON-SITE OBSERVATIONS: EPA toured the facility from approximately 0815 to 1000 hours, escorted by facility representatives Chris Phillips, Kelvin Smith, and Pam Simonson. EPA observed exterior areas of the retail operation including the propane tank, the anhydrous and aqueous ammonia tanks, containment berm, piping, controls, and the small warehouse string EPCRA regulated chemicals. EPA observed the EPCRA regulated tanks of 20% aqueous ammonia and associated product transfer system components. The tanks feature hazardous communication (HAZCOM) signage and placarding and are surrounded by a concrete dike providing secondary containment (photos 1-3). An adjacent paved product transfer area allows trucks to transfer aqueous ammonia to and from the tanks for product shipping and receiving (photos 3-4). Wilbur Ellis stages delivery fleet trucks adjacent to the aqueous ammonia tanks (photo 5). The product transfer system includes two pull-cable emergency stops (photos 6-7), and two pump on/off controls (photos 8-9). EPA inspected the RMP-regulated anhydrous ammonia tank and associated product transfer system components. The anhydrous ammonia tank is directly adjacent to the aqueous ammonia tanks, and includes hazcom placarding and signage (photos 10-11), four pressure relief valves (PRVs) (photo 12) and the ammonia transfer system piping and header assembly (photos 14-15). Pressure relieve valve certifications are current, and due for recertification in 2024. EPA observed several safety measures in place including protective concrete traffic barriers surrounding the tank (photo 13), an emergency shower and eyewash station (photo 16), emergency open-top water tank and post-mounted respirator storage Page 3 of 5 (photo 17), truck wheel chocks (photo 18), and the facility flag which serves as a windsock (photo 19). EPA inspected a small warehouse on site where the facility stores EPCRA-regulated chemicals. The warehouse exterior displayed safety and HAZCOM signage (photo 20) and EPA observed chemicals as neatly stored on pallets within the warehouse (photos 21 - 23). There is one emergency eyewash station in the warehouse (photo 24). 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 Ty Little, James Paradis, and Pam Simpson. INFORMATION COLLECTED FROM FACILITY: 1. Aerial site plan map 2. Employee SOP Training Log 3. Emergency Incident Task Completion Sheet (page J-5) 4. Emergency Incident Task Completion Sheet (page J-6 AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Training: Did not provide refresher training at least every three years, or more often if necessary, to each employee operating a process, to ensure that the employee understands and adheres to the current operating procedures of the process [68.54(b)] 2. Compliance Audits: The July 2021 compliance audit report was not signed and certified by the EHS manager in 2021. [68.58(a)]. The EHS Manager signed the audit report on July 14, 2023, two years after the audit report was completed. 3. Emergency Response: There is no written documentation for emergency response coordination activities in last five years. [68.93(c), 68.96(a))]. 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. No follow-up documents were requested during the inspection. 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: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval Page 4 of 5 __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 5 of 5