Document XRMz24m4Lq7RGpa2edjkkqR0w

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Solenis LLC, Milwaukee, Wisconsin Vicky Mei, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Solenis LLC Facility Location: 5228 N. Hopkins Street, Milwaukee, Wisconsin Date of Virtual Inspection: September 27, 2022 Date of On-site Inspection: September 28, 2022 EPA Inspectors: 1. Vicky Mei, Environmental Engineer 2. Danny Nguyen, Environmental Engineer (at virtual inspection only) Other Attendees 1. Scott Thomson, Plant Manager 2. Jim Faulstich, Corporate EHS Manager (at virtual inspection only) 3. Keith Budreau, Production Planner (at virtual inspection only) 4. Pat Elliott, Administrator (at virtual inspection only) 5. Abby Wojtanowski, EHS Manager 6. Jay Swann, Process Project Engineer (at virtual inspection only) Contact Email Address: sthomson@solenis.com Purpose of Inspection: 40 C.F.R. Part 68: Chemical Accident Prevention Provisions (CAPP) Facility Type: Plastics material and resin manufacturer Regulations Central to Inspection: 40 C.F.R. Part 68: CAPP Arrival Time of Virtual Inspection: 9:00 AM CST Departure Time of Virtual Inspection: 2:30 PM CST Arrival Time of On-site Inspection: 11:00 AM CST Departure Time of On-site Inspection: 12:15 PM CST Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided Provided CBI warning to facility The following information was obtained verbally from Solenis staff and through a CAPP document review unless otherwise noted. Process Description: The facility produces chemical additives, such as kymene, for the paper and pulp industry. The Process entails epichlorohydrin (EPI) arriving on tanker trucks, isotainers, or rail cars for use in its container or to be transferred into a 106,000-pound working capacity storage tank, and then being piped to one of 3 reactors as a reactant to create kymene. The reaction occurs in 6 to 10hour batches. The reactor sizes are 2,000, 6,000, and 7,000 gallons. Staff Interview: The facility started in 1906. The facility has a union that has decided to not participate in the inspection. There are 15 employees working on the Process. Tankers of EPI may be received at any time and day of the week. About 2 railcars are received per month. The maximum capacity for EPI is 650,000 pounds. The facility operates the chemical operations for 24 hours on 5 days per week in 3 shifts. The facility is a non-responder and works with the local fire department and Clean Harbors to handle emergencies. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA conducted an extensive document review of the facility's CAPP on September 27, 2022. EPA toured the facility on September 28, 2022 during the on-site inspection and saw the EPI Process. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Management structure 2. Off-site consequence analysis 3. Process safety information 4. Process hazard analysis 5. Operating procedures 6. Lockout-tagout procedures 7. Training documentation 8. Mechanical integrity records 9. Management of change documentation 10. Pre-startup safety reviews 11. Compliance audits 12. Incident investigation reports 13. Employee participation program 14. Hot work permits 15. Contractor policy information 16. Emergency response plans and meetings CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Completed hot work permits for EPI process Coordination with LEPC for emergency action plan or community action plan Sign-In sheet for on-site drill with Fire Department Internal drills for notification exercises PSSR for 6K reactor modification in 2019 Mechanical integrity preventive maintenance frequency of testing and inspection Concerns: There was no documentation on persons responsible for implementing individual requirements of the CAPP and defining of the lines of authority through an organization chart or similar document.  Another covered process that potentially affects public receptors different from those potentially affected by the worst-case scenario was not analyzed and reported. For the worst-case scenario, the quantity in the rail car was assumed to be spilled over the duration of an hour, instead of instantaneously, to form a liquid pool. The volatilization rate was not determined for the worst-case scenario. The rate of release to the air from the volatilization rate of the liquid pool was not determined. Smaller quantities handled at higher process temperatures or pressures and proximity to the boundary of the stationary source were not considered in selecting the worst-case scenario. The following alternative release scenarios were not considered: transfer hose release due to splits or sudden hose uncoupling; process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds; process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure; vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks; and shipping container mishandling and breakage or puncturing leading to a spill. The failure scenarios identified under 68.50 were not considered in selecting the alternative release scenario. The following were not identified in the off-site impact analysis: the presence of institutions, parks and recreational areas, major commercial, office, and industrial buildings. The following were not identified in the off-site impact analysis: the environmental receptors within a circle where its center is the point of the release and a radius determined by the distance to the endpoint. The facility did not rely on information provided on local U.S.G.S. maps, or on any data source containing U.S.G.S. data to identify environmental receptors. The worst-case and alternative release scenarios did not include the following documentation: the assumptions and parameters used, the rationale for selection, and anticipated effect of the administrative controls and mitigation on the release quantity and rate. The facility has not documented that equipment complies with recognized and generally accepted good engineering practices. The process hazard analysis did not include a qualitative evaluation of a range of the possible safety and health effects of failure of controls. The facility had not explained to the contract owner or operator the applicable provisions of the emergency response or the emergency action program. DIGITAL SIGNATURES Digitally signed by VICKY VICKY MEI Date: 2022.10.27 MEI Report Author: ________________20_:3_5:3_0_-0_5'_00_' __________ Frank, Digitally signed by Frank, Nathan Section Supervisor: _N__a_t_h_a_n_______1_5:_39_:5_1 -_05_'0_0'____________ Date: 2022.10.28 General: General: General: - - : : : . : . : : : : : : 55. 56 57 : 58 59 60 61 ] : 62 63 64 65 66