Document a1vwG5ORazDRX604qNOaQ9GN9

Clean Air Act - Risk Management Program - Section 112(r) Emergency Planning Community Right-to-Know Act - Sections 302, 311 and 312 On-site Compliance Inspection Report Cascade Columbia Distribution 14200 SW Sherwood-Tualatin Road, Sherwood, OR PURPOSE The purpose of this On-site Compliance Inspection was to determine compliance with the Clean Air Act Section 112(r) Risk Management Program and the Emergency Planning and Community Right to Know Act Sections 302, 311, and 312. CAA Section 112(r) requires facilities that hold chemicals over threshold quantities to have a Risk Management Program. EPCRA Section 311 requires facilities that hold chemicals above the reporting threshold to submit copies of the SDSs or a list of these chemicals to the State Emergency Response Commission, the Local Emergency Planning Committee, and the local fire department. EPCRA Section 312 requires the Annual Chemical Inventory Reports (Tier II) for the current calendar year to be submitted by March 1 of the following year. The Tier II is required to be submitted to the SERC, LEPC, and fire department. EPCRA Section 302 requires any facility that has any EHS above the threshold planning quantities to notify the SERC and LEPC. LEPCs should also include the EHS(s) in their emergency response plans. Facilities covered under EPCRA Section 312 are required to indicate on the Tier II if they are subject to EPCRA Section 302 emergency planning requirements. COMPANY INFORMATION Name: Cascade Columbia Distribution Mailing Address: 14200 S.W. Tualatin-Sherwood Rd. Sherwood, OR 97140 Website: cascadecolumbia.com RMP/EPCRA On-site Inspection Report Revision Date: 5/31/2024 Page 1 of 7 FACILITY INFORMATION Name: Cascade Columbia Distribution Facility Address: 14200 S.W. Tualatin-Sherwood Rd. Sherwood, OR 97140 Latitude/Longitude: 45.3365449, -122.824102 RMP Facility ID#: 1000 0016 2968 EPCRA Tier II ID#: 22175 FRS ID#: 110056966877 EJ Concerns: Yes (95%) CONTACT INFORMATION (RMP Implementation) Name: Steve Durrell Title: Manager Phone Number: 503-625-5293 E-mail: steved@cascadecolumbia.com EMERGENCY CONTACT INFORMATION Name: Steve Durrell Title: Manager Phone Number: 503-849--8645 E-mail: steved@cascadecolumbia.com INSPECTION DETAILS Inspection Date: Inspection Time: Inspectors: March 13, 2024 0900 hours - 1055 hours Terry Garcia, US EPA R10, SEE Grantee, Lead RMP/EPCRA Inspector Edward Johannes, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Peter Phillips, US EPA R10, SEE Grantee, Lead RMP/EPCRA Inspector Mhara Coffman, US EPA R10, RMP/EPCRA Inspector Thomas Vroman, CIH, Weston Solutions, Inc., EPA START Contractor On February 29, 2024, EPA emailed a Notice of Inspection Letter to the facility informing them of a planned RMP and EPCRA inspection. The letter included 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. A copy of the letter must be provided to the employee representatives and the letter posted in a manner accessible to employees in the facility. Is the facility unionized? If yes, name of union: Was an employee representative present during the inspection? If yes, name/title: Yes No Yes No GENERAL INFORMATION The facility is regulated under the Risk Management Program as a Program Level 2 facility and is owned and operated by Cascade Columbia Distribution (Cascade Columbia). There are 42 full-time employees on site. Page 2 of 7 Cascade Columbia Distribution is a chemical logistics, delivery, and warehousing company. The company distributes more than 400 types of chemicals, mostly inorganics including acids and bases. The RMPcovered process includes Cascade Columbia accepting shipment of drums containing 70% Hydrofluoric Acid (HF) from trucks at the loading dock. These drums are transported by forklift to the production area of the facility. At the production area, the 70% HF drums are pumped into an above-ground storage tank, where it is mixed with the existing stock of HF and diluted to 49% HF, where it is no longer covered by the RMP regulations. There have been no recent changes or process modifications. DATE AND PROGRAM LEVELS OF SUBMITTED RMP Initial Submission Date: 0ctober 19, 1999 Date of Latest Update: October 14, 2019 Has the facility has been inspected in the past 5 years? If yes, date of last inspection: Is the facility High Risk? Yes No Yes No Process (as reported in the RMP) Process ID Description 1000103534 Hydrofluoric Handling Process Chemical ID 1001293613 NAICS Code 325998 Program Level 2 Chemical Name CAS Number Hydrogen Fluoride/Hydrofluoric Acid 7664-39-3 Quantity (lbs.) 100,000 CAA TITLE V AIR PERMIT Does the facility have a CAA Title V Permit? If yes, permit number: Yes No EMERGENCY RELEASE / ACCIDENT HISTORY Did an RMP reportable release occur in the past 5 years? Did a CERCLA/EPCRA reportable release occur in the past 5 years? If either yes, date and description of release: Yes No Yes No Page 3 of 7 EPCRA 312 - TIER II REPORT Was the 2023 Tier II report submitted to the SERC? If yes, date Tier II was submitted: 3/1/2024 If no, calendar year of the most recent Tier II: Was the 2023 Tier II submitted to the LEPC/fire department? If yes, date Tier II was submitted: 3/1/2024 Is the facility subject to EPCRA Section 302? If yes, is it correctly checked on the Tier II? Is the subject to RMP correctly checked on the Tier II? Is RMP facility ID correct on the Tier II? Yes No Yes No Yes No Yes No Yes No Yes No EPCRA CHEMICALS OVER THRESHOLD According to the most recent Tier II, the facility stores the following hazardous chemicals over the reporting threshold. See the attached Tier II, inventory amounts. Chemical Name HYDROGEN FLUORIDE TOLUENE SULFURIC ACID EHS (Yes or No) Y N Y CAS Number None provided 108-88-3 7664-93-9 EPCRA 311 - SDSs See Attached Tier II and chemical information on each EHS stored over the reporting threshold at the Facility. EPCRA 302 - LEPC Coordination Noted at the time of inspection, that with the exception of COVID years, the facility has coordinated with LEPC since 2018 as required. LEPC Agency: Program Contact: Address: Phone Number: Email: Website: Tualatin Valley F&R Oregon Fire Marshal 11945 SW 70th Ave, Portland, OR 97223 Tigard, OR 503-649-8577 https://www.tvfr.com/129/Fire-Marshals-Office https://www.tvfr.com/129/Fire-Marshals-Office INSPECTION ENTRY Terry Garcia led the inspection entry. The inspection team met with Steve Durrell at the Cascade Columbia Distribution facility in Sherwood, Oregon. The team arrived at the facility at 9:00 a.m. and was joined by the following facility personnel: Page 4 of 7 Steve Durrell Carlos Romero Eric Lonborg Amy Potter Anne Sturgill Name Title General Manager Regulatory Director Asst. Operations Manager Attorney; Angeli Law Group LLC Investigator Were any SERC, LEPC, or fire department representatives present? Yes No If yes, names and titles of representatives: John Wheeler, Emergency Manager Washington County, OR and Travis Lindberg, Emergency Manager, Sherwood, OR Is the facility a first responder? If no, the responding agency: Tualatin Valley Fire and Rescue Yes No The inspection team was escorted to a conference room. Introductions were made by Terry Garcia, who provided a summary of the risk management program and explained the purpose of the visit. Each team member presented their credentials. EPA requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. The facility is a warehouse, storing chemicals for distribution to clients. The EPA was instructed that the required PPE included safety glasses and closed-toe shoes. FACILITY TOUR / ON-SITE OBSERVATIONS The facility tour was conducted from approximately 0930 hours to 1000 hours. Steve Durrell, Carlos Romero, Eric Lonborg, Amy Potter, and Anne Sturgill escorted the inspection team. The inspection team observed the Loading Dock, drainage systems adjacent to Loc 600, the Acid Shed, Production Area, Caustic Shed, Flammable Shed, Oxidizer Shed, and Stormwater Pond. The RMP-covered process includes Cascade Columbia accepting shipment of drums containing 70% Hydrofluoric Acid (HF) from trucks at the Loading Dock. Safety systems observed include the use of chocks for delivery trucks (Photo 1), and a T-bar allowing drainage systems to shut off drainage valves in support of spill containment (Photos 3 & 4). Three above-ground storage tanks adjacent to the Loading Dock store propylene glycol (Photo 2) are regulated under EPCRA and are not RMP-regulated). EPA observed 70% HF stored in the Acid Shed (Photos 5-8); EPA observed several safety measures in place at the Acid Shed including wheel chocks, a sub-grade catch basin for spill containment, and a T-bar tool for valve shutoff. EPA inspected the Production Area where 70% HF is pumped from drums to above-ground storage tanks for the dilution process and observed hoses, piping, valves, and tanks (Photos 9-14). Safety measures observed in the Production Area included emergency stops, safety shower and eyewash. EPCRA-covered chemicals stored on-site include acids, caustics, flammables, and oxidizers. The facility separates the chemicals according to hazard class and stores them in congruently named sheds. EPA observed EPCRA-regulated chemicals in the Caustic Shed (Photos 15 & 16), Acid Shed (Photo 16), Oxidizer Shed (Photo 17), and Flammable Shed (Photo 17). Safety measures observed in place included hazcom signage and placarding and proper spacing and management of containers. A fire alarm and fire extinguisher were observed in the shed area (Photo 17). Page 5 of 7 EPA inspected the Stormwater Pond at the Western area of the facility property and observed the pond to be functional. Photographs were taken of the chemical distribution and handling process. The photographs are included in Attachment A. After touring the RMP-covered process areas and the EPCRA chemical storage areas, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Steve Durrell, Carlos Romero, Eric Lonborg, Amy Potter, and Anne Sturgill. INFORMATION COLLECTED FROM FACILITY 1. Training Verification Record 2. Training for RMP Maintenance Elements Record 3. Pressure Testing for Hose and Fittings Leak Detection 4. Block Flow Diagram 70% HF 5. Facility Site Map (photo) 6. RMP Site Map (rendered sketch) 7. Maintenance Schedule for HF 70% Service 8. Equipment Maintenance Log AREAS OF CONCERNS The following is a list of areas of concern identified: 1. Prevention Program: Training [68.54(a)]: Cascade Columbia's training documentation did not include verification of training by both employee and manager. The operators are Steve Durrell, Forrest Hesedahl, Matt Keinonen, Erik Lonborg, Francisco Elder, Ed Hawthorne, Roger Lopez, Cameron Mingear, Daniel Parent, and Rudy Lacaden (Hire date: 1-3-2024; Maintenance Operator). On May 17, 2024, Cascade Columbia provided revised training documentation with verification by training manager to ensure future training is documented. 2. Maintenance [68.56(a)]: Cascade Columbia was unable to provide documentation that showed they prepare and implement procedures to maintain the on-going mechanical integrity of the process equipment. On May 17, 2024 Cascade Columbia provided revised site-specific maintenance procedures and documentation to maintain the on-going mechanical integrity of the regulated process equipment Page 6 of 7 ON-SITE INSPECTION REPORT CERTIFICATION This is to certify that I, Terry Garcia, as the Lead Inspector for the On-site Compliance Inspection, have verified the accuracy of the information in this report. __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator Signature __________________________________________________________ EPCRA Coordinator Signature __________________________________________________________ Land Enforcement Section Chief Signature ATTACHMENTS A. Photographs (Photo Log and Layout) B. Safety Data Sheets C. Tier II Report Page 7 of 7 Attachment A - Photo Log Site Name: Cascade Columbia Disribution City, State: Sherwood, Oregon Photographer: Tom Vroman, Weston Solutions File Photo1.jpg Photo2.jpg Photo Layout ID 1 2 Date 3/13/2024 3/13/2024 Time 9:35 AM 9:36 AM Description Location: Loading Dock Chocks are put under wheels, drain for any spills during loading or unloading of trucks, a T-bar is along the dock wall to shut off catch basin valves in case of spill Location: Adjacent to Loading Dock Three large blue above-ground storage tanks storing propylene glycol [Not RMP] Location: South of Loc 600 Photo3.jpg 3 3/13/2024 9:38 AM Drain with a nearby T-bar to shut off the valve Location: South of Loc 600 Photo4.jpg 4 3/13/2024 9:38 AM Detail of drain valve Location: Acid shed Photo5.jpg 5 3/13/2024 9:39 AM Storage of acids, floor of shed is sloped inward to limit spread of spill Location: Acid Shed Photo6.jpg 6 3/13/2024 9:39 AM Storage of 70% hydrofluoric acid Location: Acid Shed Photo7.jpg 7 3/13/2024 9:40 AM NFPA placard on acid shed Location: Acid Shed Photo8.jpg 8 3/13/2024 9:40 AM Storage of acids in drums and on shelves Location: Production Area Photo9.jpg 9 3/13/2024 9:43 AM Emergency shower located approximately 10 feet from HF pump area Location: Production Area Photo10.jpg 10 3/13/2024 9:43 AM Hoses and valves used in the 70% HF pumping process Location: Production Area Photo11.jpg 11 3/13/2024 9:43 AM Detail of valve used in 70% HF pump process Location: Production Area Photo12.jpg 12 3/13/2024 9:43 AM Hose used in 70% HF pump process Location: Production Area Photo13.jpg 13 3/13/2024 9:44 AM Plastic piping from valves to white above-ground storage tank. Pipes transport 70% HF to the above-ground storage tank Location: Production Area Photo14.jpg 14 3/13/2024 9:44 AM Plastic piping to transport 70% HF to the above-ground storage tank Location: Caustic Shed Photo15.jpg 15 3/13/2024 9:48 AM Storage of caustic chemicals Location: Acid and Caustic Sheds Photo16.jpg 16 3/13/2024 9:53 AM Signage for stored chemicals Location: Oxidation and Flammable Sheds; Fire alarm and extinguisher Photo17.jpg 17 3/13/2024 9:52 AM Signage for stored chemicals Location: Facility Exterior, Western Edge of Property Photo18.jpg 18 3/13/2024 9:50 AM Stormwater pond at the western edge of the property