Document bq4JMoqB5x56Xez0Eka8d7Q3

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 The McGregor Company PURPOSE The purpose of this On-site Compliance Inspection was to determine compliance with the Clean Air Act (CAA) Section 112(r) Risk Management Program (RMP) and the Emergency Planning and Community Right to Know Act (EPCRA) Sections 302, 311 and 312. CAA Section 112(r) requires facilities that hold chemical over threshold quantities to have a RMP. EPCRA Section 311 requires facilities that store chemicals above reporting threshold to submit copies of the Safety Data Sheets (SDSs) or a list of these chemicals to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), 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 Extremely Hazardous Substance (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: The McGregor Company Mailing Address: PO Box 740 Colfax, WA 99111 Website: https://mcgregor.com/ RMP/EPCRA On-site Inspection Report Revision Date: 2/21/2024 Page 1 of 6 FACILITY INFORMATION Name: Walla Walla, WA 44 Facility Address: 1410 G Street Walla Walla, WA 99362 Latitude/Longitude: 46.093958/-118.257568 RMP Facility ID#: 1000 0006 7731 EPCRA Tier II ID#: CRK000024330 FRS ID#: 110000752169 EJ Concerns: No CONTACT INFORMATION (RMP Implementation) Name: Mark Welter Title: Business Unit Manager Phone Number: (509) 529-6787 E-mail: rmp@asmark.org EMERGENCY CONTACT INFORMATION Name: Gary Brookshire Title: Service Manager Phone Number: (509) 386-4374 E-mail: gary.brookshire@mcgregor.com INSPECTION DETAILS Inspection Date: Inspection Time: Inspectors: May 17, 2024 8:00 a.m. - 9:40 a.m. Edward Johannes, US EPA R10, SEE Grantee, Lead RMP/EPCRA Inspector Peter Phillips, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Terry Garcia, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Erin Williams, US EPA R10, RMP/EPCRA Inspector Mhara Coffman, US EPA R10, RMP/EPCRA Inspector Robert Faries, Weston Solutions, Inc., EPA START Contractor On May 2, 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 is 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 RMP as a Program Level 2 facility and is owned and operated by The McGregor Company (McGregor). There are nine full-time employees on site. Page 2 of 6 Retail Store Walla Walla, WA 44 offers agricultural framing products including herbicides and pesticides. The retail business offers anhydrous ammonia for sale and stores the product onsite in a 29,500-gallon tank. The facility operates 7:00 a.m. to 4:30 p.m. Monday through Friday, February through mid-May; and 6:00 a.m. to 6:00 p.m. Monday through Friday, August through mid-October. DATE AND PROGRAM LEVELS OF SUBMITTED RMP Initial Submission Date: June 21, 1999 Date of Latest Update: June 10, 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 1000096934 Storage & Transfer Process NAICS Code Program Chemical ID Level 1000121347 1000098156 2 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs.) 170,000 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 RPM reportable release occur in the past 5 years? Did a CERCA/EPCRA reportable release occur in the past 5 years? If either yes, date and description of release: Yes No Yes No EPCRA 312 - TIER II REPORT Was the 2023 Tier II report submitted to the SERC? If yes, date Tier II was submitted: January 18, 2024 If no, calendar year of the most recent Tier II: Yes No Was the 20223 Tier II submitted to the LEPC/fire department? If yes, date Tier II was submitted: January 18, 2024 Yes No Is the facility subject to EPCRA Section 302? If yes, is it correctly checked on the Tier II? Yes No Yes No Is the subject to RMP correctly checked on the Tier II? Is RMP facility ID correct on the Tier II? Yes No Yes No Page 3 of 6 EPCRA CHEMICALS OVER THRESHOLD According to the most recent Tier II, the facility stores the following hazardous chemicals and extremely hazardous substances over the reporting threshold. See the attached Tier II, Attachment C, for inventory amounts. Chemical Name Dimethoate 4ec Urea Uan Solution (28-32) Rt 3 Anhydrous Ammonia Huskie Framework 3.3ec Paraquat Concentrate Zinc Edta 9 Ammonium Sulfate (Dry) Ammonium Thiosulfate Solution Ammonium Polyphosphate Sol. (11-37-0) Monoammonium Phosphate (11-52-0) Potash, Muriate (White) 40 Rock Gramoxone Sl 3.0 Roundup Powermax 3 0-0-15 Solution EHS (Yes or No) Yes No No No Yes No No No No No No No No No No Yes No No CAS Number 60-51-5 57-13-6 57-13-6 70901-12-1 7664-41-7 1689-99-2 40487-42-1 1910-42-5 64-02-8 7783-20-2 7783-18-8 68333-79-9 7722-76-1 7447-40-7 7722-76-1 1910-42-5 70901-12-1 7447-40-7 EPCRA 311 - SDSs The facility stores three EHS (two in the chemical storage shed) on-site over the TPQ and is subject to EPCRA Section 302. See Attachment B for SDSs and chemical information on each EHS stored over the reporting threshold at the Facility. EPCRA 302 - LEPC Coordination Facility has not participated in meetings with the LEPC. LEPC Agency: Program Contact: Title: Address: Phone Number: Email: Website: Walla Walla County LEPC Chris Lee Director 27 N. Second Ave. Walla Wall, WA 99362 (509) 524-2902 clee@co.walla-walla.wa.us co.walla-walla.wa.us Page 4 of 6 INSPECTION ENTRY The EPA Inspection Team (EPA) led by Edward Johannes arrived at the premises of Walla Walla, WA 44 facility in Walla Walla, Washington at 8:00 a.m. and was met by the following facility personnel: Todd Perry Clark Capwell Gary Brookshire Name Title Assistant Director General Manager Service Manager Were any SERC, LEPC or fire department representative present? If yes, names and titles of representatives: Chris Lee, Director Yes No Is the facility a first responder? If no, responding agency: Yes No The inspection team was escorted to a conference room. Introductions were made by Edward Johannes, who provided a summary of RMP 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 tour included the ammonia storage area, tank farm, and chemical storage shed. Close-toed shoes, Hi-Vis vests, and safety glasses were required while touring the facility. FACILITY TOUR / ON-SITE OBSERVATIONS The facility tour was conducted from approximately 8:25 a.m. to 8:40 a.m. The inspection team was escorted by Todd Perry, Clark Capwell, and Gary Brookshire. The photographs taken during the tour are found in Attachment A of this report. The inspection team observed the ammonia storage area consisting of one 29,500-gallon storage tank of ammonia, a windsock, shower/eyewash station, and a tank volume gauge on the tank (Photos 1 and 2). The inspection team observed the tank's vapor and liquid ammonia lines and a hose on the ground outside the protective barrier (Photos 3 and 4). Emergency shutoff cables (Photo 5), a bleed-off tank (Photo 6), and pressure relief valves were observed (Photo 7). EPA observed the Tank Farm where the facility stores EPCRA-regulated chemicals including urea ammonium nitrate solution, ammonium thiosulfate solution, ammonium polyphosphate solution, and potassium chloride in totes and above-ground storage tanks with concrete secondary containment (Photo 8). EPA also observed the Chemical Storage Shed containing EPCRA-regulated chemicals (Photo 9). Chemicals in the storage shed were segregated according to liquid and dry storage areas. EPA observed four large tanks containing liquid herbicide (Photos 9 to 11), and an assortment of dry fertilizers (Photo 12). 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 Todd Perry, Clark Capwell, and Gary Brookshire. Page 5 of 6 INFORMATION COLLECTED FROM FACILITY 1. Operating Procedures Review AREAS OF CONCERNS The following is a list of areas of concern identified. 1. McGregor has not complied with the emergency coordination activities in accordance with 68.93 by September 21, 2018. [68.10(b)]. The facility was unable to provide emergency coordination documentation for 2018-2022. FOLLOW-UP DOCUMENTS REQUESTED The following document was unable to be located during the inspection by the facility representatives. The document was requested to be sent to EPA by May 31, 2024. The document was to be reviewed after the inspection to determine compliance with Section 112(r) of the CAA. The facility did not provide the requested document. 1. Provide emergency coordination since 2018. ON-SITE INSPECTION REPORT CERTIFICATION This is to certify that I, Edward Johannes, as the lead inspector for the On-site Compliance Inspection and that I 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. Photo Log and Photographs B. Safety Data Sheets (SDSs) C. Tier II D. Google Earth Image and Street View E. Property Boundary Page 6 of 6 ATTACHMENT A Photo Log and Photographs