Document e5BNV8axjZ8w6kM066EmjXxN4

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: OXARC - Springfield Physical Address: 3417 E Springfield Ave. Spokane, WA 99202 Phone Number: (509) 535-7794 Latitude/Longitude: 47.664275-117.359341 RMP Facility ID# 100000248804 FRS ID#: 11000539128 EJ Concerns: No (Below 80%) CONTACT INFORMATION (RMP Implementation): Name: Ty Little Title: EHS Manager/Claim Manager Phone Number: (509) 547-2492 E-mail: tlittle@oxarc.com EMERGENCY CONTACT INFORMATION: Name: Jena Fitzgerald Title: Executive Vice President Phone (24-hr): (509) 993-6534 E-mail: jfitzgerald@oxarc.com Website: www.oxarc.com TRIP DETAILS: Inspection Date: July 13, 2023 Inspection Time: 0845 through 1030 hours EPA Inspection Team: Edward Johannes, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Mhara Coffman, US EPA Region 10, RMP Inspector Mike Wolski, Weston Solutions, Inc., EPA START Contractor July 13, 2023 Page 1 of 5 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: May 26, 2022 Date of Latest Update: May 26, 2022 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process NAICS Chemical ID Code 1000125273 Chlorine Storage 1000156567 42469 Program Level 3 Chemical Name CAS Number Chlorine (7782-50-5) Quantity (lbs) 30,000 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 If Yes, Date of Last Inspection: May 26, 2022 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? No Yes If Yes, Date the Tier II was submitted: 1/31/23 original, 7/7/23 update If No, calendar year of the most recent Tier II: Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 1/31/23 original, 7/7/23 update INSPECTION ENTRY: The EPA Inspection Team (EPA) led by Mr. Edward Johannes arrived at the premises of OXARC, Inc. (facility) in Spokane, Washington, at 08:45 and met with the following facility personnel: Name Ty Little James Paradis Brad Boyce Title, Organization EHS Manager/Claim Manager, OXARC Plant Manager, OXARC Safety Coordinator, OXARC Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes Page 2 of 5 The facility is a first responder: If No, Responding Agency: Spokane Fire Department No Yes Facility representatives escorted EPA to a central office work area located in the facility main building. Lead Inspector Edward Johannes, 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. Ty Little and James Paradis 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: No Yes If Yes, Name of Union: Drivers are unionized under Teamster Local 690. An employee representative present during the facility visit: If Yes, Name/Title: No Yes GENERAL INFORMATION: The facility is regulated under RMP as a Program Level 3 facility and is owned and operated by OXARC, Inc. This company is a family-owned business that has operated in 21 locations across the Northwest since 1968. The facility receives, stores, and ships compressed gases for sale to industry, providing welding and industrial supplies, safety products, and training, as well as industrial, medical, and specialty gases. There are twenty full-time employees, eight of whom are operators. Facility standard procedures require that three personnel support chlorine loading and offloading. Normal hours of operation are 0400 hours through 1700 hours, Monday through Friday. The RMP-covered process at the facility consists of chlorine gas stored on site in two container types: five 2,000-pound (1-ton) containers and several 150-pound compressed gas cylinders. Controls or safety equipment include pressure relief meltable fusible plugs (120F for 1-ton containers and 158F for 150pound cylinder), facility alarm system, outside ventilation for releases, and "A" and "B" Chlorine Institute Emergency Kits. In addition to the chlorine, the facility has other RMP regulated substances that include both hydrochloric acid (conc. 37% or greater) and sulfur dioxide, but they occur at this facility below the threshold quantities. The facility also stores EPCRA-regulated chemicals that include sulfur dioxide, sulfuric acid, and propane. Only propane is below reportable amounts under EPCRA at this facility. And finally, the facility stores other compressed gases and chemicals not regulated under EPCRA or RMP that include carbon dioxide, oxygen, nitrogen, argon, and sodium hypochlorite (12.5%). OSHA General Duty Clause would apply to substances having threshold amounts below EPCRA or RMP compliance. At the time of the inspection, the total chlorine inventory reported in their 2022 Tier II was 30,000 pounds. Operating procedures are available to employees in paper format (binders) and digitally (company intranet). Page 3 of 5 ON-SITE OBSERVATIONS: The facility inspection was conducted from approximately 0906 hours to 0915 hours. EPA personnel were escorted by facility representatives Ty Little, James Paradis, and Brad Boyce outside to the east end of the facility. EPA observed the Loading Dock area where the storage area for chlorine and sulfur dioxide was located, the nearby staging area for empty cylinders, the truck parking area, and the adjacent storage area for EPCRA-regulated chemicals and other chemicals. In addition to the area with the covered process, the facility has a security perimeter fence with lockable gates at both entrances. Photographs taken during the inspection are included in Attachment A to this report. EPA observed the Loading Dock area at the facility, where the facility stages five 1-ton cylinders of chlorine, several 150-pound cylinders of chlorine, and several cylinders of sulfur dioxide in a small area (Photos 1, 2, 3, and 4). The area with these two chemicals had a chain-link security fence enclosure with a locked gate that had hazardous communication (hazcom) signage posted (Photo 5). The area is monitored 24/7 by security cameras (Photo 6). A daily log was examined by the EPA that is maintained by the facility staff on the quantity and container size of chlorine stored onsite at the Loading Dock area (Photos 7 and 8). EPA observed facility operations, including the staging area for delivery trucks (Photo 9), and the staging area for empty cylinders (Photo 10). EPA also observed EPCRA-regulated chemicals and other chemicals stored in barrels and totes in a larger dedicated staging area (Photos 11 and 12). 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 Brad Boyce. EPA departed the facility at 1000 hours. INFORMATION COLLECTED FROM FACILITY: 1. Figure D-1. OXARC - Springfield Evacuation Assembly Areas 2. Process Hazard Analysis 3. Appendix G. Operating Procedures and Safe Work Practices 4. G.2. Annual Review of Operating Procedures Log (example) 5. Standing Operating Procedure G1: Chlorine Storage (4 pages) 6. Standing Operating Procedure G2: Sulfur Dioxide Storage (4 pages) 7. Emergency Response Contact List AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. OXARC did not address engineering and administrative controls applicable to hazards and interrelationships and consequence of failure of engineering and administrative controls in their February 2, 2022, PHA [68.67(c)(3), (4)]. 2. OXARC listed the team's titles but did not list their names in their February 2, 2022, PHA [68.67(d)]. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: During the inspection, no follow-up document requests were made requiring further review. 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