Document o9bbN5dXNrxzqqMNx45bd0bjE

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Southern States Coop 14242 Henderson, Kentucky August 8, 2023 1.0 Introduction The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA. The focus of this inspection was to assess the RMP for the fertilizer distribution process at the Southern States Coop 14242 facility located in Henderson, Henderson County, Kentucky. This facility was selected for inspection because it hadn't been inspected under the RMP within the last five years. The inspection, which was conducted on August 8, 2023, consisted of an examination of program documentation, as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Requested program documents were provided for further review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Southern States Coop 14242 facility is located in Henderson, Kentucky. The facility stores and distributes anhydrous ammonia to end users for use as a fertilizer. The process is regulated as program level 2. The facility utilizes one 30,000-gallon vessel, eleven 1,450-gallon vessels, and fifty 1,000-gallon vessels for anhydrous ammonia storage and distribution. During peak season (~March - June), the facility receives 7 - 8 truckloads of anhydrous ammonia per day. According to facility records, the facility has a maximum of 450,000 pounds of anhydrous ammonia on site. The fertilizer distribution process at the facility is subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1. TABLE 1: Inspection Information Summary Inspection Team Lead Inspector: Jordan Noles Inspector: Chet Gala Inspector-in-Training: Justin Stark Date of Facility Visit: August 8, 2023 Facility Identification Name: Henderson, KY 14242 Street Address: 5290 Highway 425 Bypass City: Henderson County: Henderson EPA Facility ID No: 100000093203 Dun & Bradstreet (D&B) No: 50063908 Latitude: 37.785339 Longitude: -087.605208 State: Kentucky Zip: 42420 Name, address and phone of corporate parent company: Owner/Operator: Southern State Inc Mailing Address: 6606 W Broad Street City: Richmond State: Virginia Zip: 23230 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Joe Thomas Title: Manager Phone: (270) 826-4366 Email: joe.thomas@sscoop.com Name and title of emergency contact: Name: Joe Thomas Title: Manager Day phone: (270) 826-4366 24-hour Phone: (270) 952-2196 Email: joe.thomas@sscoop.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Joe Thomas Title: Manager Phone: (270) 826-4366 Email: joe.thomas@sscoop.com Name: Kristin White Title: Bookkeeper Phone: (270) 389-1656 Email: Kristin.thomas@sscoop.com Note: This is not a union facility. Page 2 of 4 Southern States Coop 14242, Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report Date and Program Levels of Submitted Risk Management Plan Date of initial submission: June 21, 1999 Date of most recent submissions: June 05, 2019 Process: Storage & Transfer Process ID: 1000096554 Program Level as reported in RMP:2 NAICS code: 42491 (Farm Supplies Merchant Wholesalers) 3.0 Observations The inspection of the Southern States Coop 14242 facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 2) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection began with an opening discussion of facility operations. The discussion was followed by a tour of the facility's fertilizer distribution process area. EPA inspectors then requested paperwork associated with the facility's Risk Management Plan (RMPlan). The documents were reviewed by EPA inspectors on-site and provided for review off-site. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Southern States Coop 14242 facility are discussed below: 1. 40 C.F.R. 68.48(b) requires the owner or operator to ensure that the process is designed in compliance with recognized and generally accepted good engineering practices. During the facility tour, the inspection team noted the American Society of Mechanical Engineers (ASME) nameplate for the 30,000-gallon tank is corroded and illegible. The facility notified its corporate office in 2016 of the issue; however, at the time of the inspection, there was still no data plate for the 30,000gallon tank. ASME Boiler and Pressure Vessel Code, Section VIII, UG-116(a) requires nameplates to be affixed to pressure vessels that provide the code basis, maximum allowable working pressure (MAWP) at a specific temperature, serial number, year manufactured, etc. 2. 40 C.F.R. 68.50(d) requires hazard reviews to be updated at least once every five years. When the inspection team requested the last two hazard reviews, facility representatives provided one review conducted in 2016 and another review conducted in August of 2023. The most recent review was conducted after the EPA's "Notice of RMP Inspection" email for the August 8, 2023, RMP inspection was sent to the facility on July 26, 2023. It had been seven years in between the last two hazard reviews. 3. 40 C.F.R. 68.58(a) requires the owner or operator to certify that they have evaluated compliance with the provisions of Subpart C - Program 2 Prevention Program, at least Page 3 of 4 Southern States Coop 14242, Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report every three years to verify that the procedures and practices developed under Subpart C are adequate and are being followed. When requested by the inspection team, facility representatives provided the last two completed compliance audits. The first audit the facility provided was dated February 25, 2016. The second audit was dated August 7, 2023, seven years after the previous audit and after the EPA's "Notification of RMP Inspection" email for the August 8, 2023, RMP inspection was sent to the facility on July 26, 2023. Inspection Report, Prepared by: JORDAN Digitally signed by JORDAN NOLES Date: 2023.10.04 _N_O__L_E_S_______1_5:_03_:0_3 _-04_'0_0'________ Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 Approved by: JASON Digitally signed by JASON DRESSLER Date: 2023.10.04 _D_R__E_S_S__L_E_R___1_3:_59_:1_9 _-04_'0_0'______________________ Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4 Page 4 of 4 Southern States Coop 14242, Henderson, KY CAA 112 (r), Risk Management Program, Inspection Report