Document p803o1DR26Na4EKx7djeYJd

Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Desk Audit Report FACILITY INFORMATION: Name: CPS Nutrien Ag Physical Address: 3630 Brooklake Road Northeast, Salem, Oregon Phone Number: (503) 393-1141 Latitude/Longitude: 45.048705/-122.987523 EPA Facility ID# 100000056529 CONTACT INFORMATION (RMP Implementation): Name: Stuart Kopp, Branch Manager Phone Number: (503) 393-1141 E-mail: stuart.kopp@nutrien.com EMERGENCY CONTACT INFORMATION: Name: Stuart Kopp, Branch Manager Phone (24-hr): (503) 519-3441 E-mail: stuart.kopp@nutrien.com Website: https://nutrienagsolutions.com/ AUDIT DETAILS: Contact Date: July 20, 2022 Inspectors: Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: June 18, 1999 Date of Latest Update: June 3, 2019 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000097493 1000097495 Description Urea Solution Production 10-34-0 Production Process Chemical ID 1000122001 1000122003 NAICS Code 325311 325312 Program Level 3 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 56,000 350,000 PURPOSE: The purpose of this document review was to determine whether 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 and compliance with Section 312 of the Emergency Planning and Community Right to Know Act (EPCRA) which requires the Tier II Chemical Inventory Reports to be submitted annually. EPA Region 10 RMP inspectors will not be conducting onsite inspections due to the COVID-19 pandemic requiring restricted travel and social distancing by the Centers for Disease Control (CDC) to prevent the spread of COVID-19. EPA Region 10 will coordinate with the RMP facility to schedule an onsite inspection when the CDC has determined it is safe. The facility has been previously inspected in the past 5 years: No Yes Is the emergency contact information current? No Yes The facility is High Risk: No Yes Page 1 of 5  Joint EPCRA inspection: No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? No Yes EPCRA TIER II REPORTING: Did the facility submit their 2021 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 2/25/2022 No Yes Did the facility submit a Tier II to the LEPC and local fire department? If Yes, Date the Tier II was submitted: 2/25/2022 No Yes GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 3 process and is owned and operated by Nutrien Ag Solutions. Nutrien Ag Solutions is a supplier of fertilizer, agrichemicals, seed, and other farming adjuncts. There are two covered processes: (1) the storage and handling of anhydrous ammonia for the production of 10-34-0 fertilizer and, (2) anhydrous ammonia used as a buffering agent for the production of urea fertilizer. 1. Phosphoric Fertilizer Production (10-34-0): The facility receives a maximum of two railcars of anhydrous ammonia for the production of poly-phosphoric fertilizer. Once onsite, the anhydrous ammonia is blended with phosphoric acid by a mobile reactor operated by Pacific Northwest Solutions to produce 10-34-0. After blending, the product is stored onsite and sold to farmers. The facility does this production 2 - 3 times a year. 2. Buffering Agent for Urea Production: Anhydrous ammonia is used to adjust the pH in the production of urea fertilizer. Anhydrous ammonia is stored in a single pressure vessel with a maximum capacity of 56,000 pounds. The product is delivered by truck and loaded as needed to support the urea production process. There are 20 full-time employees on site including two process operators (Bart Wilson and Eric Ramirez). INFORMATION REQUESTED FROM FACILITY: 1. Process Hazard Analysis - A copy of the last two PHAs with recommendations and tracking sheets. 2. Compliance Audit - A copy of the last two Compliance Audits with recommendations and tracking sheets. 3. Training - Training records for each process operator a. Initial Training Records: Training in the overview of the process and in the operating procedures, emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. Page 2 of 5 b. Refresher Training Records: Training of each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. c. Training Documentation: Records which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. d. Annual Certification: Annual operating procedures certification and review. e. Fill in Facility Training Summary sheet. 4. Emergency Response - A copy of emails, letters, or notes on meetings with LEPC and local responders including contact information (individual names, phone numbers, email addresses, organization name), dates, and coordination activities. 5. Tier II Reporting - Evidence of submission of a Tier II as described in 40 C.F.R. Part 370 to the State Emergency Response Commission ("SERC"), the Local Emergency Response Commission ("LEPC"), and the fire department with jurisdiction over the facility. ANALYSIS OF DOCUMENTATION SUBMITTED: The following is based on initial documents submitted by the facility, documents requested on followup, and telephone conversations: (Reference Attachment A for the document log.) 1. Process Hazard Analysis (PHA): The facility submitted the following PHAs: PHA dated 10/30/2018 for their 10-34-0 NH3 supply process (document 10). PHA dated 10/30/2018 for their urea buffering process (document 11). PHA dated 12/11/2018 for their 10-34-0 supply process (document 12). PHA dated 12/11/2018 for their urea buffering process (document 13). PHA dated 4/2016 conducted by Pacific Northwest Solutions (3rd party) for both processes (document 14). PHA dated 4/2021 conducted by Pacific Northwest Solutions (3rd party) for both processes (document 15). Analysis: Nutrien Ag's PHAs submitted documented that there were no findings or corrective actions required. The facility is conducting PHAs every 5 years as required by 40 CFR Part 68.67(f). 2. Compliance Audit: The facility submitted the following Compliance Audits: Compliance Audit dated 10/30/2018 for their 10-34-0 NH3 supply process (document 1). Compliance Audit dated 12/11/2018 for their 10-34-0 NH3 supply (document 2). Compliance Audit dated 12/11/2018 for their urea buffering process (document 3). Compliance Audit dated 12/11/2018 for their urea buffering process and storage (document 4). Analysis: Nutrien Ag's 2018 compliance audits documented that there were no findings or corrective actions required. Nutrien Ag did not perform a compliance audit in 2021, three years after their 2018 compliance audit because of issues related to the COVID pandemic. The facility has rescheduled their next compliance audit for 8/22/2022. Page 3 of 5 3. Training: Initial Training Records: Bart Wilson - evidence of initial training dated 5/13/2013 was provided in the form of a signed Training Qualification Card (document 19). Eric Ramirez - evidence of initial training was provided on 11/13/2020 (document 21). Refresher Training Records: The facility provided a signed operating procedures review for both operators dated 1/15/2022 and countersigned by Stuart Kopp, Branch Manager (document 5). Nutrien Ag is performing refresher training every 3 years. Training Documentation: The facility provided a signed operating procedures review for both operators dated 1/15/2022 and countersigned by Stuart Kopp, Branch Manager (document 9) and verified that the training was understood by observation. SOP Annual Certification: The facility provided signed certification of SOPs dated 1/15/2022 including the signatures of both process operators and Stuart Kopp (document 9). Facility Training Summary: Filled out and submitted to EPA. Analysis: The facility provided both initial and refresher training for Bart Wilson. Mr. Wilson is receiving refresher training every 3 years. Eric Ramirez was hired in 2020 and was initially trained. He is not due for refresher training until 2023. Both operators demonstrated that they understood the training by observation. 4. Emergency Response Coordination (Annually after 9/21/18): The facility provided documentation to support emergency response coordination on 9/27/2017, 6/26/2019, 6/22/2022 (document 16, 22, and 23). The facility noted that gaps in coordination are due to the voluntary nature of the first responders and COVID-19 protocols. The facility was advised that gaps in coordination must be documented. 5. Tier II Reporting: The facility submitted evidence that the 2021 Tier II was submitted to the Multnomah County LEPC on 2/21/2022 (document 18). AREAS OF CONCERNS: 1. Compliance Audits [68.79(a)]: Nutrien Ag Solutions has not certified that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed. Nutrien Ag Solutions did not perform a compliance audit in 2021, three years after their 2018 compliance audit. The facility stated that the delay was due to the COVID pandemic. DOCUMENTS REQUESTED ON FOLLOW-UP: The following documents were requested after the initial submission of documents. These documents will still be reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. 2021 Compliance Audit requested on 7/28/2022. The facility responded via email (same date) that they did not conduct a compliance audit which was due in 12/2021. The reason cited for not performing a compliance audit in 2021 was COVID-related. Page 4 of 5 2. Initial SOP and safe working practices training records for Eric Ramirez. This information was provided via email on 8/5/2022 (document 21). AUDIT REPORT CERTIFICATION: This is to certify that I, Peter Phillips, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: Digitally signed by PETER PHILLIPS PETER PHILLIPS (Affiliate) (Affiliate) ______________________________D__at_e_: _2_02_2_._0_8._3_0_1_0_:4_5_:0_2__-0_7_'0_0_'____ Signature Date Digitally signed by JAVIER JAVIER MORALES MORALES ______________________________D_a_t_e_: _2_0_2_2_.0_8_._3_0_1_4_:_2_5_:1_7__-0_7_'_0_0_' _ RMP Coordinator/Approval Date ERIN WILLIAMS Digitally signed by ERIN WILLIAMS ______________________________D__a_te_:_2_0_2_2_._0_8_.3_0_1__4_:4_2_:1_2__-_0_7_'0_0_' _ EPCRA Coordinator/Approval Date Digitally signed by Jennifer A Jennifer A Sullivan Sullivan Date: 2022.08.30 14:54:31 -07'00' __________________________________________________________ Land Enforcement Section Chief/Approval Date Page 5 of 5