Document qrerKx95QeDM1p11KRkgvkEE

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT PVS Chemical Solutions, Inc., 12260 S. Carondolet Ave., Chicago, IL FROM: Matthew Walters, Environmental Engineer AECAB (MN/OH) THRU: Brian Dickens, Section Supervisor AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: PVS Chemical Solutions, Inc. Facility Location: 12260 S. Carondolet Ave., Chicago, IL Date of Inspection: October 26-27, 2023 EPA Inspector(s): 1. Patrick Miller, Environmental Engineer 2. Matthew Walters, Environmental Engineer Other Attendees: 1. Sean Dunkle, Plant Manager, PVS Chemical Solutions 2. Jason Dunlap, Safety Manager, EHSS, PVS Chemical Solutions 3. Alex Graika, Project Engineer, PVS Chemical Solutions 4. Erik Rosner, Process Engineer, PVS Chemical Solutions 5. John Bozick, Supervisory Environmental Manager, PVS Chemical Solutions 6. Brandon Davis, Lead Operator and Union Representative, PVS Chemical Solutions 7. John Nicholson, Executive Vice President, PVS Chemical Solutions 8. Peter Onyskiw, Environmental Manager, PVS Chemical Solutions 9. Dale Price, Technical Manager, PVS Chemical Solutions Contact Email Address: sdunkle@pvschemicals.com Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 Purpose of Inspection: Compliance with the Prevention of Accidental Releases found in Section 112(r) of the Clean Air Act (CAA), 42 U.S.C. 7412(r) Facility Type: Oleum, liquid sulfur dioxide, and ammonium thiosulfate manufacturing plant Regulations Central to Inspection: Chemical Accident Prevention Provisions at 40 C.F.R. Part 68 Arrival Time: 10/26/23: 9:00 a.m.; 10/27/23: 8:50 a.m. Departure Time: 10/26/23: 3:45 p.m.; 10/27/23: 11:30 a.m. Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business. Provided CBI warning to facility The following information was obtained verbally from PVS Chemical Solutions personnel unless otherwise noted. Process Description: The facility has three RMP covered processes: oleum manufacturing, liquid sulfur dioxide (SO2) manufacturing, and ammonium thiosulfate (ATS) manufacturing. The primary raw materials used at the facility are molten sulfur, anhydrous ammonia (NH3), air, and water. The facility burns molten sulfur in air to produce SO2 gas, which is further oxidized in the Converter to sulfur trioxide (SO3). The process gas from the Converter can be routed to either the #2 Absorption Tower to produce high quality sulfuric acid or to the Oleum Absorption Tower to produce approximately 30% oleum. The facility either pumps the oleum product to storage or uses oleum as a starting material for the liquid SO2 process. The first step in liquid SO2 production is the heating of oleum in the Vaporizer to generate SO3. The vaporized SO3 reacts with a mixture of sulfuric acid and molten sulfur in the Primary and Secondary Reactors to form SO2 gas, which is then purified, cooled, compressed, and condensed. The liquid SO2 product is stored in one of four 30,000-gallon storage tanks located in a diked tank farm. The facility maintains at least one of the liquid SO2 tanks as a spare for emergency unloading of another storage tank. The facility receives NH3 for the ATS process via railcar. The NH3 railcar directly supplies the process from the railcar unloading station. An adjacent 12,000 gallon tank provides additional NH3 storage capacity and receives the heel of the empty railcar prior to switching. NH3 is reacted with SO2 in the Gassing Tank to produce ATS. Page 2 of 11 Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 Oleum, liquid SO2, and ammonia thiosulfate products are loaded into trucks or railcars and transported off-site. Staff Interview: Inspectors obtained the following information based on interviews with PVS Chemical Solutions management and operators: The ATS process initially started up in 2021. There is a plan to add an ultra-high purity sulfuric acid process to the facility. The control room is staffed with two operators 24/7. Maintenance employees are onsite for one 8-hour shift Monday through Friday. Initial operator training typically takes 4 to 6 months and consists of classroom training, on the job training, and a written test. Refresher training occurs approximately quarterly and covers a review of initial training material, lessons learned, and recent changes. Prior to conducting maintenance activities, LOTO is performed by both the equipment owner and the maintenance technician. Operators do not perform line breaks, but maintenance personnel check in at the control room prior to performing a line break. Operators are 40-hour OSHA certified, but there is no onsite emergency response team. In the event of an accidental release, facility personnel attempt to isolate equipment if possible but rely of the Chicago Fire Department (CFD) HAZMAT unit for emergency response. Responding operators are equipped with a respirator, personal gas monitor, and ammonia solution spray for leak detection. The last coordination activity with CFD was November 2022. PVS Chemical Solutions also has national contracts with emergency response contractors. Ambient SO2 and NH3 detectors are alarmed and interlocked in the control room. The detectors are not locally alarmed in the field except at the entrance to the SO2 compressor building. Mechanical integrity tasks are tracked through a computerized maintenance and monitoring system. Tank inspection cycles follow API specifications and PRVs are serviced on a five-year cycle. There is no regular inspection schedule for the SO2 piping system. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: 40 C.F.R. 68.69(b) requires operating procedures to be readily accessible to employees who work in or maintain a process. Operating procedures were available to operators electronically in the control room, and checklists were available as hard copies. Inspectors traced piping for the liquid SO2 process from the Vaporizer to the 30,000-gallon storage tanks and made the following observations: o 40 C.F.R. 68.65(a) requires written process safety information to be compiled, including information pertaining to the equipment in the process. Inspectors found the P&IDs to be generally consistent with the process equipment. Inspectors noted that Page 3 of 11 Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 carbon steel pipe spools and piping components were installed on certain lines indicated as stainless steel material of construction on the P&IDs. o 40 C.F.R. 68.73(b)(1) requires inspection and tests to be performed on process equipment. Inspectors observed external corrosion on carbon steel process equipment, including piping, flange bolts, and valves. Inspection and testing records were requested from the facility for later review. o The process contained multiple small-diameter lines for draining, venting, or bleeding that were isolated from the atmosphere by a single closed valve. Inspectors viewed the truck and railcar loading stations for liquid SO2, as well as the railcar loading station for oleum. The entrance to the SO2 vent system at both railcar loading stations is equipped with a flow switch for detecting liquid flow into the vent system. Inspectors traced piping for the ATS process from the NH3 railcar unloading and storage area to the Gassing Tank: o The definition of stationary source at 40 C.F.R. 68.3 includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading. The NH3 railcar feeding the ATS process was disconnected from its mode of transport at the loading station. o Ammonia feed piping to the Gassing Tank contained an open line isolated by a single valve and an open line isolated by two valves. Photos and/or Videos: were taken during the inspection. See Digital Image Log at Appendix A Field Measurements: were not taken during this inspection. RECORDS REVIEW The facility provided the following documents to EPA in advance of the inspection: General Visitor Presentation Oleum Process Description Liquid Sulfur Process Description ATS Process Description 2019 Liquid SO2 and Oleum HAZOP Worksheet1 2020 ATS HAZOP Worksheet During the inspection, Inspectors reviewed the following records (printed records that were retained by Inspectors are indicated with an asterisk): 1 The PHA provided to EPA prior to the inspection was dated 2018. The facility provided documentation to Inspectors demonstrating that the correct date is 2019. Page 4 of 11 Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 EHS-500: Process Safety Management/Risk Management Plan Management program Oleum P&IDs (Drawing Nos. 11CHI-12-PR-0001 to 11CHI-12-PR-0003)* Liquid SO2 P&IDs (Drawing Nos. 11CHI-13-PR-0001 to 11CHI-13-PR-0012)* Ammonia rail unloading and ammonia storage tank P&ID (Drawing No. 11CHI-20-PR-0001)* Select operating procedures and operator checklists Blank confined space, hot work, line break, and LOTO permits Sample employee training records Blank hazard reporting card 2021 incident investigation report Sample of completed management of change documents with supporting packages EHS-200: Emergency Response Plan Dakota EHS software for tracking action items and incidents The following observations were made during the records review process: Management System for Implementing Elements of Risk Management Program 40 C.F.R. 68.15(a) requires the development of a management system for implementing elements of the Risk Management Program. The facility developed procedure EHS-500, which outlines the facility's management system for its Process Safety Management and Risk Management Program. Process Hazard Analysis (PHA) 40 C.F.R. 68.67(a) requires an initial PHA to be conducted that identifies, evaluates, and controls the hazards of the process. The facility conducted an initial PHA on the ATS process on December 15, 2020. Six nodes were evaluated using the HAZOP method. Node descriptions are not provided in the ATS PHA report. 40 C.F.R. 68.67(f) requires the PHA to be updated and revalidated at least every five years. The facility conducted a PHA update and revalidation for the liquid SO2 and oleum processes in 2019. Twenty-two nodes were evaluated using the HAZOP method, and human factors and facility siting were evaluated using a checklist. Operating Procedures 40 C.F.R. 68.69(d) requires safe work practices to be developed and implemented to provide for the control of hazards during operations such as lockout/tagout, confined space entry, and opening process equipment or piping. The facility has developed a permit system for hazardous operations, including job hazard analysis, lockout/tagout, and line break permits. Page 5 of 11 Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 Training 40 C.F.R. 68.71(c) requires the owner or operator to ascertain that each employee involved in operating a process has received and understood the required training. Inspectors reviewed sample operator training records that included a written competency test. Mechanical Integrity 40 C.F.R. 68.73(b) requires written procedures to be established and implemented to maintain the on-going integrity of process equipment. The facility manages inspection and testing of equipment through e-Maintenance software, but the facility did not provide a written mechanical integrity procedure at the time of the inspection. 40 C.F.R. 68.73(d)(1) requires inspections and tests to be performed on equipment. Inspectors reviewed samples of inspection and testing records for items including pressure vessels, interlocks, and gas detectors. Management of Change (MOC) 40 C.F.R. 68.75(a) requires written procedures to be established and implemented to manage changes. Inspectors reviewed sample MOC packages that included completed MOC authorization forms, documentation of training, updated procedures, and updated process safety information. Pre-Startup Safety Review (PSSR) 40 C.F.R. 68.77(a) requires a PSSR to be performed for significant modifications. The facility includes PSSR documentation with the MOC package. Inspectors reviewed a sample MOC package that contained a completed PSSR form. Incident Investigation 40 C.F.R. 68.81(a) requires the investigation of each incident which resulted in, or could reasonably have resulted in a catastrophic release, and 40 C.F.R. 68.81(d) requires a report to be prepared at the conclusion of the investigation. Inspectors reviewed an incident report prepared for an SO2 leak from a blinded nozzle on the Make Tank that occurred in June 2021. Emergency Response 40 C.F.R. 68.95(a)(1) requires an emergency response program to include an emergency response plan. The facility developed emergency response plan EHS-200, which establishes procedures and mitigative steps for handling emergencies. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: EHS-500 (Management Program) Process Safety Information electronic folder Operating Procedures electronic folder Page 6 of 11 Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 PHA documentation, including the latest ATS PHA and the list of PHA recommendations with completion date MOC/PSSR electronic folder Inspection, Testing, and Repairs electronic folder Emergency Response Plan electronic folder Incident Investigation electronic folder Two copies of completed JSA permits with associated LOTO, Line Break, and other associated permits Compliance Assistance: Inspectors informed facility personnel that the 1" valve upstream of pressure relief device PSV 780.102 was missing a car seal. Concerns: Numerous small-diameter drain, vent, and bleed lines that discharge to atmosphere were not plugged and instead relied on a single valve to contain regulated and other extremely hazardous substances. Facility personnel identified portions of covered processes as being outside the RMP boundary. The piping system for the liquid SO2 process had a mix of stainless and carbon steel construction. DIGITAL SIGNATURES MATTHEW Digitally signed by MATTHEW WALTERS WALTERS Date: 2023.12.06 15:59:23 -06'00' Report Author: _________________________________ Section Supervisor: Digitally signed by BRIAN BRIAN DICKENS DICKENS Date: 2023.12.07 08:47:13 -06'00' __________________________________ Page 7 of 11 APPENDICES A. Digital Image Log Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 Page 8 of 11 Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Matthew Walters 2. Archival Record Location: R5 Electronic Record Center (AECAB Library/Enf_PVSChemicals_IL_24/ Inspection 2023.10.26/Photos) Image Number 1 2 3 4 5 6 7 8 File Name MSW_2023.10.27 (1).JPG MSW_2023.10.27 (2).JPG MSW_2023.10.27 (3).JPG MSW_2023.10.27 (4).JPG MSW_2023.10.27 (5).JPG MSW_2023.10.27 (6).JPG MSW_2023.10.27 (7).JPG MSW_2023.10.27 (8).JPG 9 MSW_2023.10.27 (9).JPG 10 MSW_2023.10.27 (10).JPG 11 MSW_2023.10.27 (11).JPG 12 MSW_2023.10.27 (12).JPG 13 MSW_2023.10.27 (13).JPG 14 MSW_2023.10.27 (14).JPG 15 MSW_2023.10.27 (15).JPG 16 MSW_2023.10.27 (16).JPG 17 MSW_2023.10.27 (17).JPG Date and Time (CDT) 2023:10:27 09:15:44 2023:10:27 09:16:38 2023:10:27 09:18:53 2023:10:27 09:19:46 2023:10:27 09:21:03 2023:10:27 09:22:38 2023:10:27 09:25:11 2023:10:27 09:28:37 2023:10:27 09:31:50 2023:10:27 09:32:00 2023:10:27 09:34:46 2023:10:27 09:36:56 2023:10:27 09:38:14 2023:10:27 09:40:31 2023:10:27 09:40:58 2023:10:27 09:42:29 2023:10:27 09:44:45 Description of Image SO3 Vaporizer SO3 Vaporizer outlet piping and 13DM3 Demister Blind flange on SO3 feed piping to Primary Reactor SO3 inlet to Primary Reactor PSE 360.102 rupture disc on Primary Reactor PI 360.107 pressure gauge with open 1/2" line isolated by single valve Outlet piping and 13DM4 Demister from Secondary Reactor Pressure gauge on Secondary Reactor outlet piping to SO2 scrubber with plugged 1/2" valve PI 460.106 pressure gauge with plugged 1/2" valve and open 1/2" line isolated by single unplugged valve on SO2 piping to Brinks 13DM1 Demister PI 460.106 pressure gauge with plugged 1/2" valve PI 480.101 and PI 480.102 pressure gauges each with an open 1/2" line isolated by a single valve on Brinks 13DM1 Demister Check valve on SO2 outlet piping from Brinks Demister Connection of carbon steel and stainless steel pipe sections on SO2 piping to compressor building with plugged 1/2" valve Vent line and open 1/2" line isolated by a single valve on SO2 piping to compressor Closed 1" valve to vent system from SO2 piping to compressor SO2 alarm at entrance to compressor building 6" valve (arrow in opposite direction as flow) and vent line on SO2 feed piping to Knock-Out Pot Page 9 of 11 Image Number 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 File Name MSW_2023.10.27 (18).JPG MSW_2023.10.27 (19).JPG MSW_2023.10.27 (20).JPG MSW_2023.10.27 (21).JPG MSW_2023.10.27 (22).JPG MSW_2023.10.27 (23).JPG MSW_2023.10.27 (24).JPG MSW_2023.10.27 (25).JPG MSW_2023.10.27 (26).JPG MSW_2023.10.27 (27).JPG MSW_2023.10.27 (28).JPG MSW_2023.10.27 (29).JPG MSW_2023.10.27 (30).JPG MSW_2023.10.27 (31).JPG MSW_2023.10.27 (32).JPG MSW_2023.10.27 (33).JPG 34 MSW_2023.10.27 (34).JPG 35 MSW_2023.10.27 (35).JPG 36 MSW_2023.10.27 (36).JPG 37 MSW_2023.10.27 (37).JPG 38 MSW_2023.10.27 (38).JPG Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 Date and Time (CDT) 2023:10:27 09:46:13 2023:10:27 09:47:39 2023:10:27 09:48:42 2023:10:27 09:50:18 2023:10:27 09:54:54 2023:10:27 09:57:39 2023:10:27 09:59:06 2023:10:27 10:04:03 2023:10:27 10:04:09 2023:10:27 10:09:18 2023:10:27 10:11:45 2023:10:27 10:11:57 2023:10:27 10:20:01 2023:10:27 10:21:02 2023:10:27 10:23:22 2023:10:27 10:25:33 2023:10:27 10:37:29 2023:10:27 10:37:36 2023:10:27 10:42:02 2023:10:27 10:42:11 2023:10:27 10:43:08 Description of Image STR-201 Y-strainer at inlet to Sullair SO2 Compressor 13PT-150 pressure transmitter and plugged 1/2" line on 13V4 Pressure Vessel PT 202 pressure gauge on piping from SO2 Final Filters to SO2 Product Cooler LOTO equipment in compressor building Open 3/4" line isolated by a single valve on Make Tank liquid SO2 discharge piping Open vent valve on Liquid Transfer Pump (13P4) discharge piping (not car sealed) SO2 Sample Station PSV 450.101 and 450.104 pressure relief valves on the 450 SO2 Storage Tank Nozzles A, B, C, E, and F on the 450 SO2 Storage Tank Open 3" valve on vent line from 450 SO2 Storage Tank (car sealed) Open 2" valves on vent line from SO2 storage tanks (car sealed and chain locked) Pressure relief discharge from SO2 tank vent line to open 3" valve (car sealed) FS 442.01 liquid flow switch on SO2 truck loading station vent line SO2 truck loading station SO2 railcar loading and storage area FS 443.01 liquid flow switch on SO2 rail car loading station vent line XV-12TK1-06 automatic valve on oleum rail car loading line and 12LSAHH-105 liquid flow switch on rail car vent line Flexible hoses for connection to oleum rail car Anhydrous ammonia rail car connected to ATS process Anhydrous ammonia storage tank ATS process connection to anhydrous ammonia rail car Page 10 of 11 Image Number 39 File Name MSW_2023.10.27 (39).JPG 40 MSW_2023.10.27 (40).JPG Facility Name: PVS Chemical Solutions, Inc. Facility Location: Chicago, IL Date of Inspection: October 26, 2023 Date and Time (CDT) 2023:10:27 10:48:13 2023:10:27 10:48:32 Description of Image Ammonia feed piping to ATS process with an open line isolated by a single valve and an open line isolated by two valves Ammonia feed piping to 19TK4 Page 11 of 11