Document reGKXp51qKvxgLgYZeXwjb6dr
MEMORANDUM
SUBJECT:
CLEAN AIR ACT INSPECTION REPORT Central Indiana Ethanol, LLC
FROM:
Manojkumar P. Patel, Environmental Engineer AECAB (MI/WI)
THRU:
Sarah Marshall, Section Supervisor AECAB (MI/WI)
TO:
File
BASIC INFORMATION
Facility Name: Central Indiana Ethanol, LLC
Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
EPA Inspector(s):
1. Manojkumar P. Patel, Environmental Engineer
Other Attendees:
1. Mike Browder, Environmental, Health and Safety Engineer, Central Indiana Ethanol LLC 2. Ryan Drook, Chief Executive Officer, Central Indiana Ethanol, LLC 3. Mark Sevier, Director of Quality, Central Indiana Ethanol, LLC 4. Brady Turner, Operations, Central Indiana Ethanol, LLC 5. Austin Crouch, Maintenance Supervisor, Central Indiana Ethanol, LLC 6. Eric Utterback, V.P. Operations, Central Indiana Ethanol, LLC
Contact Email Address: mbrowder@cie.us
Purpose of Inspection: Compliance with the Chemical Accident Prevention Provisions found in Section 112(r) of the Clean Air Act (CAA), 42 U.S.C. 7412(r)
Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
Facility Type: Ethanol Manufacturing Operations with natural gasoline (Flammable Mixture)
Regulations Central to Inspection: The Chemical Accident Prevention Provisions at 40 C.F.R. Part 68, commonly referred to as the Risk Management Program
Arrival Time: 9/24/2024 at 8:50 am CST; 9/25/2024 at 8:00 am CST Departure Time: 9/24/2024 at 4:30 pm CST; 9/25/2024 at 1:00 pm CST
Inspection Type: Unannounced Inspection Announced Inspection
OPENING CONFERENCE
Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Provided CBI warning to facility
The following information was obtained verbally from the facility personnel unless otherwise noted.
Company Ownership: In or around December 2021, CC Industries acquired Central Indiana Ethanol, LLC operations located in Marion, Indiana.
Process Description:
Central Indiana Ethanol, LLC (CIE or the facility) operates 24 hours a day, 7 days a week, and employs about 60 full-time employees. The facility performs the following operations: grain receiving, hammer milling, fermentation, distillation, dehydration and evaporation, separation, wet and dry distillers' grain and solubles (WDGS/DDGS) drying, corn oil separation, and ethanol storage. The facility also procedures carbon dioxide (CO2) from the fermenters scrubber and produces food grade CO2.
The facility has one (1) natural gasoline storage tank with 100,000 gallons capacity and it is located in the tank farm area. The natural gasoline is used to denature the ethanol in the tank farm area. Natural gasoline is a flammable mixture. The four constituents of natural gasoline are butane, pentane, neo-pentane (or 2,2- dimethylpropane), and iso-pentane (or 2-methylbutane). The four constituents are part of the Risk Management Plan (RMP) requirements. Butane makes up 0.806% of the natural gasoline, pentane makes up 24.518%, neo-pentane makes up 0.237%, and iso-pentane makes up about 22.96%.
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
TOUR INFORMATION
EPA Toured the Facility: Yes
Data Collected and Observations:
The following observations were made during the records review process:
Risk Management Program Applicability
The facility describes its operations as under the North Industrial Classification Standards (NAICS) code 325193 (Ethyl Alcohol Manufacturing). This NAICS code is not listed under the eligible NAICS code under the RMP regulations. However, the covered process meets the Program Level 3 eligibility requirements because the covered processes are subject to the Occupational Health and Safety Agency (OSHA) Process Safety Management standards at 29 C.F.R. 1910.119 and it satisfies the requirements at 40 C.F.R. 68.10(i)(2).
Management System EPA requested documentation of the management system for implementing elements of the RMP, as specified in 40 C.F.R. 68.15(a). The facility provided records of a RMP management system at the time of inspection.
The facility was unable to provide an assigned qualified person or position that has the overall responsibility for the development, implementation, and integration of RMP elements. Also, an organizational chart or similar document was not provided to EPA demonstrating the individual requirements of RMP.
Process Safety Information
The facility provided a Process and Instrumentation Diagram (P&ID) for the covered process equipment. The process chemistry and the maximum intended inventory is described in the RMP plan. The facility will provide the safe upper and lower limits for temperatures, pressures, and flows for the covered process equipment under the denaturant system for EPA's review.
The facility provided Process Deviations and Consequences for the Anhydrous Ammonia System. The facility did not evaluate the potential consequences of deviation resulting from the safe upper and lower limits for temperatures, pressures, or flows.
The facility will upload an electrical classification layout P&IDs to satisfy the requirements under 40 C.F.R. 68.65(d)(1)(iii). The facility did not provide a relief system design and design basis for the covered equipment.
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
EPA requested documents related to the safety systems on the covered equipment and the facility stated that it will provide a document that will address the safety system on the covered process equipment. The facility stated that the ventilation system design will be uploaded for the facility's covered processes.
EPA was unable to verify the facility's applicable design codes and standards employed. The facility informed EPA that it will upload them to a SharePoint site at a later time. The facility did not have a material and energy balance for the covered processes (Ammonia System and Denaturant System) as these covered processes were built after June 21, 1999.
Process Hazards Analysis
The facility used the Checklist and Hazards and Operability Study (HAZOP) methods for the latest PHA revalidation in 2024. EPA observed that the facility updated or revalidated the PHA every 5 years to show it is consistent with the current covered process. The facility's prior PHA was performed in 2019 using HAZOP and Checklist methods.
We discussed the NODE #8 Ammonia System in the 2024 PHA. The facility uses a truck's pumping system for unloading anhydrous ammonia into the Anhydrous Ammonia Tank. The facility did not define the pump's stop and the pump's breaks in NODE #8.
We also discussed about the NODE #10 - Denaturant Storage, and Final Product Tanks. In paragraph 10.1 Recommendation column, a "deadhead condition" is not defined. As per the facility, a "deadhead condition" is a phase where unloading pumps are running but the valves are closed. The facility is in process of revising its SOP for the denaturant tank to add "operator opens the deadhead valves prior to unloading of natural gasoline". Secondly, the facility needs to add "shut the drain line isolation valve prior to PG-8306 and open valve prior to the Tank TF-8306".
Operating Procedures
The facility will provide all operating procedures for EPA's review to a SharePoint site. The facility stated that all operating procedures are readily accessible by employees who are involved in the covered processes through a Document Control Software (DCS). The facility informed EPA during the inspection that the facility did not annually certify that operating procedures are current and accurate, and they were not reviewed to assure the facility's current operating practices.
Opening of process equipment and line break are part of Lockout and Tagout (LOTO) policy and the facility will upload the policy.
Training
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
EPA requested RMP training records for all employees at the facility. Specifically, EPA requested that all records must contain information that each employee understood the training on the operating processes and can verify that each employee understood the training. All training records were uploaded to the SharePoint folder.
Mechanical Integrity
The facility claims that it has established and developed written procedures to maintain the on-going integrity of the process equipment. EPA requested inspection, calibration, testing records for tank farm equipment, all related transfer pumps, loading and unloading arms, pressure relief valves (PRV), and tank level gauges.
The facility provided the Mechanical Integrity (MI) policy and procedures for all covered equipment. EPA did not verify the inspection and the required testing performed on all process equipment. The facility will provide documents demonstrating that it followed RAGAGEP for inspections and tests on all covered equipment.
Management of Change
The facility informed EPA that it established and implemented written procedures to manage change to process chemicals, technology, and equipment. EPA requested a list of Management of Change (MOC) in the last 5 years and requested the facility to upload all information related to the MOCs. The facility claimed that it did not have any MOCs in the last 5 years.
Compliance Audits
At the time of the inspection, the facility provided compliance audit reports that have been performed for the facility's RMP covered processes. The facility completed the latest compliance audit (CA) on July 18, 2023. The previous CA was completed on April 25, 2021. The RMP regulations require the facility to certify that it evaluated compliance with RMP regulations at least every three (3) years to verify that the procedures and practices are being followed adequately.
EPA reviewed the 2023 Audit findings and observed that the report described several findings were marked NS (as not in compliance with the RMP criteria).
The latest 2023 CA report stated that the facility does not maintain a document on the maximum capacity of the process vessels or piping and recommended the facility to update the maximum intended inventory including the pressure vessel capacity and piping capacity.
The 2023 CA report stated that no operating limits are defined with the SOPs at the facility and the report recommends updates to the SOPs to include normal operating limits including safe upper and lower limits and exit points from normal operations into emergency operations or shutdown procedures for the Process Safety Management (PSM) covered processes. The 2023 CA report states
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024 that no conditions for emergency shutdown were defined within the SOPs and recommends to define the conditions in which emergency operations or emergency shutdown is required.
As per the 2023 CA Report, operating limits do not contain consequences of deviation and steps required to correct or avoid deviation. The 2023 CA Report suggests to develop SOPs to define actions to take to avoid deviation from normal operating conditions and address the hazards of the chemicals in the processes.
The facility's SOPs do not contain safety systems and its functions for the covered processes.
The facility did not document visual inspection of the rupture disks during the shutdown and 2023 CA report recommended to add documentation for visual inspections of rupture disks in the shutdown checklist.
The 2023 CA Report provides that there is no established process for evaluation of contractor safety. The 2023 CA Report recommends developing and implementing a process to periodically evaluate contractor performance, safety protocols, and training records.
Employee Participation
The facility informed EPA during the inspection that it developed a written plan of action regarding the implementation of employee participation to access PHAs, operating procedures, and all related information under the RMP regulations.
Contractors
The facility claims that it collects and evaluates information regarding the contract owner or operator's safety performance when it selects a contractor. However, EPA was unable to verify how the facility evaluates a contractor's periodical performance.
Emergency Response
The facility informed EPA that its facility is designated as a "non-responding source" under RMP emergency response program. EPA received a revised Emergency Response Plan dated May 3, 2024.
Photos and/or Videos: were taken during the inspection and are listed in Appendix A.
Field Measurements: were not taken during this inspection.
CLOSING CONFERENCE
Provided U.S. EPA point of contact to the facility
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Requested documents:
Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
2020/2021 Compliance Audit Report July 18, 2023, Compliance Audit Report Protect Project 9/2024 Report First Verify Screenshot - Annual Review First Verify Screenshot Review 9-2021 First Verify Screenshot Westmore Project 8-2024 First Verify Screenshot Zeeco Project 7-2023 Emergency Action Plan dated May 3, 2024 CIE PSM Committee Meeting Minutes dated January 10, 2024 API 653 Storage Tank TF-8306 Inspection Report dated February 11, 2021 API 653 Storage Tank TF-8309 Inspection Report dated February 8, 2021 API 510 Anhydrous Ammonia Tank TP-12401 Inspection Report dated November 12, 2020 Pressure Safety Valve Replacement Report Manufacturer Specifications for CROSSBY Series valves, Hydro seal valves, SQUIBB TAYLOR
Relief Valves F-720-013 Maintenance Technicians Training Checklist Standard Operating Procedures WI-C-1040 Filling Ammonia Tank SOP WI-C-1075 Starting Ammonia System SOP WI-C-1083 Working on the Ammonia System SOP WI-D-1019 Offload Denatured Truck SOP WI-M-1240 Resetting Liquid Ammonia Breakaway Valve CIE 2019 PHA Final Report (8/30/2019) CIE Marion PHA Final Report (7/14/2019) F346 PSV ASME Standards Rev 3 F346 Wall Louvers Rev 0 ICM40 Wall Louvers Design Calculations Rev 0 01 PK-12400 Specifications Rev 0 02 Ammonia Pkg Cut Sheets TP4, TP5, TP6, TP7 (2015) Documents TP12401 Ammonia Tank Specification Anhydrous Ammonia Safety Data Sheet Natural Gasoline Data Sheet (3/2/2023) New Hire Training Ammonia Driver Training Logs Incident Investigation Policy (P-PSM-1012) Pre-Startup Safety Review Policy (P-PSM-1008) Mechanical Integrity Policy (P-PSM_1009) Management of Change Policy (P-PSM-1011) Employee Participation Policy (P-PSM-1002) Hotwork Policy (P-PSM-1010)
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
Contractor Safety Policy (P-PSM-1007) Process Deviations and Consequences
DIGITAL SIGNATURES
MANOJKUM MANOJKUMAR PATEL Digitally signed by
Date: 2024.11.04
Report Author: _A_R__P_A__T_E_L____1_5:_12_:0_7_-0_6'0_0'_____________
Section Supervisor:
SARAH
Digitally signed by SARAH MARSHALL
Date: 2024.11.05
_M__A_R_S__H_A__L_L__0_8_:55_:4_8_-0_6'_00_' _____________
APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG
Inspector Name: Manojkumar P. Patel Sept 25 2024
Archival Record Location: CAA RMP Inspection Pictures
Image Number
File Name
Date and Time (incl. Time zone and DST)
1
P9250328.JPG 9/25/2024 10:21
2
P9250329.JPG 9/25/2024 10:22
3
P9250330.JPG 9/25/2024 10:25
4
P9250331.JPG 9/25/2024 10:25
5
P9250332.JPG 9/25/2024 10:26
6
P9250333.JPG 9/25/2024 12:14
7
P9250334.JPG 9/25/2024 12:14
8
P9250335.JPG 9/25/2024 12:16
9
P9250336.JPG 9/25/2024 12:19
10
P9250337.JPG 9/25/2024 12:23
11
P9250338.JPG 9/25/2024 12:23
12
P9250339.JPG 9/25/2024 12:24
13
P9250340.JPG 9/25/2024 12:25
14
P9250341.JPG 9/25/2024 12:26
15
P9250342.JPG 9/25/2024 12:29
16
P9250343.JPG 9/25/2024 12:31
17
P9250344.JPG 9/25/2024 12:32
18
P9250345.JPG 9/25/2024 12:32
19
P9250346.JPG 9/25/2024 12:34
20
P9250347.JPG 9/25/2024 12:34
21
P9250348.JPG 9/25/2024 12:37
22
P9250349.JPG 9/25/2024 12:37
23
P9250350.JPG 9/25/2024 12:38
24
P9250351.JPG 9/25/2024 12:41
25
P9250352.JPG 9/25/2024 12:45
26
P9250353.JPG 9/25/2024 12:47
27
P9250354.JPG 9/25/2024 12:47
Description of Image
Denaturant Unloading (Bottom w/ facility's pump)
Denaturant Unloading Pressure Gauge Final Product Loadout - Bottom Rack
Final Product Loadout - Filter
Final Product Loadout - Filter Pressure Readout @PSI
PSV on the Filter Skid Ethanol Loadout Bottom - Yellow Vapor Pressure Indicator 150 PSI Bottom Loading Arm
Manual Valve (Separates Bottom & Top Loading Arm)
Denaturant Tank T 8306 Denaturant Tank T 8306 (Closer View)
Denaturant Loading Pipe - Yellow (Left Manual Valve Close; Right Valve - Close; Middle Manual Valve - Open)
Firesafe Valve Pressure Indicator from Denaturant Tank to Pump to
Final Product Tank TF 8309 Denaturant Enters the Ethanol Line Ethanol w/ Denaturant Transfer & Recirculation Temperature Indicator Readout @ 64F
Firesafe Valve w/ Fusible Link Pump 8309
Pump 8309 to Truck Loadout / Recirculation Recirculation Valve
Air Pressure to the Air circulation valve Flow Regulator (controls flow rate between Truck and
Rail Loadout) TF 8309 Denatured Ethanol 750,000 Gallons
Vapor Knockout Tank
N.G. Pressure Regulator (one is at 12 PSI; other is 8 PSI)
Flame Arrestor - In 3" H2O; Out - 3" H2O)
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Facility Name: Central Indiana Ethanol, LLC Facility Location: 2955 West Delphi Pike, Marion, Indiana 46952
Date of Inspection: September 24 and 25, 2024
28
P9250355.JPG 9/25/2024 12:49
29
P9250356.JPG 9/25/2024 12:51
30
P9250357.JPG 9/25/2024 12:52
31
P9250358.JPG 9/25/2024 12:56
32
P9250359.JPG 9/25/2024 12:57
33
P9250360.JPG 9/25/2024 12:58
34
P9250361.JPG 9/25/2024 12:58
35
P9250362.JPG 9/25/2024 12:59
36
P9250363.JPG 9/25/2024 13:00
37
P9250364.JPG 9/25/2024 13:03
38
P9250365.JPG 9/25/2024 13:04
39
P9250366.JPG 9/25/2024 13:10
40
P9250367.JPG 9/25/2024 13:10
41
P9250368.JPG 9/25/2024 13:11
42
P9250369.JPG 9/25/2024 13:11
43
P9250370.JPG 9/25/2024 13:12
44
P9250371.JPG 9/25/2024 13:13
45
P9250372.JPG 9/25/2024 13:15
46
P9250373.JPG 9/25/2024 13:15
47
P9250374.JPG 9/25/2024 13:17
Open /Close Valve prior to the Flame Arrestor Flare Vapor Line Main / Pilot Burner Flare Name Plate
Rail Loadout Pump PG 8310 (Denaturant to Tank TF8306)
Pressure Indicator on PG 8310 Filter Skid Knockout Tank Strainer on the Skid
PSV 8402 Denaturant Filter (Dripping) Second PSV PMA 400 PSI Name Plate Information
Filter Differential Pressure Gauge Anhydrous Ammonia Tank TP 1240 Anhydrous Ammonia Tank TP 1240 Sideview
Fill Level Gauge 70% Pressure Gauge 110 PSI Temperature Gauge 56 F Ammonia Tank 4 PSV on the Top Ammonia Unloading Left Inspection of Ammonia Unloading Signage Ammonia Tank Name Plate Information
48 P9250375.JPG 9/25/2024 13:19 PSVs (2) on the Anhydrous Ammonia to Slurry Tanks
49
P9250376.JPG 9/25/2024 13:21
Pressure Indicator 109 readout
50
P9250377.JPG 9/25/2024 13:22
51
P9250378.JPG 9/25/2024 13:22
52
P9250379.JPG 9/25/2024 13:23
53
P9250380.JPG 9/25/2024 13:25
Anhydrous Ammonia Entrance to the Slurry Tank
PSV-2 (Outside of the Process Building) Windsock (Entrance of the Process Building)
Pressure Indicator
54
P9250381.JPG 9/25/2024 13:27
55
P9250382.JPG 9/25/2024 13:28
56
57
58
P9250385.JPG 9/25/2024 13:37
59
P9250386.JPG 9/25/2024 13:42
60
P9250387.JPG 9/25/2024 13:50
Anhydrous Ammonia Introduction to Slurry Tank Message Board for Employees
Emergency Stop (E-Stop) inside DCS E Stop Outside of the Lab in the Process Building
PSV from Anhydrous Ammonia Tag
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