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Envlronmtnta.l Protection
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Agency
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date{s): Media: Regulatory Program{s)
Company Name: Facility Name: Facility Physical l ocation:
September 17-20, 2018 Air Clean Air Act Section 112{r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions
Blue Cube Operations LLC Blue Cube Operations Plaquemine 21255 Highway 1 S, Plaquemine, LA 70765
(city, state, zip code)
Plaquemine, LA 70765
Mailing address:
21255 Highway 1 S P.O. Box 424
{city, state, zip code-) !~Plaquemine, lA 70765 -
County/Parish : Facility Contact:
lberville
Stephen Ledoux- (225)353-6778 I Plant Manager
FRS Num be r: Identification/Perm it Number: Media Number: NAICS: NAICS:
110067415871
EPA Facility Identifier: 10000023 1536 32518 Other Basic Inorganic Chemical Manufacturing 32519 Other Basic Organic Chemical Manufacturing
Personnel participating in inspection:
Allyson Ledet
Blue Cube Operations
Sarah Babin
Blue Cube Operations
Keith Schell
Blue Cube Operations
David Martin
Blue Cube Operations
Blake Siem inski
US EPA
Environmental Manager Environmental Specialist PSM Manager Process Safety Tech l eader Inspector/ Enforcement Off.
(225 )353-1500 (225 )353-1500 (225 )353-1500 (225)353-1500 (214)665-8062
EPA Lead Inspector Signature/Date
EPA lead Inspecto r
B11'l,e Sieminski
Signa t u r e / D a t e
Supervisor Signature/Date Supervisor
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Samuel Tates
Signature/Date
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Date
i Z/1/uiB
!z./4I /2018
Date
6ENFORM-019-R7 {2/15/2017)
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Blue Cube Opera tions Plaquemine Inspect ion Date 9/17-20/2018
Section I -INTRODUCTION
PURPOSE OF THE INSPECTION
I, United States Environmental Protection Agency (EPA) Region 6 Inspector Blake Sieminski, arrived at the Blue Cube Operations facility at approximately 1:00PM on Monday September 17, 2018 for an announced ins pection . I met with Allyson Ledet, Sarah Babin, Keith Schell and David Martin. I presented my credentials and informed Blue Cube personnel that this was an EPA inspection to determine compliance with the facility's Chemical Accident Prevention Provisions Program. The scope of the inspection was a partial compliance evaluation (PCE) and included an evaluation of the compliance of the facility with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions (40 C.F.R. Part 68). The Blue Cube Operations Plaquemine (BCO) is listed as a Risk Management Plan (RMP) Progra m three (3) facility. Blue Cube Operations Plaquemine is not a union faci iLty. 1be Lo-Uisiana- - - - - - - ---;D; epartment on Environmental Quality was notified of this PCE inspection and joined me on Tuesday September 18, 2018 during this inspection.
NAME Allyson Ledet Sarah Babin Keith Schell David Martin Blake Sieminski
Table 1: Opening Meeting Attendance; Monday September 17, 2018
COMPANY Blue Cube Operations Blue Cube Operations Blue Cube Operations
TITLE Environmental Manager Environmental Specialist PSM Manager
Blue Cube Operations
Process Safety Tech Leader
U.S. EPA
Inspector
FACILITY DESCRIPTION
Blue Cube Ope rations Plaquemine operates a basic organic and inorganic chemical manufacturing facility. The facility is located in Plaquemine, Louisiana. BCO is a facility which receives and/or stores various regulated flammable chemicals by trucks and pipelines. The products onsite include chlorine, chloroform, hydrogen chloride, and methyl chloride. The facility employs approximately 205 employees and 150-200 contractors.
Section II- OBSERVATIONS
On Wednesday September 19, 2018, LDEQ and BCO personnel, and I conducted a site walk-through of the facility to observe the covered process, equipment, and operations. The facility lists two covered processes in the RMP as Chlorine plant and Solvents/ EDC. We toured both processes and their respective control rooms, and tank T-86A, which was chosen as the example for worst-case scenario release due its location inside the DOW facility.
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Blue Cube Operations Plaquem ine Inspection Date 9/17-20/2018
40 C.F.R. Part 68- CHEMICAL ACODENT PREVENTION PROVISION
Subpart A- General
40 C.F.R. 68.10 Applicability -I observed that BCO is a stationary source with a Clean Air Act Title-V permit (2188-V9 and 2537N9) that has more than a threshold quantity of regulated substances in their process. BCO re-submitted a Risk Management Plan (RMP) (5-year update for 40 CFR 68.190{b)(1)) on September 13, 2018, which described the process containing chlorine, chloroform, hydrogen chloride, and methyl chloride held at more ~han a threshold quantity. BCO is a Risk Management Plan Program 3 facility. BCO is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119).
- - - - - 40 C.F.R. 68.12 General requirements- BCO's Risk Management Plan {RMP}. which was re.submitted_ __ _ _ _
on September 13, 2018, lists chlorine, chloroform, hydrogen chloride, and methyl chloride over the threshold for Program Level3 processes.
40 C.F.R. 68.15 Management- BCO developed a management system to oversee the implementation of the risk management program elements. The organizational chart that was provided outlined the positions to implement the individual elements of the RMP as required by this subpart.
Subpart B- Hazard Assessment-
40 C.F.R. 68.20 Applicability- BCO is a Program 3 stationary source subject to this part. The facility is required to prepare an offsite consequence analysis and complete the five-year accident history.
40 C.F.R. 68.22 Offsite consequence analysis parameters- The offsite consequence analysis and supporting documentation was reviewed to assure the data was accurate and to confirm the parameters used by BCO to document this data.
40 C.F.R. 68.25 Worst-case release scenario analysis- BCO identified and document ed a worst-case release scenario analysis for the RMP covered regulated substances. The distance to endpoint for regulated substances was calculated using RMP*CompM.
40 C.F.R. 68.28 Alternative release scenario analysis- BCO identified and analyzed at least one alternative release scenario for each regulated substance, as well as,.at least one alternative release scenario to represent all regulated substances held in covered processes. The distance to endpoint was calculated using RMP*CompM.
40 C.F.R. 68.30 Defining offsite impacts-population -BCO discussed the offsite consequence analysis. and used the 2010 Census Bureau population data to calculate population numbers reported in their September 13. 2018 RMP resubmission.
40 C.F.R. 68.33 Defining offsite impacts-environment- BCO provided documentat ion that identified the potential offsite impacts and identified public receptors.
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