Document vVDnb0KLEk08Oe832YLqXq2mR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Inspection Report FACILITY INFORMATION: Name: Eugene Welders Supply dba Industrial Source Physical Address: 3500 Commercial Avenue, Springfield, OR 97478 Phone Number: 541-242-6101 Latitude/Longitude: 44.0535491/-122.975755 RMP Facility ID# 1000000248109 FRS ID#: 10004820374 EJ Concerns: Yes (80% and Above) CONTACT INFORMATION (RMP Implementation): Name: Pamela Jones Phone Number: 541-228-6549 E-mail: pamj@industrailsource.com EMERGENCY CONTACT INFORMATION: Name: David Ficker Phone (24-hr): 541-228-6549 E-mail: davidf@industrialsource.com TRIP DETAILS: Inspection Date: February 7, 2024 Inspection Time: 0900 hours through 1235 hours EPA Inspection Team: Terry Garcia, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Robert Faries, Weston Solutions, Inc., EPA START Contractor Ken Valder, Weston Solutions, Inc., EPA START Contractor Page 1 of 7 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: February 8, 2022 Date of Latest Update: February 8, 2022 Process Program Level 3 as reported in RMP: Process ID 1000122596 1000122596 1000122596 Description hydrocarbon filling hydrocarbon filling hydrocarbon filling Process Chemical ID 1000153491 1000153492 1000153493 NAICS Code 42469 42469 42469 Program Level 3 Chemical Name CAS Number Butane (106-97-8) 3 Isobutane (75-28-5) 3 Propane (74-98-6) Quantity (lbs) 79,383 59,660 51,253 PURPOSE: The purpose of this inspection was to determine if 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. The facility has been previously inspected in the past 5 years: No Yes If Yes, Date of Last Inspection: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the [Enter Year] Tier II report to the SERC? No Yes If Yes, Date the Tier II was submitted: 3/1/2024 If No, calendar year of the most recent Tier II: Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 3/1/2024 Page 2 of 7 INSPECTION ENTRY: Terry Garcia led the inspection entry. The EPA Inspection Team (EPA) met with facility representatives Ronnie Johnson, Pamela Jones, David Ficker, Robert Laing, and Victoria Lewis at the Eugene Welders Supply (Industrial Source) Facility in Springfield, Oregon. EPA arrived at the facility at 0900 hours and was joined by the following facility personnel: Name Ronnie Johnson Pamela Jones David Ficker Robert Laing Victoria Lewis Title, Organization Compliance Coordinator Gas Operations Manager General Manager Co-President Marketing Assistant Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes The facility is a first responder: If No, Responding Agency: No Yes Facility representatives escorted EPA to a conference room located in the facility's office building. Lead Inspector Terry Garcia, introduced all parties present, provided a summary of the Risk Management Program (RMP), and explained the purpose of the visit. Each EPA Inspector presented his/her credentials. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. David Ficker gave a brief description of the facility, operations, and personal protective equipment required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives (such as a union representative) have the right to participate in the RMP inspection, and that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: If Yes, Name of Union: No Yes An employee representative present during the facility visit: If Yes, Name/Title: No Yes Page 3 of 7 GENERAL INFORMATION: The facility is regulated as a RMP Program Level 3 facility and is owned and operated by Eugene Welders Supply dba Industrial Source. The facility provides gas filling services, offering both trans-fill and blend filling. Regulated chemicals are stored and utilized in the facility's hydrocarbon fill area on the south side of the property. The facility maintains three 12,000-gallon bulk tanks that contain pure instrument-grade hydrocarbons that are non-odorized (butane, propane, and isobutylene). There are two smaller 1,000pound tanks. The first tank contains industrial grade propane which is utilized by the facility's forklifts. The second tank is the facility's dump tank. When customers return cylinders, their contents are emptied into the dump tank and fed into the facility's flare. There are 44 full-time employees on-site, three of whom are operators (two main, one backup). The facility operates Monday through Friday from 0800 to 1700 hours. Bulk tanks were installed by Gas Innovations. ON-SITE OBSERVATIONS: EPA toured the facility from approximately 0920 to 1200 hours. EPA observed the hydrocarbon filling area located on the northwest side of the property (Photo 1). The hydrocarbon filling area utilizes emergency shutoff switches that shut down electric and mechanical functions in the filling area (Photo 2). The Propane, Butane, and Isobutane tanks are all filled via bulkheads on the north side of the filling area (Photos 3-5). Trucks connect a liquid and vapor line while filling each tank. Each tank has a certification plaque (Photos 6-8). A cinderblock wall (Photo 9) separates the hydrocarbon filling area from the neighboring property. The local fire department required the facility to construct the wall before issuing a permit. Facility representatives led EPA to the south side of the filling area. Three fill stations are utilized (Photo 10) to fill customers' cylinders to 80% capacity using a pump. Each station has a certified electronic scale and gas line running to either propane, butane, or isobutane. The fill lines were unlabeled at the time of the inspection (Photos 11 & 12). Each line runs to a 12,000-gallon tank. Each 12,000-gallon tank has a volume gauge (Photos 13-15). Customers' returned cylinders are visually inspected and any remaining contents are emptied into the facility's dump tank. Residual vapors are then vacuumed out of the cylinder and into the dump tank at the vacuum station (Photos 16 & 17). Vapor gas from the dump tank is burned off with the facility's flare stack (Photo 18). Photographs taken during the inspection are included in Attachment A to this report. EPA observed the 6,000-gallon oxygen and carbon dioxide tanks, not RMP regulated (Photos 19 & 20) before ending the walkthrough and returning to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Ronnie Johnson, Pamela Jones, David Ficker, Robert Laing, and Victoria Lewis. INFORMATION COLLECTED FROM FACILITY: 1. Sign-in Sheet 2. June 2021 Process Hazard Analysis 3. SOP Training Certification 4. Facility Plot Plan 5. Process Flow Diagrams 6. 2022 Emergency and Hazardous Chemical Inventory Page 4 of 7 AREAS OF CONCERN ADDRESSED IN THE CLOSING CONFERENCE: 1. General Applicability [68.10]: The facility has not coordinated with emergency responders. [68.10(b)] 2. General Applicability [68.10]: The facility has not developed plans for conducting emergency response exercises in accordance with 68.96 by December 21, 2023. [68.10(d)] 3. General Management [68.15]: During the inspection, the facility provided a document entitled General Management Policy identifying the persons responsible for developing and implementing the overall RMP elements but does not clearly identify roles for implementing individual RMP requirements. [66.15(c)] 4. Process Safety Information [68.65]: The facility process safety information did not contain information pertaining to the design code standards employed such as the National Fire Protection Association (NFPA) and American Society of Mechanical Engineers (ASME) codes and standards. [68.65(d)(1)(vi)] 5. Process Safety Information [68.65]: The facility was unable to provide proper documentation that shows process equipment complies with recognized and generally accepted good engineering practices (RAGAGEP). [68.65(d)(2)] 6. Process Hazard Analysis [68.67]: The facility was unable provide a PHA recommendations and findings tracking document for their 2021 PHA with the responsible person, proposed completion dates, completion dates, resolution and actions taken. [68.67(e)] 7. Mechanical Integrity [68.73]: The facility was unable to provide written maintenance procedures on their process equipment such as piping, valves, pressure vessels, pumps, and emergency shutdown system. [68.73(b)] 8. Mechanical Integrity [68.73]: The facility was unable to provide training documentation for each employee involved in maintaining the ongoing integrity of process equipment. The facility did not maintain documentation for two Maintenance Operators, David Ficker and Jordan Adams [68.73(c)] 9. Mechanical Integrity [68.73]: The facility was unable to provide inspection and testing documentation for inspection and tests performed on process equipment identifying date of the inspection, name of person who performed the inspection or test, equipment identifier, inspection or test performed, and results. [68.73(d)(1) and (d)(4)] 10. Mechanical Integrity [68.73]: The facility was unable to provide documentation showing they followed recognized and generally accepted good engineering practices (RAGAGEP) for inspection and testing procedures. [68.73(d)(2)] 11. Mechanical Integrity [68.73]: The facility was unable to provide documentation showing they ensured the frequency of inspections and tests of process equipment is consistent with applicable manufacturers, recommendations, good engineering practices, and prior operating experience. [68.73(d)(3)] 12. Mechanical Integrity [68.73]: The facility was unable to provide documentation on their quality assurance program to ensure maintenance materials, spare parts and equipment were suitable for the process application for which they would be used and appropriate checks and inspections are done to assure that equipment was installed properly. [68.73(f)] 13. Employee Participation [68.83]: The facility was unable to provide a written plan of action regarding the implementation of the employee participation required. [68.83(a)] 14. Contractors [68.87]: The facility was unable to provide documentation on the safety performance evaluation on the contract owner or operator. The facility provided contractor information for two contractors: Gas Innovations (drivers) and Revolution (electric); however the documents provided do not meet the requirements. [68.87(b)(1)] Page 5 of 7 15. Contractors [68.87]: The facility was unable to provide documentation that they implemented safe work practices consistent with 68.69(d), to control the entrance, presence, and exit of the contract owner or operator and contract employees in the covered process areas. [68.87(b)(4)] 16. Contractors [68.87]: The facility was unable to provide documentation that they periodically evaluate the performance of the contract owner or operator in fulfilling their obligations. [68.87(b)(5)] 17. Emergency Response [68.90]: The facility was unable to provide documentation that they coordinated response action with the local fire department. [68.90(b)(2)] 18. Emergency Response [68.90]: The facility was unable to provide documentation that they performed annual emergency response coordination activities. [68.90(b)(4)] 19. Emergency Response [68.93]: The facility was unable to provide documentation showing they had coordinated at least annually to address changes to their emergency action plan and/or in the community emergency response plan. [68.93(a) and (c)] 20. Emergency Response [68.93]: The facility was unable to provide documentation that they provided their emergency action plan to the local emergency planning and response organizations. [68.93(b) and (c)] DOCUMENTS REQUESTED NOT INCLUDED IN THE REPORT: The following documents were requested during the inspection but are not included in this report. These documents will still be reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. Driver bulk fill standard operating procedure and training records. Provided post inspection. 2. Pre-startup review as required by 68.77 for regulated process innovation. 3. RMP Management Policy/Orientation Chart. (Facility created and provided General Management Organizational Chart at time of inspection.) 4. Gas Innovations' training policy regarding the regulated processes. 5. Confined space and LOTO policy. 6. Pre-startup safety review policy. Page 6 of 7 INSPECTION REPORT CERTIFICATION: This is to certify that I, Terry Garcia, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 7 of 7 Attachment A Photo Log Site Name: RMP Inspection Eugene Welders Supply dba Industrial Source City, State: Springfield, OR Photographer: Robert Faries, Weston Solutions File Photo1.jpg Photo2.jpg Photo3.jpg Photo4.jpg Photo5.jpg Photo6.jpg Photo7.jpg Photo8.jpg Photo9.jpg Photo10.jpg Photo11.jpg Photo12.jpg Photo13.jpg Photo14.jpg Photo15.jpg Photo16.jpg Photo17.jpg Photo18.jpg Photo19.jpg Photo20.jpg Photo Layout ID Date 1 2/7/2024 2 2/7/2024 3 2/7/2024 4 2/7/2024 5 2/7/2024 6 2/7/2024 7 2/7/2024 8 2/7/2024 9 2/7/2024 10 2/7/2024 11 2/7/2024 12 2/7/2024 13 2/7/2024 14 2/7/2024 15 2/7/2024 16 2/7/2024 17 2/7/2024 18 2/7/2024 19 2/7/2024 20 2/7/2024 Time 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours 0920 1200 hours Description Overview including three 12,000 gallon bulk product tanks, one 1,000 lb dump tank, one 1,000 lb industrial propane tank, safety bollards, a wall separating the hydrocarbon filling area from the neighboring property, emergency shutoff, and empty tanks. Location in Facility: Hydrocarbon filling area. Emergency shutoff switch on the Northwest side of the property. Location in Facility: Hydrocarbon filling area. Butane filling bulkheads. Liquid and vapor lines. Location in Facility: Hydrocarbon filling area. Propane filling bulkheads. Liquid and vapor lines. Location in Facility: Hydrocarbon filling area. Isobutane filling bulkheads. Liquid and vapor lines. Location in Facility: Hydrocarbon filling area. Propane tank certification. Location in Facility: Hydrocarbon filling area. Isobutane tank certification. Location in Facility: Hydrocarbon filling area. Butane tank certification. Location in Facility: Hydrocarbon filling area. Eugene Springfield Fire Department required the facility to build a wall due to the hydrocarbon filling areas proximity to the neighboring property. Location in Facility: Hydrocarbon filling area. Propane, butane, and isobutane filling stations. Pig tail connects empty customer tanks to the lines to be filled. Location in Facility: Hydrocarbon filling area. Unlabeled propane, butane, and isobutane filling pipes. Location in Facility: Hydrocarbon filling area. Unlabeled propane, butane, and isobutane filling pipes. Location in Facility: Hydrocarbon filling area. Isobutane tank volume gauge. Location in Facility: Hydrocarbon filling area. Butane tank volume gauge. Location in Facility: Hydrocarbon filling area. Propane tank volume gauge. Location in Facility: Hydrocarbon filling area. Vacuum station. Customers returned gas cylinders are emptied into the dump tank and residual vapors are vacuumed out. Location in Facility: Hydrocarbon filling area. Facilitys industrial propane tank and dump tank. Customers cylinders are emptied into the dump tank. The contents of the dump tank are run to the flare. Location in Facility: Hydrocarbon filling area. Flare stack on the roof. Location in Facility: Hydrocarbon filling area. 6,000 gallon CO2 Tank. [not RMP] Location in Facility: Hydrocarbon filling area. 6,000 gallon oxygen tank. [not RMP] Location in Facility: Hydrocarbon filling area.