Document wD6g3eZNYqe2904aBwJV4ow94

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Ms. Lori Leffler Vice President Health Environmental Safety Sustainability KIK Custom Products - Biolab 1700 Old Covington Highway SW Conyers, Georgia 30012 LLeffler@kikcorp.com Dear Ms. Leffler: Enclosed is a copy of the final Inspection Report (Enclosure A) generated by the U. S. Environmental Protection Agency's Region 4 Air Enforcement Branch for the partial compliance inspection of KIK Custom Products - Biolab located at 1700 Old Covington Highway SW, Conyers, Georgia 30012. The EPA previously sent a copy of the draft inspection report in an email on December 14, 2021, allowing KIK Custom Products - Biolab to make any comments on the report and to claim any information contained in the report as confidential business information (CBI). In an email dated December 16, 2021, KIK Custom Products - Biolab notified EPA that certain information was being claimed as CBI. Those items have omitted from the final report. Should you have any questions regarding this inspection report, please contact me at (404) 562-9198, or by email at Warrilow.Phyllis@epa.gov. Enclosure Sincerely, PHYLLIS WARRILOW Digitally signed by PHYLLIS WARRILOW Date: 2022.01.11 12:16:01 -05'00' Phyllis Warrilow, PE Environmental Engineer South Air Enforcement Section ENCLOSURE A INSPECTION REPORT United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch I. GENERAL INFORMATION Facility Name: KIK Custom Products - Biolab Location (Address): 1700 Old Covington Highway SW, Conyers, Georgia Inspection Date: November 15, 2021 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation focused on the Clean Air Act Section 112 (r)(1) General Duty Clause requirements. ICIS-Air Number: GA0000001324700009 EPA Region 4 Investigator(s)/Inspector(s): 1. Phyllis Warrilow PE, Environmental Engineer 2. Carrie Griffith, Environmental Engineer State/Local Investigator(s)/Inspector(s): 1. Christina Jagonase, Georgia Environmental Protection Division Person(s) Contacted at Facility (Name and Title): 1. Tom Wideman, Director Health Environmental Safety and Sustainability (HESS) 2. Brian Cobb, HESS Specialist 3. Lori Leffler, Vice President HESS Report Prepared by: Phyllis Warrilow, PE Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 13 II. FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). KIK Custom Products Biolab is classified under NAICS code 325180 (Other Basic Inorganic Chemical Manufacturing). Permit No. 2842 247-00009-S-03-0, Synthetic Minor 3. Air permit issuance date. Issued January 4, 2018, Amended Sept. 18, 2018 4. Air permit expiration date. September 18, 2022 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). Synthetic Minor N/A CAA 112 (r)(1) General Duty Clause N/A N/A B. Process Description KIK Custom Products Biolab (Biolab) is classified under NAICS code 325180 (Other Basic Inorganic Chemical Manufacturing). Biolab operates a Swimming Pool Chemicals Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 13 blending facility where large quantities of chlorine-based oxidizers are reformulated and stored. The facility covers approximately 56 acres of land and includes several office buildings, maintenance buildings and warehouses. Biolab operates two shifts a morning shift and an afternoon/evening shift. In peak season such as summer, the facility sometimes operates three shifts. The facility is typically unmanned except for security guards in the overnight hours. The facility was purchased by KIK Custom Products from Chemtura in 2014. III. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. Yes No NA Y 2. Credentials presented to facility Y personnel (include name and title). Comments EPA Region 4 (R4) inspectors arrived at the Facility on November 15, 2021 at 9:25 AM EST. All inspectors presented their credentials to Tom Wideman, Director HESS; Brian Cobb, HESS Specialist; Credentials were presented to Lori Leffler, VP HESS after she arrived at the meeting. 3. Conducted an opening meeting Y to explain the purpose and objectives of the inspection. 4. Discussed safety issues. Y Inspectors held an opening conference on November 15, 2021 at 9:37 AM EST during which the purpose and objectives of the inspection were explained. Lori Leffler joined via telephone as she was in route to the meeting. Inspectors discussed Facility-specific safety and emergency procedures, including procedures for COVID-19 safety during the inspection. Tom Wideman, Director HESS, advised of safety requirements for the site. Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 13 Activity 5. Discussed which records to be reviewed. Yes No NA Y 6. Discussed the facility walk- Y through and the areas to be observed in the facility. 7. Discussed facility policy Y regarding photographs or video (if applicable). 8. Discussed the use of the N/A infrared camera, TVA, PID, and any other equipment. 9. Discussed CBI. Y Records Reviewed at the Facility 10. The types of records reviewed, Y and the time period reviewed. Facility Walk-Through Observations Comments EPA inspectors requested to review the details of the September 14, 2020, incident and current inventory records indicating quantities of chemicals stored in the location of the September 14, 2020, incident. EPA inspectors also asked for the facility to discuss the Emergency response and operational situation leading up to the September 14, 2020, incident. Inspectors were interested in the storage areas where the September 14, 2020, incident took place. EPA inspectors indicated that digital photographs may be taken during the walkthrough. See Appendix A - Photograph Log. Region 4 inspectors did not use an infrared camera, TVA, or other equipment. EPA inspectors indicated that any documents claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. Inventory records requested at the time of the inspection were sent to EPA as a follow-up. Other documents requested from the Facility via email communication were Emergency Response Procedures and written hazard assessments for those chemicals that could decompose and release Chlorine or generate Nitrogen Trichloride. Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 13 11. The process equipment N/A observed and the associated operational rate observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 13 The EPA Region 4 inspectors focus for the inspection was the location of the September 14, 2020, chemical decomposition incident. The building is situated adjacent to Interstate 20 in an industrial setting and is used for dry blending and warehouse offices. The warehouse building was commissioned in 1977. The building is a one-story structure. At the time of the inspection, the facility was storing the same type of chemicals as had been stored during the September 14, 2020, incident. Super sacks of chemicals were lined up parallel to each other waiting to be reformulated into product. A previously removed domestic water (restroom) area had been located within the same open warehouse as the chemicals and had been located approximately 25 to 30 feet away from the super sacks. EPA requested the November 15, 2021, inventory for the warehouse. Biolab emailed the inventory list to EPA inspectors after the inspection. Inspectors were told that the quantity of chemicals observed during the inspection was much lower than in the summer months as demand for the chemicals is seasonal. EPA Inspectors asked Biolab officials to recall and walk through the situation of the September 14, 2020, incident. Biolab officials told Inspectors that on the day of the incident, employees arrived for the morning shift and found water on the floor. Biolab continued to state that maintenance crews had been called right away that morning, however water had mixed with the Activity Yes Comments No NA dry chemicals such that employees were quickly overwhelmed, and thus evacuated. The fire department was then called. The National Response Center was notified and DOT officials shutdown the adjacent roads including Interstate 20 until midafternoon on that day. The Inspectors were told that the building had been mostly gutted due to severe corrosion generated during the incident. The company stated that it was still in the process of rebuilding certain parts of the building. Inspectors observed that the bathroom (domestic water) equipment where the water leak originated was completely removed. The space previously housing the leaky domestic water line piping was empty. Blank walls remained. One wall still had yellowish paint from the restroom area. There was one perpendicular partial wall in the building which was the back wall of the domestic water area. Inspectors were told that water had possibly collected along this wall. Inspectors were told that drills with the fire department were conducted biannually but previously had been conducted quarterly. Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 13 Activity 12. The type of process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 13. If process equipment or N/A parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Comments Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 13 Activity 14. The type of air pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.). Yes No NA N/A (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 13 Activity 15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. If air pollution control N/A equipment was not operating, state the reason by facility personnel why the equipment was not operating. Comments The facility operates portable Chlorine detectors. During the inspection, EPA inspectors asked if the facility had plans to incorporate permanent fixed Chlorine detectors in the building which was involved in the September 14, 2020, chemical decomposition incident. Biolab responded that permanent fixed Chlorine detectors would be included as part of their rebuild. 17. Capture and collection system N/A (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 13 Activity 18. Ductwork transferring the emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). Yes No NA N/A 19. Any existing unpermitted N/A emission points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 20. Were any visible emissions N/A observed? (if yes, identify the location and equipment). 21. Was a Method 9 reading N/A performed? (if yes, identify the location and equipment). 22. Was the cause of the visible N/A emissions investigated and the information documented? Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 13 Comments Activity 23. Was a Method 22 performed for visible emissions? (if yes, identify the location and equipment). Yes No NA N/A 24. Identify the cause of the visible N/A emissions as explained by facility personnel, if applicable. 25. Was the infrared camera used? N If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. 26. Was the TVA used? If so, N identify the equipment monitored and the results. Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 13 Comments Activity 27. Was the PID used? If so, identify how the PID was used and the results. Yes No NA N Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Closing Meeting 28. Conducted a closing meeting. Y 29. Summarize any additional Y information needed, if applicable? 30. Accept a declaration of CBI, if N/A applicable? 31. Discussed observations. Y Comments The closing conference was conducted on November 15, 2021, at 11:50 AM EST. Attendees were the same as were present for the opening meeting. Facility personnel agreed to send additional documents to EPA. See Appendix A. Inspectors thanked Facility personnel for their time. Inspectors observed that the bathroom (domestic water) equipment where the water leak originated was completely removed thus the source of the water which reacted with the stored chemicals on September 14, 2020, was eliminated. Inspectors were told that drills with the fire department were conducted biannually but previously had been conducted quarterly. Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 13 Activity 32. Discussed next steps, if applicable? 33. Date and time inspection concluded. Yes No NA Y Comments A final inspection report from EPA Region 4 will be sent to the company within a 60day timeframe. Document requests were discussed (see Appendix A.2). The inspection concluded with a closing conference at 12:05 AM EST on November 15, 2021. Miscellaneous 34. Include any additional N/A observations, if applicable. Digitally signed by PHYLLIS EPA Investigator/Inspector Signature:__P_H__Y_L__L_IS__W__A__R_R_I_L_O__W___W_A_R_R_IL_O_W_____ Date: 2022.01.11 12:17:17 -05'00' Digitally signed by TODD TODD GROENDYKE GROENDYKE EPA Supervisor Signature & Title ___________________D_a_te_: 2_02_2_.01_.1_1_13_:3_3:_41_-0_5_'0_0' ___________________________________ Date Report Finalized:___________________________________ Project Name: KIK Custom Products - Biolab Conyers ICIS/Project No.: GA0000001324700009-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 13 APPENDICES AND ATTACHMENTS Appendix A. 1. Photograph Log Photograph Log KIK Custom Products - Biolab November 15, 2021 Image Number File Name Date Time (EDT) Description 128- 11/15/2 Approx. 11:30 Yellow area of wall where break room was 1 1114.JPG 021 AM located 128- 11/15/2 Approx. 11:30 Partition separating break room area from 2 1115.JPG 021 AM product storage All photographs were taken by EPA inspector Carrie Griffith. Appendix A. 2. Document Receipt Log Documents were not obtained from Facility representatives during the on-site inspection but were emailed as a follow-up: 1) Plant 6 Inventory list 11 15 21.xlsb. 2) SOP-EHS-03-05 Consolidated Emergency Response Plan. 3) Storage and Handling of ACL Chlorinating Compositions.