Document xz1gVKoJeQwEL1rOzQ4Bjez7g

UNITED STATES UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 ENVIRONMENTAL 1200 Sixth Avenue, Suite 155 Seattle, WA 98101ENFORCEMENT & PROTECTIONCOMPLIANCE ASSURADINVISICON E Clean Air Act - Section 112 (r) Risk Management Program and EPCRA 312 - - Tier II Facility Inspection Report FACILITY INFORMATION: Company Name:High Purity Products, Inc. Facility Name:Front Avenue Physical Address:5740 NW Front Avenue Portland, OR 97210 Phone Number:503-548-6355 Latitude / Longitude: (45.56430, -122.516788) RMP Facility ID #1000 0023 9397 FRS ID #: EJ Concerns:Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name:Andrew Demos EH & S Specialist Phone Number:925-788-7745 E-mail:andrewd@highpp.com EMERGENCY CONTACT INFORMATION: Name:Logan Rounsevelle Phone (24-hr):503-548-6355 E-mail:logan@highpp.com Website:highpurityproducts.com TRIP DETAILS: Inspection Date:March 17, 2023 Inspection Time:09:00 through 12:15 EPA Inspection Team: Edward Johannes, US EPA Region 10 SEE Grantee, Lead RMP Inspector / EPCRA Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Mhara Coffman, US EPA Region 10, RMP Inspector Taylor Law, Weston Solutions, Inc., EPA START Contractor May 26, 2023Page 1 of 5 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date:November 29, 2022 Date of Latest Update:November 29, 2022 Process (Program 1, 2, 3) as reported in RMP: NAICS Progr ProcessChemical Name Process ID DescriptionCodeamQuantity (lbs) Chemical IDCAS Number Level 110,000 (37% Hydrochloric acid 1000104726 Storage / Shipping 1000131199 325998 2concentration or (7647-01-0) greater) 166,000 (20% Ammonia, Aqueous 1000104726 Storage / Shipping 1000160522 325998 2concentration or (7664-41-7) greater) 24,800 (37% hydrochloric acid 1000128041 Repacking1000160553 325998 2concentration or (7647-01-0) greater) 21,000 (20% Ammonia, Aqueous 1000128041 Repacking1000160554 325998 2concentration or (7664-41-7) greater) 24,825 (37% Hydrochloric acid 1000128042 Bulk Transferring 1000160555 325998 2concentration or (7647-01-0) greater) 21,000 (20% Ammonia, Aqueous 1000128042 Bulk Transferring 1000160556 325998 2concentration or (7664-41-7) greater) 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:NoYes If Yes, Date of Last Inspection: None The facility is High Risk:NoYes Joint EPCRA inspection:NoYes CAA Title V Air Permit: Does the facility have a CAA Title V Permit?NoYes If Yes, Permit Number: RELEASE / ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years?NoYes If Yes, Date and Description of the Release: EPCRA TIER II REPORTING: Did the facility submit the [Enter Year] Tier II report to the SERC?NoYes If Yes, Date the Tier II was submitted:2-14-2023 If No, calendar year of the most recent Tier II: Page 2 of 5 Did the facility submit a Tier II to the LEPC and local fire department? NoYes If Yes, Date the Tier II was submitted:2-14-23 INSPECTION ENTRY: The EPA Inspection Team (EPA) led by Mr. Edward Johannes arrived at the premises of High Purity Products, Inc. Front Avenue facility (facility) in Portland, Oregon, at 08:45 and was joined by the following facility personnel: NameTitle, Organization Andrew DemosEH & S Specialist - High Purity Products (HPP) Bhaskar ChoudhuryPresident - HPP Logan RounsevelleProduction Manager - HPP Daniel WilliamsDirector of Quality - HPP David MarsolekDirector of Production - HPP Paul SmithLab Manager - HPP Was a state / county / or local emergency representative present?NoYes If Yes, Name and Title of Representative: Bryan Profit The facility is a first responder:NoYes If No, Responding Agency: Portland Fire Department Facility representatives escorted EPA to the facility's office / conference room. Lead Inspector Edward Johannes 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. Mr. Andrew Demos EH & S Specialist of HPP 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 on February 27, 2023, 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. A corrected second notice was sent out on March 14, 2023, informing the facility that the inspection was for Program Level 2 requirements, not for Program Level 3 requirements as was stated in the original notice. The facility is unionized:NoYes If Yes, Name of Union: An employee representative present during the facility visit:NoYes If Yes, Name / Title: Mr. Andrew Demos EH & S Specialist Page 3 of 5 GENERAL INFORMATION: The facility is regulated under RMP rule a Program Level 2 facility and is owned and operated by High Purity Products, Inc. (HHP) whose parent company is Cascade Columbia Distribution. Operations at the facility began in 2003. HPP is a full line supplier of the highest purity acids, bases, solvents, and etchants used for semiconductor applications. The facility receives ISO tank containers (ISOtainers) of bulk product, which it repackages to into gallon bottles, pails, carboys, drums, and totes for the semiconductor industry. The ISOtainers are offloaded at a dock, where the bulk product is repackaged after going through a filtration transfer system. The facility stores the bottles of repackaged product in specified storage rooms inside the main facility building. HHP has 18 full - time employees on site, 14 of whom are trained as Operators. ON-SITE OBSERVATIONS: EPA toured the facility from approximately 0930 hours to 1015 hours, escorted by facility representatives Mr. Andrew Demos, Mr. Bhaskar Choudhury, Mr. Logan Rounsevelle, Mr. Daniel Williams, Mr. David Marsolek, and Mr. Paul Smith. EPA observed the covered chemical storage facility process and repackaging of product for the semiconductor industry. Photographs taken during the inspection are included in Attachment A to this report. EPA observed operations in the Clean Room Lab and Shipping / Receiving Area, which comprise the majority of the facility interior. The Clean Room Lab serves as a lab and staging area for chemical repackaging (Photo 1) and is adjacent to the Shipping / Receiving Area. The facility receives bulk chemical product from delivery trucks in the Shipping / Receiving Area (Photos 2 and 3). EPA observed a filtration system dedicated to processing ammonium hydroxide between the receiving doors (Photos 4 and 5), hydrochloric acid (HCL) repackaging operations in the Clean Room Lab (Photos 6 and 8). Process safety practices observed in the Clean Room Lab and Shipping / Receiving Area include an eyewash station and hazard communication signage posted on the access door leading to the Scrubber Room (Photos 9 and 10). EPA observed exhaust system components housed in the Scrubber Room, including a dual unit exhaust system, ventilation pipe, control panels, pumps, and compressors (Photos 11-20). EPA observed exterior areas of the facility, including a parking / storage area for ISOtainers (Photos 21- 25), and nitrogen storage tank (Photos 26 and 27). Storage rooms in the facility interior provide separate, dedicated storage areas for a variety of chemicals including ammonia, HCL, flammable products, and corrosives. EPA observed the Flammables and Corrosives Rooms which included fire extinguishers, emergency shower / eyewash stations, and hazcom signage (Photos 28-36). After touring the RMP-covered process areas at the facility, EPA returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Mr. Andrew Demos, Mr. Bhaskar Choudhury, Mr. Logan Rounsevelle, Mr. Daniel Williams, Mr. David Marsolek, and Mr. Paul Smith. Page 4 of 5 INFORMATION COLLECTED FROM FACILITY: 1. Safety Data Sheet for Ammonium Hydroxide 2. Safety Data Sheet for Hydrochloric Acid 3. List of Trained of Employees for Container Drum disposal process 4. Example of empty container disposition training quiz 5. Facility Compliance and Audit Report package 6. Visitor Conduct Guide 7. Copy of Emergency Response Plan package with Site Figures AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: No areas of concern were identified during the inspection. DOCUMENTS REQUESTED NOT INCLUDED IN 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. During the inspection, no follow - up document requests were made requiring further review. INSPECTION REPORT CERTIFICATION: This is to certify that I, Edward Johannes, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: EDWARD JOHANNES Digitally signed by EDWARD JOHANNES (Affiliate) (Affiliate)Date: 2023.07.07 13:14:33 -07'00 ' Inspector Signature Digitally signed by JAVIER JAVIER MORALES MORALES Date: 2023.07.10 11:08:19 -07'00 ' RMP Coordinator / Approval Digitally signed by ERIN ERIN WILLIAMS WILLIAMS Date: 2023.07.12 15: 07: 50-07'00 ' EPCRA Coordinator / Approval MATTHEWDigitally signed by MATTHEW QUARTERMAN QUARTERMANDate: 2023.07.17 15:25:19 -07'00 ' Land Enforcement Section Chief / Approval Page 5 of 5 Attachment A-Photo Log Site Name: Front Ave RMP Inspection City, State: Portland, Oregon Photographer: Taylor Law File Photo Layout ID Date Time 1 1.jpg 3/17/2023 09:41 am 2 2.jpg 3/17/2023 09:41 am 3 3.jpg 3/17/2023 09:41 am 4 4.jpg 3/17/2023 09:43 am 5 5.jpg 3/17/2023 09:46 am 6 6.jpg 3/17/2023 09:47 am 7 7.jpg 3/17/2023 09:50 am 8 8.jpg 3/17/2023 09:50 am 9 9.jpg 3/17/2023 09:50 am 10 10.jpg 3/17/2023 09:50 am 11 11.jpg 3/17/2023 09:50 am 12 12.jpg 3/17/2023 09:50 am 13 13.jpg 3/17/2023 09:51 am 14 14.jpg 3/17/2023 09:51 am 15 15.jpg 3/17/2023 09:51 am 16 16.jpg 3/17/2023 09:52 am 17 17.jpg 3/17/2023 09:52 am 18 18.jpg 3/17/2023 09:52 am 19 19.jpg 3/17/2023 09:53 am 20 20.jpg 3/17/2023 09:53 am 21 21.jpg 3/17/2023 09:55 am 22 22.jpg 3/17/2023 09:55 am 23 23.jpg 3/17/2023 09:55 am 24 24.jpg 3/17/2023 09:56 am 25 25.jpg 3/17/2023 09:58 am 26 26.jpg 3/17/2023 09:58 am 27 27.jpg 3/17/2023 09:58 am 28 28.jpg 3/17/2023 09:59 am 29 29.jpg 3/17/2023 10:00 am 30 30.jpg 3/17/2023 10:00 am 31 31.jpg 3/17/2023 10:00 am 32 32.jpg 3/17/2023 10:00 am 33 33.jpg 3/17/2023 10:00 am 34 34.jpg 3/17/2023 10:01 am 35 35.jpg 3/17/2023 10:02 am 36 36.jpg 3/17/2023 10:03 am Description Overview of Clean Room, Lab, and Staging / Receiving area. Overview of Dock / Shipping receiving down - downpack area with Ammonium Hydroxide transfer system. Exit doorway adjacent to Docks / Shipping receiving area. Ammonium Hydroxide transfer and filtration system. Ammonium Hydroxide transfer and filtration system. Clean Room Lab, HCL downpack operations Clean Room Lab, HCL downpack operations Clean Room Lab, HCL downpack operations Clean Room Lab, eyewash station adjacent to scrubber / exhaust system Shipping / Receiving Area, hazard communication (hazcom) signage at access door to Scrubber Room Scrubber Room, dual unit exhaust system Scrubber Room, dual unit exhaust system Scrubber Room, ceiling mounted pipe ventilation of the dual unit exhaust system Scrubber Room, overview Scrubber Room, overview Scrubber Room, exhaust system control panel with calibration information Scrubber Room, exhaust system piping and pumps Scrubber Room, overview of exhaust system manufacturer label Scrubber Room, exhaust system control panel with calibration information Scrubber Room, air compressors for the exhaust system Facility Exterior, ISOtainer receiving area Facility Exterior, ISOtainer receiving area adjacent to the Willamette River Facility Exterior, ISOtainer receiving area Facility Exterior, ISOtainer receiving area Facility Exterior, ISOtainer receiving area Facility Exterior, nitrogen storage tank Facility Exterior, nitrogen storage tank Fire extinguisher overview near facility exterior exit. Clean Lab Room, view of Flammable Room access door with fire extinguisher and hazcom signage Flammables Room, chemical storage Flammables Room, chemical storage Flammables Room, chemical storage Clean Room Lab, access door to Corrosives Storage Room with fire extinguisher, eyewash / shower, and hazcom signage Corrosives Room, overview of chemical storage Corrosives Room, overview of chemical storage Corrosives Room, overview of chemical storage