Document zdqZaEDMy19g1ewgg7jY4mY0n

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Harcros Chemicals Inc. - Muscle Shoals Muscle Shoals, Alabama August 21, 2024 1.0 Introduction The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA. The focus of this inspection was to assess the RMP for the chemical storage and distribution process at the Harcros Chemicals Inc. - Muscle Shoals (Harcros) facility located in Muscle Shoals, Colbert County, Alabama. This facility was selected for inspection because it hadn't been inspected in over five years. The inspection, which was conducted on August 21, 2024, consisted of an examination of program documentation as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Requested program documents were provided for further review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Harcros facility is located in Muscle Shoals, Alabama. The facility stores and distributes various chemicals. Chlorine cylinders are emptied, inspected, cleaned, and repainted before being filled with more chlorine. The chlorine arrives by railcar and there are at least two cars onsite, any given day. The facility also stores and distributes sulfur dioxide; however, there is no repackaging involved in the process. Both processes are regulated as program level 3. According to facility records, the facility has a maximum of 1,528,000 pounds of chlorine and a maximum of 70,000 pounds of sulfur dioxide on site. The chemical distribution process at the facility is subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1. TABLE 1: Inspection Information Summary Inspection Team Lead Inspector: Jordan Noles, EPA Inspector-in-Training: Callie Sotolongo, EPA Date of Facility Visit: August 21, 2024 Facility Identification Name: Harcros Chemicals Inc. - Muscle Shoals Street Address: 300 Pepi Drive City: Muscle Shoals County: Colbert EPA Facility ID No: 1000 0001 1505 Dun & Bradstreet (D&B) No: 194128765 Latitude: 34.76704 Longitude: -087.61854 State: Alabama Zip: 35662 Name, address and phone of corporate parent company: Owner/Operator: Harcros Chemicals Inc. Mailing Address: 5200 Speaker Rd. City: Kansas City Phone: (913) 321-3131 State: Missouri Zip: 66106 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Ryan Doyle Title: Dir. Eng. & Env. Phone: (816) 813-4799 Email: ryan.doyle@harcros.com Name and title of emergency contact: Name: Chris Liles Title: Operations Manager Day phone: (256) 381-2420 24-hour Phone: (256) 412-4549 Email: chris.liles@harcros.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Ryan Doyle Title: Dir. Eng. & Env. Phone: (816) 813-4799 Email: ryan.doyle@harcros.com Name: Gabriel Valencia Title: Compliance Manager Phone: (216) 644-8195 Email: gabriel.valencia@harcros.com Page 2 of 5 Harcros Chemicals Inc, Muscle Shoals, AL CAA 112 (r), Risk Management Program, Inspection Report Name: Julie Hirner Title: Compliance Manager Phone: (660) 287-5298 Email: jhirner@harcros.com Name: Chris Liles Title: Ops. Manager Phone: (256) 412-4549 Email: cliles@harcros.com Name: Madison Futch Title: Not given Phone: Not given Email: mfutch@Harcros.com Name: Scott Nesbilt Title: District Manager Phone: (256) 606-8622 Email: scott.nesbilt@harcros.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: May 21, 1999 Date of most recent submissions: February 06, 2023 Process: Chemical Storage & Distribution (Chlorine & SO2) Process ID: 1000129511 Program Level as reported in RMP: 3 NAICS code: 42469 (Other Chemical and Allied Products Merchant Wholesalers) 3.0 Observations The inspection of the Harcros facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 3) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection included an opening conference where EPA inspectors reviewed documents associated with the facility's Risk Management Plan. The discussion was followed by a tour of the facility's chemical storage areas. An inspection out-brief was conducted where EPA inspectors requested additional documents for review off-site and described their observations. Observations from the RMP inspection at the Harcros facility are discussed below: 1. 40 C.F.R. 68.67(e) requires the owner or operator to establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what Page 3 of 5 Harcros Chemicals Inc, Muscle Shoals, AL CAA 112 (r), Risk Management Program, Inspection Report actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; and communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. The 2018 process hazard analysis (PHA) identified 28 action items. Three of the action items had due dates in 2018 but were not completed until 2020. The 2023 PHA identified five action items that were all completed; however, there were no due dates as part of the action item tracking page. Section 11.0 "Recommendation Closure" of the PHA states, "All recommendations are addressed in a timely manner by assigning a predicted date for the closure for each recommendation." 2. 40 C.F.R. 68.69(c) requires the operating procedures to be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. The owner or operator shall certify annually that these operating procedures are current and accurate. The inspection team requested documentation of the standard operating procedures (SOP) review and certification for the last three years. Facility representatives provided three documents showing that the SOPs have been reviewed and certified for the last three years. However, the SOPs were not reviewed for 2024 until the "Notification of Inspection" email sent August 7, 2024, a year and six months after they were previously reviewed and certified. 3. 40 C.F.R. 68.73(d)(2) requires inspections and testing procedures to follow recognized and generally accepted good engineering practices. The facility utilizes a chart to document the inspections and tests performed on the process equipment. Under the "Controllers/Sensor" section, it states chlorine sensors are required to be calibrated every six months. The last calibration of the chlorine sensors was on February 15, 2024, more than six months before the RMP inspection took place. Page 4 of 5 Harcros Chemicals Inc, Muscle Shoals, AL CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, JORDAN Digitally signed by JORDAN NOLES Date: 2024.10.21 _N_O__L_E_S_______1_3:_40_:4_2 -_04_'0_0'________ Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 Approved by: JASON Digitally signed by JASON DRESSLER Date: 2024.10.21 _D_R_E__S_S__L_E_R___1_2:_34_:4_9 -_04_'0_0'________ Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4 Page 5 of 5 Harcros Chemicals Inc, Muscle Shoals, AL CAA 112 (r), Risk Management Program, Inspection Report