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0" EPAU~..'"";"s:..-t.". Ptolt.on
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
9/11-13/2017 Clean Air Act RMP
Company Name: Facility Na me: Facility Physical Location:
{city, state, zip code) Mailing address:
{city, state, zip code) Count y/Parish: Facility Contact:
Woodward Iodine Corporation Woodward Iodine Corporation 205865 East County Road 32 Woodward, Oklahoma 73801 205865 East County Road 32 Woodward, Oklahoma 73801 Woodward Terry Davis t davis@cneconnect.com
FRS Number: Identification/Permit Number: RMP: NAICS: SIC:
110007386818 4015300017 1000054542 32519 2819
Personnel participating in inspection:
Terry K. Davis
Woodward Iodine Corporation
Alvin Leroy Goodman
Woodward Iodine Corporation
Greg Mitchell
Woodward Iodine Corporation
BJ Williams
Woodward Iodine Corporation
Russell Compston
Woodwa rd Iodine Corporation
Marie Stucky
EPA Region 6
I Executive Vice President
Executive Vice President President & CEO Vice President Administrative Manager Safety Manager Inspector
EPA Lead Inspect or Signature/Date
Supervisor Signature/Date
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Marie Stuc~ ~ )
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Samue l Tates
l \/ 2-t:f. /17
Date
II /l 'i/Zol?
Date
6ENFORM-019-R7 (2/15/2017)
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Section I- INTRODUCTION
Woodward Iodine Corporation Inspection Date {9/11-13/17}
PURPOSE OF THE INSPECTION
I, EPA Region 6 inspector Marie Stucky, arrived at the Woodward Iodine Corporation (Woodwa rd) around 1:30PM on September 11, 2017, for an announced inspection. I met with Terry K. Davis (Executive Vice President), Alvin Leroy Goodman (President & CEO), Greg Mit chell (Vice President), BJ Williams (Administrative Manager), and Russell Compston (Safety Manager). I present ed my credentials and informed them that this was an EPA inspection to determine compliance with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions at 40 CFR Part 68. The scope of the inspection was a partial com pliance evaluation (PCE) and includes evaluation of the facility's compliance with CAA 112(r) and 40 CFR Part 68 . On September 1, 2017, Woodward received an announcement email from me, which outlined the directions for conducting the inspection on September 11-13, 2017 . The email also contained a list of documents for Woodward to gather for review during t he inspect ion. Woodward is not a union facility.
FACILITY DESCRIPTION
Woodward Iodine Corporation operates an iodine manufacturing facility at 205865 East County Road 32 in Woodward, Oklahoma. Woodward began operations in September 1976 and was purchased in 1984 by the current owner. According to the facility's Risk Management Plan (RMP), the facility has 25 full time employees onsite and is covered by OSHA PSM and a Clean Air Act Title V Air Perm it. Onsite, the facility has Sulfur Dioxide, Anhydrous Ammonia, and Chlorine, which are RMP covered chemicals over the threshold quantity.
Section II- OBSERVATIONS
On September 12, 2017, I was accompanied by Woodward staff on a walk-through of the facility to observe the covered process, equipment, and operations. The facility explained the iodine process from entering to leaving the faci lity. I also observed tanks, pipes, fire hoses, SCBA, and other safety equipment throughout the facility.
40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS
Subpart A- General 40 C.F.R. 68.10 Applicability -I observed that Woodward is a stationary source that has an Air Operating Permit and more tha n a threshold quantity of a regulated substances in a process; therefore, these regulations are applicable. Woodward su bmitted a Risk Management Plan (RMP) that describes the process containing the toxic chemicals held at more t han a threshold quantity. The process is Program three due to the fact that the facility is subject to OSHA's Process Safety Management Standard (29 CFR 1910.119), and is a chemical manufacturing NAICS Code 32519.
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