Complaint ID 91046 — Public Copy

After reviewing the information provided, EPD has concluded because the release was from a spent drum, the facility knew there was less than 10lbs of Ethylene Oxide at the time of the 7-31-2019 release. 10 lbs is the reportable quantity threshold for Ethylene Oxide. Therefore, there is no violation of O.C.G.A. 12-14-3 in regards to the 7-31-2019 release. In addition, EPD requested data regarding the past five years releases, regardless of the amount. EPD has concluded that all of the additional releases either were previously addressed by EPD (4-2-2018 and 7-10-2018) or were immediately determined by the facility to be less than the reportable quantity threshold. Accordingly the previously unreported releases on 2-3-2015, 11-11-2015, 11-17-2015, 1-31-2017, 6-11-2017, 7-17-2018 and 4-10-2019 were not required to be reported to EPD in accordance with O.C.G.A. 12-14-3. Going forward, EPD has requested that the facility send us monthly reports of all known releases, including those below the reportable quantity threshold. The facility has agreed to do so. I have shared all information regarding this investigation with EPD's Air Protection Branch for their review as they develop the draft amendment to the permit. I am closing this investigation on behalf of ERT.

I received an email from Kathleen Hoffman with additional information. See email from Thursday, September 26, 2019 at 6:11 pm.

I spoke with Kathleen Hoffman to follow up on the information I requested. She informed me that she would be sending me the information I requested a little later in the afternoon.

I spoke with Kathleen Hoffman. I asked her how far along they were with getting the information for me. She informed me that they were finishing up their draft and sending it to their legal team for review this afternoon.

I spoke with Kathleen Hoffman. I informed her that I needed more detailed information on how they calculated the releases that they estimated.

I received an email from Kathleen Hoffman with additional information. See email from Wednesday, September 18, 2019 at 6:34 pm.

I spoke with Kathleen Hoffman. She informed me that she would be sending me the information I requested a little later in the afternoon.

I sent an email to Kathleen Hoffman requesting additional information. See the attached email from Thursday, September 12, 2019 at 3:03 pm for details.

I received an email from Kathleen Hoffman with additional information. See email from Thursday, September 5, 2019 2:59 pm.

I received an email from Kathleen Hoffman with the information I requested earlier that morning. See the email from Tuesday, September 3, 2019 at 5:42 pm for details.

I sent an email to Kathleen Hoffman requesting additional information. See the attached email from Tuesday, September 3, 2019 at 3:26 pm for details.

I received a response from Kathleen Hoffman regarding my request. See the attached email from September 3, 2019 at 12:31 pm for details.

I sent an email to Kathleen Hoffman requesting additional information. See the attached email from Tuesday, September 3, 2019 at 8:22 am for details.

I received a follow up email from Kathleen Hoffman with the rest of the information I requested. See the attached email from Friday August 30, 2019 at 6:16 pm for details.

I received an email from Kathleen Hoffman with part of the requested information. This included documentation that the spent drum that caused the release on 7-31-2019 had 9.3 lbs of Ethylene Oxide left in it before the release occurred. See the attached email from Friday, August 30, 2019 at 12:29 pm for details.

I spoke with Kathleen Hoffman. She informed me that she sent me part of the information I requested and that she would try to have me the rest of it by that afternoon.

I spoke with Kathy Hoffman, Senior Vice President - Global Environmental, Heath & Safety and Technical Services. I asked her to provide me with a list of the last five years releases at the facility along with incident reports for each one. I also asked her to provide me with a timeline for the events surrounding the 7-31-2019 release of Ethylene Oxide.

I (James Cooley, EPD) received an email from Daryl Mosby with an attachment of the complete email that prompted the investigation. See the attached email from Wednesday, August 28, 2019 at 4:07 pm for details.

EPD conducted an on site investigation of the potential incident. See the attached inspection report for details.

Upon receiving the email from Ms. Lutz, EPD initiated an investigation of the potential incident. See the attached email from Tuesday, August 27, 2019 at 2:45 pm.