Document 0m0oNDGD1B4MJMKp4zB2wrZm

CLEAN AIR ACT (CAA) 112(r)(1) & EMERGENCY PLANNING & COMMUNITY RIGHT-TO-KNOW ACT (EPCRA) 312 INSPECTION REPORT Stillman Wholesale Meat Company Facility Name and Address: Stillman Wholesale Meat Company 620 East 52nd Avenue Denver, Colorado 80216 Contact/Telephone: (303)296-0029 Mailing Address: Same as above Date of Inspection: June 12, 2023 RMP EPA ID #: NA TRIFID #: NA NAICS: 42424 # Employees at this location: 25 INTRODUCTION This report presents the observations of the CAA section 112(r)(1) and EPCRA section 312 inspection conducted by EPA Region 8. The purpose of this inspection was to determine compliance with the General Duty Clause (GDC) requirements of CAA section 112(r)(1) and the Tier II reporting requirements of EPCRA section 312. Stillman Wholesale Meat Company (SWMC) produces, processes, handles, or stores Anhydrous Ammonia. Anhydrous Ammonia is a regulated substance and is covered by the General Duty Clause as specified in the CAA 112(r)(1). Nature of Business: SWMC is a wholesale meat distributor. The SWMC facility was built expressly for SWMC's owners, and the facility went online in October/November of 2018. The facility was designed in accordance with ANSI/IIAR 2-2014 Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems (11AR 2). SWMC is strictly a distributor. No meat processing takes place on site. Summary of the General Duty Clause: The CAA section 112(r)(1) General Duty Clause states: "It shall be the objective of the regulations and programs authorized under this subsection to prevent the accidental release and to minimize the consequences of any such release of any substance listed pursuant to paragraph (3) or any other extremely hazardous substance. The owners and operators of stationary sources producing, processing, handling or storing such substances have a general duty, in the same manner and to the same extent as section 654, title 29 of the United States Code [the general duty clause in the Occupational Safety and Health Act], to identify hazards which may result from such releases using appropriate hazard 1 assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur." OBSERVATIONS CAA 112(r)(1) (GDC): Section 1. Identify hazards, which may result in, or from, accidental releases, using appropriate hazard assessment techniques. 1. SWMC did not conduct a Hazard Assessment, until 2023, to identify hazards which might result in, or from, an accidental release of anhydrous ammonia. Hazard assessments should be conducted using recognized and appropriate hazard evaluation techniques such as those described in "Guidelines for Hazard Evaluation Procedures" by the Center for Chemical Process Safety (CCPS). Hazard Review checklists developed by ammonia refrigeration industry organizations such as the IIAR Ammonia Refrigeration Management Program and are based on industry codes, standards and good engineering practices may also be used for systems that contain ammonia below the RMP threshold quantity of 10,000 pounds. Shortly after the EPA issued a Notice of inspection to SWMC on June 20, 2023, SWMC retained a consultant. The consultant prepared a GDC program for SWMP. The GDC program was completed in June of 2023, and included a Hazard Assessment. The Hazard Assessment is entitled "Process Hazard Analysis". Section 2. Design a safe facility taking such steps as are necessary to prevent releases. 2. The panic hardware on the south exit door of the Machinery Room (Ammonia Compressor Room) may not meet industry standards for safe design. The panic hardware consists of a glow-in-the-dark knob which must be pushed to open the door. The knob is of the type used in walk-in coolers and freezers. The EPA has the following concerns about the existing panic hardware, and about the door itself: o Too much pressure might be required to open the door o A touchpad style of hardware, which extends at least halfway across the door leaf, might be preferable o In addition, the door should be self-closing per Section 7.3.9.2 of ANSI/IIAR 9-2020 Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems (IIAR-9) and per Section 6.10.2 of ANSI/IIAR 2-2014 Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems (11AR 2). The EPA recommends that SWMC consult with an expert re. the door hardware and change the hardware if the expert recommends doing so The EPA also recommends that SWMC ensure that the door is self-closing. 2 3. An emergency eyewash/safety-shower is not installed in the Machinery Room (Ammonia Compressor Room). An emergency eyewash/safety-shower is required inside the Machine Room per Section 7.3.7.1 of IIAR-9 and per Section 6.7.1 of IIAR-2. Note: SWMC discovered the missing eyewash/safety-shower, during their 2023 Compliance Audit and 2023 Process Hazard Analysis. SWMC is arranging to have the eyewash/safety-shower installed. 4. The NFPA label on the exterior side of the west Machinery-Room door is faded and needs to be replaced. The label is required per NFPA 704, Section 7.2.9.1 of IIAR-9, and Section 6.15.1 of IIAR-2. 5. The signage on the exterior side of the west Machinery-Room door does not include an emergency phone number. Section 5.14.1 of IIAR-2 requires that the phone number be included on the signage. 6. The King valves (one electronic, one manual) in the Machinery-Room are not labeled. The King valves should be identified per Section 7.2.9.3 of IIAR-9, and Sections 5.12.5.2, 5.14.4, and 13.3.2.8 of IIAR-2. Section 3. Maintain a safe facility taking such steps as are necessary to prevent releases. 7. The facility did not conduct/document daily, weekly, monthly, and yearly inspections of the ammonia system before 2023. These Inspections are required by ANSI/IIAR 6-2019 Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems (IIAR-6) IIAR-6 is described as a "normative" (i.e., "required") reference in IIAR-9. 8. SWMC did not conduct/document maintenance training for their employees, on the ammonia equipment, until 2023. However, a documented training program was established in 2023 SWMC hired a consultant in 2023 to establish a GDC program for SWMC The GDC program, which is essentially a "PSM/RMP-light" program, includes a documented maintenance-training program, for their employees, on the ammonia equipment Such training is required by OSHA's PSM regulations and by the EPA's RMP regulations. 3 9. The windsock is missing at the condenser tower. Section 7.2.9.5 of IIAR-9 requires that the windsock be installed according to the emergency planning documents. Note: SWMC is aware of the missing windsock and has ordered a replacement. Section 4. Minimize the consequences of accidental releases which do occur. 10. Except for some training in 2018, SWMC did not conduct/document training, including emergency evacuation training, for their employees before 2023. However, a documented training program was established in 2023 SWMC hired a consultant in 2023 to establish a GDC program for SWMC The GDC program, which is essentially a "PSM/RMP-light" program, includes a documented training program for SWMC's employees Such training is required by OSHA's PSM regulations and by the EPA's RMP regulations. EPCRA 312: 1. SWMC did not submit Tier II's before 2023 (for RY2022), although they were required to do so. 2. The reported quantity of anhydrous ammonia on SWMC's 2022 Tier II may be incorrect. The reported quantity is 2000 pounds. However, a sign, at a Machinery-Room exit, documents that the quantity is 2500 pounds. SWMC should establish whether the correct quantity is 2000 pounds, or 2500 pounds, then change the quantity on their Tier II if the quantity is incorrect. INSPECTION REPORT REVIEW RECORD Author: Final Reviewer: Toxics and Pesticides Enforcement Section Inspector Section Supervisor Date: 8/4/2023 8/18/2023 4 5