Document 1gYdZkQV7Gw3q60j4m5KepK8K

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Inspection Report FACILITY INFORMATION: Name: Alpenrose Dairy Physical Address: 6149 S.W. Shattuck Rd. Portland, OR 97221 Phone Number: 503-244-1133 Latitude/Longitude: (45.478885, -122.739784) RMP Facility ID# 1000 0001 0203 FRS ID#: 110000487679 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Carl Cadonau Jr. Phone Number: (503) 244-1133 E-mail: None EMERGENCY CONTACT INFORMATION: Name: Patrick Ryan Phone (24-hr): (503) 519-5086 E-mail: patrick@alpenrose.com Website: http://www.alpenrose.com TRIP DETAILS: Inspection Date: March 15, 2023 Inspection Time: 09:00 through 15:15 EPA Inspection Team: Terry Garcia, US EPA Region 10 SEE Grantee, Lead RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, EPCRA 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 19, 2023, Page 1 of 6 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: May 19, 1999 Date of Latest Update: June 24, 2019 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000100968 Description Refrigeration System Process Chemical ID 1000126424 NAICS Code 1000102229 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 20,000 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: If Yes, Date of Last Inspection: January 13, 2014 No Yes The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit their Tier II report to the SERC? If Yes, Date the Tier II was submitted: March 14, 2023 If No, calendar year of the most recent Tier II: No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: March 14, 2023 INSPECTION ENTRY: Terry Garcia led the inspection entry. The EPA Inspection Team (EPA) met with facility representatives at the Alpenrose Dairy facility in Portland, Oregon. EPA arrived at the facility at 0845 hours and was joined by the following facility personnel: Name Larisa Palmentere Nancy Gammond-Moody Brad Armstrong Larry Bailey II John White Title, Organization EH&S Manager - Alpenrose Dairy Director of HR - Alpenrose Dairy Maintenance Manager - Alpenrose Dairy Contracted Service Tech - APCCO Maintenance Manager - Alpenrose Dairy Page 2 of 6 Was a state/county/or local emergency representative present? No Yes If Yes, Name and Title of Representative: Bryan Profit, Portland Fire Department The facility is a first responder: If No, Responding Agency: Portland Fire Department No Yes Facility representatives escorted EPA to a conference room located in the facility's office building. Lead Inspector Terry Garcia 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. Facility representative Larisa Palmentere gave a brief description of the facility, operations, and personal protective equipment required for the tour. It was stated that Alplenrose facility will move operations in 2024 to different Portland area location. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility 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. The facility is unionized: If Yes, Name of Union: Teamsters Union No Yes An employee representative present during the facility visit: If Yes, Name/Title: John White - Maintenance Manager No Yes GENERAL INFORMATION: The facility is regulated under RMP as a Program Level 3 facility and is owned and operated by Smith Brothers LLC and Alfin Investments - Alpenrose Family. The facility operates as a diary production and cold storage facility and utilizes one anhydrous ammonia refrigeration system to support production and storage of milk, cottage cheese, sour cream, and ice cream mix. The refrigeration system utilizes 20,000 pounds of anhydrous ammonia to refrigerate the facility's cold storage rooms. There are 150 full-time employees on site including four operators that work on the regulated process. Six AAPCO Contractors conduct maintenance on the refrigeration process equipment. ON-SITE OBSERVATIONS: EPA toured the facility from approximately 1000 hours to 1200 hours, escorted by facility representatives Larisa Palmentere, Brad Armstrong, Larry Bailey II, John White, and Nancy GammondMoody. One engine room houses refrigeration system components, supported by roof-mounted condensers. The refrigeration system services cold storage rooms and productions chillers at the facility. EPA observed four [4] cold storage rooms (School Diary Cold Storage, Nut Cold Storage Cold Storage Room 3, and Cold Storage Room 4), The Milk Chiller Room, Fabrication Room, Compressor Room (engine room), and the Ludell Engine Room. EPA also observed exterior areas of the facility and viewed the roof-mounted condensers from below. Ammonia is present in the Milk chiller (photos 5-12) and engine rooms (photos 49-71). The milk chiller room contains an operational chiller and one decommissioned chiller, the room also has two ammonia sensors with alarms set to notify personnel at 25, 50, and 100 ppm concentrations. The entire facility Page 3 of 6 system will shut down if an ammonia concentration of 1,600 ppm is detected. EPA observed the Compressor Room containing an oil-water separator, ammonia detection system and alarm, compressors, ammonia lines, and intake/exhaust vents (photos 49-65). The Luddell Engine Room includes an ammonia detection system and alarm, ammonia lines, and eye wash station and hazcom signage (photos 66-71). EPA observed staged product and evaporators in the cold rooms including the School Dairy Cold Room (photo 1), the Nut Cold Storage Room (photo 2), and a connecting hallway which includes emergency shower and eye wash station (photos 3-4). EPA observed refrigeration system components and safety features in the Milk Chiller Room (photo 5), including an ammonia detection system (photo 6), ammonia tanks, piping, and valves (photos 7-12). In the Milk Chiller Room, pressure relief valve (PRV) inspection tags were observed as overdue. Replace by October 2022 foreground tag; second tag install date: October 2017. Both PRV tags show replacement dates are overdue (photo 12). EPA observed additional refrigerated areas including the Temperature Exchange Room (photos 13-14, 27-29), Cold Storage Room 4 (photos 15-23), Cold Storage Room 2 (photos 23-24), Cold Storage Room 3 (photos 25-26) Exterior areas of the facility include NFPA placards, hazardous communication (hazcom) signage, a windsock next to the roof-mounted condensers and ammonia lines (photos 30-36, 44-48). The Fabrication Room at the facility includes ceiling-mounted condensers, an ammonia detection system alarm, fire suppression and first aid supplies, ammonia lines and valves, and intake/exhaust vents (photos 37-43). EPA observed the Compressor Room containing an oil-water separator, ammonia detection system and alarm, compressors, ammonia lines, and intake/exhaust vents (photos 49-65). Photographs taken during the inspection are included in Attachment A of this report. 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 Larisa Palmentere, Brad Armstrong, Larry Bailey II, John White, and Nancy Gammond-Moody. INFORMATION COLLECTED FROM FACILITY: 1. Mechanical Integrity documentation 2. Alpenrose facility map 3. Alpenrose Ammonia refrigeration system diagrams 4. Compliance Audit example AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Compliance Audits: Alpenrose Dairy did not certify that they have evaluated compliance with the provisions of this subpart at least every three years to verify that the procedures and practices developed under this subpart are adequate and are being followed. [68.79(a)]. Alpenrose did not provide documentation that a 2019 Compliance Audit was performed and was unable to provide the last two compliance audits. [69.79(c) and (e )]. Alpenrose Dairy provided PSM Meeting documents dated 2019 and 3/13/2022 in lieu of a compliance audit. Page 4 of 6 2. Process Hazard Analysis (PHA): Alpenrose Dairy did not complete PHA revalidation at least every five (5) years after the completion of the initial 2015 PHA and 2022 PHA revalidation. [68.67(f)]. 3. Employee Participation: Alpenrose Dairy does not have a written plan of action regarding employee participation. At the time of inspection, it was noted that employees have access to PHA via company Drive however there is no proof that the company has assured employees are aware of the conduct and development of process hazard analyses or other process safety management in chemical accident prevention. [68.83 (a-c)]. 4. Contractors: Alpenrose Dairy did not obtain and evaluate information regarding the contract owner or operator's safety performance and programs. Alpenrose did not provide documentation that demonstrates they have periodically evaluated the performance of contractors as required. [68.87(b)(1), (b)(4) and (b)(5)]. 5. Training: Alpenrose Dairy was unable to provide initial and refresher training documentation for operators that show site specific SOP training. Alpenrose Dairy did provide some training documents on ammonia safety but no SOP training for the three operators (Andrew LaBelle, John White and Bradley Armstrong). 6. Operating Procedures: Alpenrose Dairy was unable to provide documentation that shows operating procedures are certified annually and are current and accurate. [68.69(c)] 7. Emergency Response: Alpenrose Dairy has not maintained a record of each notification exercise conducted within the last five years. [68.96 (a)]. 8. Mechanical Integrity, Training for Process Maintenance Activities: Alpenrose Dairy did not provide documents that demonstrate they train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner. [68.73(c)]. Alpenrose was unable to provide training documentation for six AAPCO contractors that perform maintenance at the site. 9. RMP Required Corrections: Emergency contact information--Beginning June 21, 2004, within one month of any change in the emergency contact information required under 68.160(b)(6), the owner or operator shall submit a correction of that information. [68.195(b)]. At the time of inspection Mr. Patrick Ryan was still listed as the emergency contact in their RMP who left the company in 2022. 10. EPCRA Compliance: Alpenrose Dairy 2022 Tier II report was submitted thirteen (13) days late to the SERC, LEPC and Fire. 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. 1. Engine room ventilation calculations documentation needed 2. Relief system design basis documentation Page 5 of 6 3. APCCO contractor maintenance training documentation 4. Refresher training documentation for facility operators 5. Initial training documentation for facility operators 6. 2019 Mechanical integrity audit tracking for all findings documentation 7. SOP annual certification documentation 2021 and 2022 On June 14, 2023, EPA requested additional information and clarification from Alpenrose Dairy facility on the items listed above that were provided on March 28, 2023. In June 26, 2023, email Alpenrose Dairy stated they are unable to provide any additional documentation to complete the request for documents. INSPECTION REPORT CERTIFICATION: This is to certify that I, Terry Garcia, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 6 of 6 Attachment A - Photo Log Site Name: City, State: Photographer: Alpenrose Dairy Portland, Oregon Taylor Law File Photo 1.jpg Photo 2.jpg Photo 3.jpg Photo 4.jpg Photo 5.jpg Photo 6.jpg Photo 7.jpg Photo 8.jpg Photo 9.jpg Photo 10.jpg Photo 11.jpg Photo 12.jpg Photo 13.jpg Photo 14.jpg Photo 15.jpg Photo 16.jpg Photo 17.jpg Photo 18.jpg Photo 19.jpg Photo 20.jpg Photo 21.jpg Photo 22.jpg Photo 23.jpg Photo 24.jpg Photo 25.jpg Photo 26.jpg Photo 27.jpg Photo 28.jpg Photo 29.jpg Photo 30.jpg Photo 31.jpg Photo 32.jpg Photo Layout ID 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Date 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 3/15/2023 Description School Dairy Cold Storage Room, overview Nut Room Cold Storage Room, overview Entrance Hallway, connecting small cold storage rooms to Cold Storage Room 4 Cold Storage Room 4, eyewash station Milk Chiller Room, overview Milk Chiller Room, ammonia detection system Milk Chiller Room, chiller system and ammonia piping Milk Chiller Room, chiller system tanks and piping Milk Chiller Room, chiller system components Milk Chiller Room, chiller system inspection sticker Milk Chiller Room, chiller system tanks, valves and piping Milk Chiller Room, PRV inspection tags Temperature Exchange Room, overview Temperature Exchange Room, evaporators Cold Storage Room 4, overview Cold Storage Room 4, overview Cold Storage Room 4, dairy product carton/container area Cold Storage Room 4, ammonia piping Cold Storage Room 4, ammonia detector proximal to ceiling piping Cold Storage Room 4, small ammonia evaporators Cold Storage Room 4, Small ammonia evaporators Cold Storage Room 4, ammonia line transfer with labeling Transition from Cold Storage Room 4 to Cold Storage Room 2, ammonia transfer lines Cold Storage Room 2, ammonia evaporators Cold Storage Room 3, ammonia evaporators Cold Storage Room 3, staged milk cartons Temperature Exchange Room, ammonia evaporators and staged milk cartons Temperature Exchange Room, ammonia sensor Temperature Exchange Room, evaporators Cold Storage Room 3, hazard communication (hazcom) signage at exit Maintenance Room, hazcom signage at entrance Facility Building Exterior, roof-mounted condenser and windsock Photo 33.jpg Photo 34.jpg Photo 35.jpg Photo 36.jpg Photo 37.jpg Photo 38.jpg Photo 39.jpg Photo 40.jpg Photo 41.jpg Photo 42.jpg Photo 43.jpg Photo 44.jpg Photo 45.jpg Photo 46.jpg Photo 47.jpg Photo 48.jpg Photo 49.jpg Photo 50.jpg Photo 51.jpg Photo 52.jpg Photo 53.jpg Photo 54.jpg Photo 55.jpg Photo 56.jpg Photo 57.jpg Photo 58.jpg Photo 59.jpg Photo 60.jpg Photo 61.jpg Photo 62.jpg Photo 63.jpg Photo 64.jpg Photo 65.jpg Photo 66.jpg Photo 67.jpg Photo 68.jpg Photo 69.jpg Photo 70.jpg Photo 71.jpg 33 3/15/2023 Facility Building Exterior, roof-mounted condenser 34 3/15/2023 Facility Exterior / Fabrication Shop, eyewash station 35 3/15/2023 Facility Exterior / Engine Room, ammonia detector and alarm and hazcom signage outside access door 36 3/15/2023 Facility Exterior / Fabrication Shop, ammonia detector and reading display at access door 37 3/15/2023 Fabrication Room, ammonia lines for ceiling-mounted condensers 38 3/15/2023 Fabrication Room, ammonia alarm 39 3/15/2023 Fabrication Room, fire suppression and first aid equipment at access door 40 3/15/2023 Fabrication Room, air intake on wall 41 3/15/2023 Fabrication Room, ammonia lines and valves 42 3/15/2023 Fabrication Room, ammonia lines and ammonia detector 43 3/15/2023 Fabrication Room, overview of housekeeping 44 3/15/2023 Facility Exterior, roof mounted condensers above Fabrication Room 45 3/15/2023 Facility Exterior, roof mounted condensers above Fabrication Room 46 3/15/2023 Facility Exterior, roof mounted condensers above Fabrication Room 47 3/15/2023 Facility Exterior, roof mounted condensers above Fabrication Room 48 3/15/2023 Facility Exterior, roof mounted condensers and ammonia lines above Fabrication Room 49 3/15/2023 Compressor Room, oil/water separator 50 3/15/2023 Compressor Room, ammonia alarm 51 3/15/2023 Compressor Room, ammonia lines compressors 52 3/15/2023 Compressor Room, ammonia detector 53 3/15/2023 Compressor Room, ammonia detector 54 3/15/2023 Compressor Room, inspection dates on ammonia gas sensor 55 3/15/2023 Compressor Room, system intake 56 3/15/2023 Compressor Room, system exhaust vent 57 3/15/2023 Compressor Room, second system air intake 58 3/15/2023 Compressor Room, compressor inspection documentation 59 3/15/2023 Compressor Room, inspection tags on compressor 60 3/15/2023 Compressor Room, ammonia transfer system components 61 3/15/2023 Compressor Room, ammonia lines 62 3/15/2023 Compressor Room, ammonia lines and compressors 63 3/15/2023 Compressor Room, recirculation unit 64 3/15/2023 Compressor Room, inspection sticker on recirculation unit 65 3/15/2023 Compressor Room Exterior, ammonia alarm 66 3/15/2023 Luddell Engine Room, ammonia detector 67 3/15/2023 Luddell Room, ammonia alarm at access door and hazcom signage 68 3/15/2023 Luddell Room, ammonia lines 69 3/15/2023 Luddell Room, ceiling damage 70 3/15/2023 Luddell Room, eyewash station 71 3/15/2023 Luddell Room, ammonia lines