Document 2qYo8ZEwoz382wgonEb71eQaa

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Jason Peppers Engineering and Maintenance Manager Americold Logistics 600 25th Avenue W Birmingham, Alabama 35204 Jason.Peppers@americold.com Dear Mr. Peppers: Enclosed is a copy of the final Inspection Report (Enclosure A) generated by the U.S. Environmental Protection Agency's Region 4 Air Enforcement Branch for the August 24, 2022, partial compliance inspection of Americold Logistics, located at 600 25th Avenue W, Birmingham, Alabama 35204. The EPA previously sent a copy of the draft inspection report on October 5, 2022, allowing Americold Logistics to make any comments regarding the report and to claim any information contained in the report as confidential business information (CBI). In an email dated October 19, 2022, Americold Logistics notified EPA that no comments were being made and that no information was being claimed as CBI. Should you have any questions regarding this inspection report please contact me at (404) 562-9198, or by email at Warrilow.Phyllis@epa.gov. Enclosure Sincerely, Warrilow, Digitally signed by Warrilow, Phyllis Phyllis Date: 2022.10.19 11:53:32 -04'00' Phyllis Warrilow, PE Environmental Engineer South Air Enforcement Section ENCLOSURE A INSPECTION REPORT United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report I. GENERAL INFORMATION Facility Name: Americold Logistics Location (Address): 600 25th Ave W, Birmingham, Alabama Inspection Date: August 24, 2022 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation focused on the Clean Air Act (CAA) 112 (r)(1) General Duty Clause requirements of the ammonia refrigeration system. ICIS-Air Number: EPA Region 4 Investigator(s)/Inspector(s): 1. Phyllis Warrilow, Environmental Engineer 2. Carrie Griffith, Environmental Engineer State/Local Investigator(s)/Inspector(s): 1. N/A Person(s) Contacted at Facility (Name and Title): 1. Jason Peppers, Engineering and Maintenance Manager 2. John Moss, Process Safety Manager 3. Barbara Oden, Office Manager Report Prepared by: Phyllis Warrilow Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 13 II. FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). 3. Air permit issuance date. 4. Air permit expiration date. Comments NAICS 493120 - Refrigerated warehousing and storage N/A N/A N/A 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). N/A N/A Clean Air Act 112(r)(1) Ammonia refrigeration system N/A B. Process Description Americold Logistics (Facility) in Birmingham, Alabama is classified under NAICS code 493120, refrigerated warehousing and storage. The company provides storage and distribution of frozen food products. The facility has approximately 8,897 lbs ammonia on site. The facility size is 160,000 square feet. The facility operates shipping and receiving of products. The facility employs 15 workers and operates 1 shift daily. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 13 III. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. Yes No NA Y 2. Credentials presented to facility Y personnel (include name and title). Comments EPA Region 4 (R4) inspectors arrived at the Facility on August 23, 2022, at approximately 4:00 PM EDT and learned that the facility was closing for the day. R4 inspectors returned to the facility the next morning, August 24, 2022, at 9:10 AM EDT. Inspector Carrie Griffith was present via telephone. The EPA Inspector presented her credentials to Jason Peppers, Engineering and Maintenance Manager, John Moss, Process Safety Manager and Barbara Oden, Office Manager Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 13 Activity 3. Conducted an opening meeting to explain the purpose and objectives of the inspection. Yes No NA Y Comments Inspectors held an opening meeting on June 24, 2022, at 9:12 AM EDT during which the purpose and objectives of the inspection were explained. The opening conference was led by EPA inspector Phyllis Warrilow. Other opening meeting attendees were Carrie Griffith (via telephone) of EPA Region 4, as well as members of Americold Logistics management. Inspectors explained that they were conducting a Clean Air Act inspection specifically focused on the General Duty Clause requirements of the ammonia refrigerant system. 4. Discussed safety issues. Y Inspectors discussed Facility-specific safety and emergency procedures, including procedures for COVID-19 safety during the inspection. No personal protective equipment was required on site regarding COVID. Steel toe shoes and earplugs were required. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 13 Activity 5. Discussed which records to be reviewed. Yes No NA Y 6. Discussed the facility walk- Y through and the areas to be observed in the facility. 7. Discussed facility policy N/A regarding photographs or video (if applicable). 8. Discussed the use of the N/A infrared camera, TVA, PID, and any other equipment. 9. Discussed CBI. Y Records Reviewed at the Facility Comments EPA inspectors requested to review the following records: - Piping and instrumentation diagrams for the ammonia refrigeration system - Hazard assessment for the ammonia refrigeration system - Standard operating procedures relating to the ammonia refrigeration system - Documentation of the preventive maintenance/mechanical integrity program for the ammonia refrigeration system - Records of the most recent calibration or testing of any ammonia sensors/alarms -Pressure Relief Valve recertifications - Facility's emergency response plan or emergency action plan - Documentation of the total amount of ammonia in the refrigeration system EPA inspectors indicated that any documents claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 13 Activity 10. The types of records reviewed, and the time period reviewed. Yes No NA Y Facility Walk-Through Observations Comments EPA inspectors reviewed the following records during the inspection: -Piping and instrumentation diagrams for the ammonia refrigeration system. - Hazard assessment for the ammonia refrigeration system. - Standard operating procedures relating to the ammonia refrigeration system. - Documentation of the preventive maintenance/mechanical integrity program for the ammonia refrigeration system. - Records of the most recent calibration or testing of any ammonia sensors/alarms. (Required every 6 months) -Records of Pressure Relief Valve recertifications. (Required every 5 years) - Facility's emergency response plan or emergency action plan. - Documentation of the total amount of ammonia in the refrigeration system. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 13 Activity 11. The process equipment observed and the associated operational rate observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Yes No NA Y Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments Compressors were operating at time of the inspection. Compressor Number 2 was observed to be operating at a suction pressure of 28.7 PSIG and discharge of 170 PSIG at 10:06 a.m. on August 24, 2022. Compressor Number 4 was observed to be operating at a suction pressure of 2.1 inch of HG and discharge of 30.5 PSIG at 10:07 a.m. on August 24, 2022. 12. The type of process parametric N/A monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). Provide the date and time the information was recorded by the inspector. 13. Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 13 Activity 14. If process equipment or parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Yes No NA N/A 15. The type of air pollution N/A control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.). (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. Continuous emissions N/A monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments EPA inspectors observed ammonia detectors in the machine room. The facility operates 7 ammonia detectors. Documentation verifying monthly calibration records for all ammonia sensors was provided at 10:05 am on 8/24/2022. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 13 Activity 17. If air pollution control equipment was not operating, state the reason by facility personnel why the equipment was not operating. Yes No NA N/A 18. Capture and collection system N/A (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). 19. Ductwork transferring the N/A emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). 20. Any existing unpermitted N/A emission points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 21. Were any visible emissions N/A observed? (if yes, identify the location and equipment). Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 13 Comments Activity 22. Was a Method 9 reading performed? (if yes, identify the location and equipment). Yes No NA N/A 23. Was the cause of the visible N/A emissions investigated and the information documented? 24. Was a Method 22 performed N/A for visible emissions? (if yes, identify the location and equipment). 25. Identify the cause of the visible N/A emissions as explained by facility personnel, if applicable. 26. Was the infrared camera used? N/A If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. Comments Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 13 Activity 27. Was the TVA used? If so, identify the equipment monitored and the results. Yes No NA N Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. 28. Was the PID used? If so, N/A identify how the PID was used and the results. Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Comments Closing Meeting 29. Conducted a closing meeting. Y 30. Summarize any additional N information needed, if applicable? 31. Accept a declaration of CBI, if N/A applicable? The closing meeting was conducted starting at 11:05 a.m. on August 24, 2022. Attendees were the same as were present for the opening meeting. Facility had all requested documents present at time of inspection. Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 13 Activity 32. Discussed observations. Yes No NA N Comments 1) The facility's mechanical equipment and maintenance program was fully automated. All calibration records and maintenance records were computerized and easily retrievable. There was an organized maintenance schedule for the ammonia system including calibration of ammonia sensors and relief valve maintenance. 2) The Facility was able to produce the following records for the ammonia refrigerant system: - Process & Instrumentation Diagram - Hazard Assessment - Preventative Maintenance records - Calibration records - Facility Emergency Response Plan - Documentation of the total amount of ammonia in the refrigeration system - Standard Operating Procedures (SOPs) 3. Mechanical Integrity and Preventative maintenance were all kept on schedule and organized by computer. 4. All documents including PHA, Ammonia sensor calibrations, PSV recertifications and SOPs were organized and up to date. 33. Discussed next steps, if applicable? Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Y A final inspection report from EPA Region 4 will be sent to the company within a 60- day timeframe. Document requests were discussed. Page 12 of 13 Activity 34. Date and time inspection concluded. Miscellaneous 34. Include any additional observations, if applicable. Yes No NA N/A Comments On August 24, 2022, at approximately 11:10 AM EDT the Region 4 inspector left the Facility and concluded the inspection. No additional records are to be received from the facility as acknowledged above. EPA Investigator/Inspector Signature:_W___a_r_ri_l_o_w__,_P_h__y_ll_i_s_____D_a_te_: _20_22_.1_0_.1_9 _11_:5_4:05 -04'00' Digitally signed by Warrilow, Phyllis Digitally signed by Groendyke, EPA Supervisor Signature & Title _G_r_o_e__n_d__y_k_e_,_T_o__d_d__TD_oa_dted_: 2_0_22_.1_0._19_1_2:_52_:5_3_-0_4'_00' ___________________________________ Date Report Finalized: October 19, 2022 Project Name: Americold Logistics, Birmingham ICIS/Project No.:3601466202-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 13 APPENDICES AND ATTACHMENTS Appendix A: Document Receipt Log No documents were obtained from Facility representatives during the on-site inspection.