Document 50kQ42KXkdN2VEMNMeEm9b6kR

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: Zirkle Fruit Co., Johnny Appleseed Physical Address: 226 B&O Road, Malott, WA 98829 Phone Number: 509-245-5231 Latitude/Longitude: 48.303818 / -119.684517 RMP Facility ID# 100000141704 FRS ID#: 110071178192 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Scott Blackledge Phone Number: 509-941-8714 E-mail: scottb@zirklefruit.com EMERGENCY CONTACT INFORMATION: Name: Joel Hand Phone (24-hr): 509-421-0986 E-mail: joelh@zirklefruit.com TRIP DETAILS: Inspection Date: Inspection Time: Inspection Team: May 27, 2022 0815 hours through 1130 hours Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, EPCRA Inspector Lisa Graves, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: June 25, 1999 Date of Latest Update: June 7, 2019 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID NAICS Code 1000100118 Ammonia Refrigeration 1000125397 49312 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 14,000 Page 1 of 5 PURPOSE: The purpose of this inspection was to determine whether 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: No Yes The facility is High Risk: No Yes Joint EPCRA inspection: No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? No Yes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 2/22/2022 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: 2/22/2022 INSPECTION ENTRY: Peter Phillips led the inspection entry. The EPA Inspection Team (EPA) met with facility representative Joshua Austin at the Zirkle Fruit Co., Johnny Appleseed facility in Marlott, Washington. EPA arrived at the facility at 0815 hours and was joined by the following facility personnel: Name Joshua Austin Scott Blackledge Myles Austin Troy French Michael Leadon Title PSM Manager Safety Manager Refrigeration Operator Facility Manager Compliance Was a state/county/or local emergency representative present? No Yes The facility is a first responder: If No, Responding Agency: Malott Fire Department No Yes The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Peter Phillips, who provided a summary of the risk management program (RMP) and explained the purpose of the visit. Each team member 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. Joshua Austin and other facility personnel gave a brief description of the facility, operations, and personal protective equipment required for the tour. Page 2 of 5 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: No Yes An employee representative present during the facility visit: No Yes GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 3 facility and is leased and operated by Zirkle Fruit Co., Johnny Appleseed (Zirkle Fruit). Zirkle Fruit operates produce packing and refrigeration warehouse which utilizes an ammonia refrigeration system. The refrigeration system retains 14,000 lbs. of anhydrous ammonia on site. There are 25 full-time employees on site, four of whom are responsible for refrigeration operations. Two engine rooms house components of the facility's interconnected refrigeration system, which provides cooling to fifteen controlled atmosphere rooms. The refrigeration operator checks the ammonia refrigeration system every workday and all refrigerated areas are continuously monitored by an ammonia detection system. The refrigeration system remotely notifies the refrigeration operator when an alarm is triggered, or when refrigeration parameters are out-of-range. There are no process modifications that impact the facility's ammonia refrigeration process. The facility has established an Emergency Action Plan (EAP) in the event of an ammonia release and all employees receive refresher training at least every three years or more as necessary. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 0930 hours to 1020 hours. The EPA Inspection Team was escorted by facility representatives Joshua Austin, Troy French, Michael Leadon, and Myles Austin. EPA observed refrigeration system equipment at exterior areas of the facility, Engine Room 1, Engine Room 2, the Control Room, and two controlled atmosphere rooms CA 1A and CA 2. The hydro-cooler conveyor system is located at the exterior of the building designated as Common Storage 11. The hydro-cooler included a dedicated evaporator with ancillary equipment adjacent to it (Photos 1-3). The interior of Common Storage 11 (Photos 4-5) contained ammonia piping components of the refrigeration system. EPA observed two controlled atmosphere (CA) rooms, CA 1A (Photos 6-8) and CA 2 (Photos 9-11). The equipment observed in each CA room included an evaporator, ammonia sensor intake, and an alarm leak detection device. The equipment observed in Engine Room 1 included compressors, pressure relief valves, an accumulator tank, an exhaust vent, intake (which the facility identified as airflow through the opened inner door into the engine room), emergency shower/eyewash, and the alarm leak detection device (Photos 12-22). Three high pressure receiver (HPR) tanks and the associated king valve for Engine Room 1 were located outside the room, in an enclosed fenced area (Photos 23-24). The system condensers were housed above the HPR tanks on a metal platform (Photos 25-27). Page 3 of 5 The equipment observed in the Engine Room 2 (mislabeled as Engine Room 3 by facility signage, Photo 28) included one HPR tank and associated king valve, compressors, pressure relief valves, emergency shower/eyewash, safety lock-out station, exhaust, intakes, and the alarm leak detection device (Photos 29-40). The system condensers for Engine Room 2 were located on the building rooftop (Photo 41). The Control Room used to monitor all facility refrigeration parameters from a dedicated computer terminal, and the ammonia sensor network panel were in an adjacent room from Engine Room 2 (Photo 42). The facility ammonia refrigeration system and ancillary equipment were clearly labeled and tagged. In addition, safety features were observed throughout the facility (Photos 43-45). All photographs taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at the Zirkle Fruit facility, EPA returned to the conference room to review the facility RMP documentation. Upon completion of the document review, EPA provided a debriefing to Joshua Austin, Troy French, Michael Leadon, Myles Austin, and Scott Blackledge. INFORMATION COLLECTED FROM FACILITY: 1. Training Summary Form: On-The Job Training - 2 pages 2. Training Summary Form: General Training - 3 pages 3. Grandfathering Certification Form - 1 page 4. Operating Procedures Review Summary and Certification Form - 1 page 5. Plant Process Flow Diagram - 1 page 6. Plant Facility Layout - 1 page 7. Plant Mechanical Rm. #1 Receiver & Condensers (Outside) - 1 page 8. Plant Mechanical Rm. #1 (Inside) - 1 page 9. Plant Building Layout #1 - 1 page 10. Plant Building Layout #2 - 1 page 11. Plant Building Layout #3 - 1 page 12. Plant Mechanical Rm. #3 - 1 page AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Process Hazard Analysis (PHA): Zirkle Fruit has no documentation prior to the 2017 PHA for process updates or revalidations from the previous facility owner. Zirkle Fruit only has a 2017 PHA documentation on file. [68.67(g)] 2. Training: Zirkle Fruit has no initial training documents for ammonia operator, Arnulfo Mercado, on site specific operating procedures. [68.71(a)(1)] 3. Mechanical Integrity: Zirkle Fruit has pressure relief valves (PRVs) with a replacement date of 1/2020 that are passed due located in Engine Room 2. The inspection and testing frequency for the PRV maintenance is different than every five years for replacement.1 The facility stated the 1 The facility employs a methodology that only the PRV that is selected to relieve pressure on a 3-way manifold is tagged and current. The other relief valve on the manifold is out of date. When the active relief valve nears its replacement date, the other valve (out of date) is replaced by a new valve and the manifold is switched accordingly. The facility reasons that using one relief valve whether it be a single valve or mounted on a 3-way valve is adequate and that it is more cost-effective since the PRV inventory is reduced by 50%. Page 4 of 5 PRV replacement method was an approved method by Washington State L&I and would provide documentation for this approval. [68.73(f)(2)] 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. Mechanical Integrity - Letter from Washington State for PRV replacement practices. 2. Mechanical Integrity - SOP for changing out pressure relief valves. This follow-up information was requested on 5/28/2022, 8/2/2022 and 8/4/2022. The facility did not respond to the follow-up request. INSPECTION REPORT CERTIFICATION: This is to certify that I, Peter Phillips, 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 5 of 5