Document 6by3vbXVNqL2prgYa3djY44E9

SENT VIA ELECTRONIC MAIL Danny Moseley Plant Manager United Packers of Mobile Coca-Cola Bottling Company United, Inc. 5300 Coca Cola Road Mobile, Alabama 36619 Dannymoseley@ccbcu.com Dear Danny Moseley: Enclosed is a copy of the final Inspection Report (Enclosure A) generated by the Environmental Protection Agency Region 4 Air Enforcement Branch for the December 11, 2024, partial compliance inspection of the Coca-Cola Bottling Company United, Inc., facility located at 5300 Coca-Cola Road, Mobile, Alabama. The EPA previously sent a copy of the draft report in an email on January 30, 2025, allowing the CocaCola Bottling Company United, Inc., 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 February 4, 2025, the Coca-Cola Bottling Company United, Inc., notified EPA that no information was being claimed CBI. Should you have any questions regarding the inspection report, please contact me at (404) 562-9198, or by email at warrilow.phyllis@epa.gov. Sincerely, PHYLLIS WARRILOW Digitally signed by PHYLLIS WARRILOW Date: 2025.02.06 10:38:43 -05'00' Phyllis Warrilow, PE Environmental Engineer South Air Enforcement Section Enclosure ENCLOSURE A INSPECTION REPORT United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report I. GENERAL INFORMATION Facility Name: United Packers of Mobile, Coca-Cola Bottling Company United Location (Address): 5300 Coca-Cola Road, Mobile, Alabama 36619 Inspection Date: December 11, 2024 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: 3601756357 EPA Region 4 Investigator(s)/Inspector(s): 1. Phyllis Warrilow, Environmental Engineer State/Local Investigator(s)/Inspector(s): none Person(s) Contacted at Facility (Name and Title): 1. Danny Moseley, Plant Manager 2. Julia Thomas, Management Systems Manager 3. Alex Clark, EHS Specialist 4. Justin Kicbo, Maintenance Manager 5. Chuck Hill, Corporate EHS manager for Production, via telephone Report Prepared by: Phyllis Warrilow Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 15 II. FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 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. NAICS 312111 - Soft Drink Manufacturing. N/A N/A 4. Air permit expiration date. 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 Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 15 United Packers of Mobile, Coca-Cola Bottling Company United (Facility) located at 5300 Coca Cola Road, Mobile, Alabama is classified under NAICS Code 312111, Soft Drink Manufacturing. The United Packers Mobile, Coca-Cola Bottling Company United location is owned by Coca-Cola Bottling Company United. The Mobile Coca-Cola manufacturing facility was originally located in downtown Mobile, Alabama. In 1974, the facility was moved to its present location at 5300 Coca-Cola Road and has been owned and operated by Coca-Cola Bottling Company United since 2017. The facility includes a total of 100,000 square feet of operations comprised of three bottling lines producing bottles and cans of soft drinks. The facility operates all year, with 5-day weeks and 2 shifts plus maintenance per day. The facility employs approximately 101 persons. The facility uses an ammonia refrigeration system to cool the manufacturing production lines and product. The facility had 6,000 lbs of ammonia on site at the time of the inspection per invoices. III. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. 2. Credentials presented to facility personnel (include name and title). Yes No NA Y Y Comments The EPA Region 4 (R4) inspector arrived at the Facility on December 11, 2024, at approximately 10:00 AM EDT The EPA Inspector presented credentials to: Danny Moseley - Plant Manager, Julia Thomas - Management Systems Manager, Alex Clark -EHS Specialist, Justin Kimbro - Maintenance Manager. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 15 Activity Yes No NA 3. Conducted an opening meeting Y to explain the purpose and objectives of the inspection. Comments The opening conference began at 10:40 AM EDT during which the purpose and objectives of the inspection were explained. The opening conference was led by EPA inspector Phyllis Warrilow as well as members of United Packers of Mobile, Coca-Cola Bottling United management. The inspector 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 The inspector discussed Facility-specific safety and emergency procedures. Ear plugs, safety glasses, coats, gloves, shoe, and hair coverings were provided as needed. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 15 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 Comments The EPA inspector 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: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 15 Activity Records Reviewed at the Facility 10. The types of records reviewed, and the time period reviewed. Yes No NA Y Comments EPA inspectors requested the following records during the inspection: - Documentation of the total amount of ammonia in the refrigeration system. -Piping and instrumentation diagrams for the ammonia refrigeration system. -Process Hazard Analysis. -Documentation of the preventive maintenance/mechanical integrity program for the ammonia refrigeration system. -Standard operating procedures relating to the ammonia refrigeration system -Confirmation of the most recent calibration or testing of any ammonia sensors/alarms, - Records of Pressure Relief Valve recertifications. (Required every 5 years), -Facility's emergency response plan or emergency action plan. Records of the Process Hazard Analysis for the ammonia refrigeration system were not presented to EPA at the time of the inspection. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 15 Activity Yes No NA Facility Walk-Through Observations 11. The process equipment Y 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). 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 The facility has ten compressors. Compressor Number 1, 3,4,5,6 and 10 were not running at the time of the inspection. Compressors 2,7,8 and 9 were operating at time of the inspection. At approximately 1:53 PM on Dec 11, 2024: Compressor Number 2 was observed to be operating at a discharge pressure of 145 PSIG and a suction pressure of 24 PSIG. Compressor Number 7 was observed to be operating at a discharge pressure of 150 PSIG and a suction pressure of 32 PSIG. Compressor Number 8 was observed to be operating at a discharge pressure of 150 PSIG and a suction pressure of 26 PSIG. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 15 Activity 12. The type of process parametric 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. Yes No NA N/A 14. If process equipment or N/A parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Comments Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 15 Activity 15. The type of air pollution 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. Yes No NA N/A Comments Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 15 Activity 16. Continuous emissions 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. Yes No NA N/A Comments As part of the walk through at approximately 1:50 pm on Dec 11, 2024, the EPA inspector observed ammonia detectors in the machine room and throughout the facility. The facility operates 7 ammonia detectors. The last calibration of the ammonia sensors occurred September 19, 2024. The facility stated that the next calibration was scheduled for March of 2025. The pressure safety relief valves in the machine room were current and will expire in April of 2025 with the exception of PSV2 which was installed October 2, 2024, along with some other maintenance and it will expire in 2029. 17. If air pollution control N/A equipment was not operating, state the reason by facility personnel why the equipment was not operating. 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). Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 15 Activity 19. Ductwork transferring the 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.). Yes No NA N/A 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). 22. Was a Method 9 reading N/A performed? (if yes, identify the location and equipment). 23. Was the cause of the visible N/A emissions investigated and the information documented? Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 15 Comments Activity 24. Was a Method 22 performed for visible emissions? (if yes, identify the location and equipment). Yes No NA N/A 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. 27. Was the TVA used? If so, N identify the equipment monitored and the results. 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. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 15 Comments Activity 28. Was the PID used? If so, 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. Yes No NA N/A Comments Closing Meeting 29. Conducted a closing meeting. Y 30. Summarize any additional Y information needed, if applicable? 31. Accept a declaration of CBI, if N/A applicable? The closing meeting was conducted starting at 2:38 PM on December 11, 2024. Attendees were the same as were present for the opening meeting except for the Plant Manager. Facility had all requested documents except for the Process Hazard Analysis. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 15 Activity 32. Discussed observations. Yes No NA Y Comments The facility's mechanical equipment and mechanical integrity program was implemented by maintenance personnel. Some records were computerized and easily retrievable. The Facility was able to verify the following records for the ammonia refrigerant system: - Documentation of the total amount of ammonia in the refrigeration system - Pressure safety valve certifications. - Dates of the most recent calibration or testing of any ammonia sensors/alarms. - Process & Instrumentation Diagram - Standard Operating Procedures - Preventative Maintenance records - Facility Emergency Response Plan Mechanical Integrity and Preventative maintenance were kept on schedule by maintenance personnel and ammonia refrigeration contractors. Process Hazard Analysis was not available at the time of the inspection. Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 14 of 15 Activity 33. Discussed next steps, if applicable? 34. Date and time inspection concluded. Miscellaneous 34. Include any additional observations, if applicable. Yes No NA Y Y Comments A final inspection report from EPA Region 4 will be sent to the company within a 70day timeframe. Document requests were discussed. On December 11, 2024, at approximately 2:50 PM the Region 4 inspector left the Facility and concluded the inspection. Process Hazard Analysis for the ammonia refrigeration system are to be received from the facility as acknowledged above. EPA Investigator/Inspector Signature:__P__H_Y__L_L_I_S__W__A_R__R_I_L_O__W____D_a_te_: 2_02_5_.0_2._06_10:39:39 -05'00' Digitally signed by PHYLLIS WARRILOW EPA Supervisor Signature & Title Digitally signed by TODD __T_O__D__D_____________G_R_O_EN_D_Y_K_E________ GROENDYKE Date: 2025.02.06 11:50:03 -05'00' ___________________________________ Date Report Finalized: 2/6/2025 Project Name: Coca-Cola United Packers Mobile ICIS/Project No. 3601756357 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 15 of 15 APPENDICES AND ATTACHMENTS Appendix A: Document Receipt Log No documents were obtained from Facility representatives during the on-site inspection.