Document B5D944xx7NayNrZDDmpxo21qw

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Green Bay Dressed Beef, LLC - East River, Green Bay, Wisconsin Vicky Mei, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Green Bay Dressed Beef, LLC - East River Facility Location: 800 University Avenue, Green Bay, Wisconsin 54302 Date of Virtual Inspection: September 20, 2022 Date of On-Site Inspection: September 21, 2022 EPA Inspector(s): 1. Vicky Mei, Environmental Engineer Other Attendees at the Virtual Inspection: 1. Matthew Beno, Safety Coordinator 2. Eric Johnston, PSM Director 3. Nick Ossi, Environmental Manager 4. John Waldner, Refrigeration Maintenance Staff 5. Octavio Sanchez, Refrigeration Maintenance Staff 6. Devin Ermis, Maintenance Manager Other Attendees at the On-Site Inspection: 1. Mark Hildebrand, VP of Operations 2. Nate Green, EHS Manager 3. Matthew Beno, Safety Coordinator 4. John Waldner, Refrigeration Maintenance Staff 5. Octavio Sanchez, Refrigeration Maintenance Staff 6. Devin Ermis, Maintenance Manager Page 1 of 5 Contact Email Address: mbeno@americanfoodsgroup.com Purpose of Inspection: Evaluate compliance with Part 68 - Chemical Accident Prevention Provisions Facility Type: Beef Harvesting Facility Regulations Central to Inspection: Part 68 - Chemical Accident Prevention Provisions Arrival Time of Virtual Inspection: 9:00 AM Departure Time of Virtual Inspection: 10:40 AM Arrival Time of On-Site Inspection: 1:55 PM Departure Time of On-Site Inspection: 2:10 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Provided CBI warning to facility The following information was obtained verbally from American Foods Group staff and a Part 68 program document review unless otherwise noted. Process Description: American Foods Group is the owner of the Green Bay Dressed Beef East River facility. Live animals are harvested, deboned, and shipped. The beef slaughtering process has an anhydrous ammonia refrigeration system that is a covered process subject to Part 68. The ammonia refrigeration system reutilizes anhydrous ammonia gas and fluid in a circular system. The ammonia is held in a high-pressure receiver as a liquid and pumped into evaporators, where the liquid is converted to gas. The gas is sent to the condenser in the engine room for the gas to be converted to liquid and sent to the high-pressure receiver. Staff Interview: American Foods Group opened the facility in 2003. The amount of ammonia on-site is 20,000 pounds in an ammonia refrigeration system. A 20,000-pound release from the high temperature recirculator was decided as the worst-case scenario. The alternative release scenario was a 1,300pound release from the largest safety relief valve on the high-pressure receiver that is piped to Page 2 of 5 atmosphere. The process hazard analysis and written operating procedures are stored and readily accessible in the refrigeration shop and on the computer. Evaluation of an employee's understanding of operating procedure training is through discussion. Maintenance staff only conducts the daily maintenance activities. Contractors handle the other maintenance tests and inspections. The facility maintains documents from the manufacturer for each piece of equipment, and sources in-kind maintenance materials, spare parts, and equipment through contractors. A recent change included a new cooler being added in 2020. When there is an emergency release, the alarm system detects the release. The employees are notified via radio and a staff member contacts the local fire department. The facility is a non-responder. The 2020 annual emergency response coordination activities were not conducted due to covid. The previous emergency contact retired last month, and the facility submitted corrected information within thirty days of the change. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA toured the facility and saw the five ammonia detectors, recirculator, compressors, highpressure receivers, two condensers, the water chiller, and the three emergency shutdown buttons outside each of the doors into the engine room. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Management structure 2. Off-site consequence analysis 3. Process safety information 4. Process hazard analysis 5. Operating procedures 6. Lockout-tagout procedures 7. Training documentation 8. Mechanical integrity records 9. Management of change documentation 10. Pre-startup safety reviews 11. Compliance audits 12. Incident investigation reports 13. Employee participation program 14. Hot work permits 15. Contractor policy information 16. Emergency response plans and meetings Page 3 of 5 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Safe upper and lower limits such as temperatures, pressures, flows, or compositions; and an evaluation of the consequences of deviation Initial process hazard analysis Community emergency response plan 2019 - 2021 emergency response coordination activities documentation Completed management of change form Concerns: In the management system, the responsibility for the process hazard analysis element of the Part 68 program was not assigned to a staff member. The Vice President of Operations oversees the Part 68 program but was not included in the management system documentation. Smaller quantities handled at higher process temperature or pressure were not documented in selecting the worst-case release scenario. The failure scenarios identified under 68.50, per 68.28(e)(2), need to be considered and documented in selecting the alternative release scenario. Documentation on the following was not available: assumptions and parameters used, and rational for the selection of specific scenarios. The process safety information does not contain an evaluation of the consequences of deviation. The process hazard analysis did not address a qualitative evaluation of a range of the possible safety and health effects of failure of controls. The operating procedures do not include normal shutdown procedures and safety and health considerations, 68.69(a)(3)(i), (iii), (iv), and (v). Initial training was not provided to one of the staff employees involved in operating the process. Training on each standard operating procedure was not provided at least every 3 years, or more often if necessary. The facility has not documented that it followed recognized and generally accepted good engineering practices for inspections and testing procedures. The facility has not documented that the frequency of inspections and tests of process equipment is consistent with applicable manufacturers' recommendations, good engineering practices, and prior operating experience. The community emergency response plan was not available during the inspection. There was no documentation on notifying emergency responders when there is a need for a response. The facility has not maintained a written record of each notification exercise conducted over the last five years. The facility has not periodically evaluated the performance of the contractor in fulfilling their obligations as described at 68.87(c)(1)-(c)(5), according to 68.87(b)(5). Page 4 of 5  The facility stated that it has not conducted notification exercises. DIGITAL SIGNATURES Digitally signed by VICKY VICKY MEI Date: 2022.09.22 MEI Report Author: ______________11_:2_3:_22_-_05_'00_' ____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2022.09.22 _N__a_th__a_n_______17_:0_9:_47_-_05_'00_' _____________ Page 5 of 5 General: General: General: - - : : : . : . : : : : : : 55. 56 57 : 58 59 60 61 ] : 62 63 64 65 66