Document DrLa8x4meYNoqjyXpm0G3ZrB

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Unilever Covington, Tennessee August 17, 2021 1.0 Introduction The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA. The focus of this inspection was to assess the RMP for the ammonia refrigeration process at the Unilever facility located in Covington, Tipton County, Tennessee. This facility was selected for inspection because it had never been inspected under the RMP. The inspection, which was conducted on August 17, 2021, consisted of an examination of program documentation as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Program documents were provided for further review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Unilever facility is located in Covington, Tennessee. The facility uses anhydrous ammonia as a refrigerant to produce and store ice cream and frozen dessert products. The process is regulated as program level 3. According to facility records, the facility has a maximum of 198,170 pounds of ammonia (anhydrous) on site. The ammonia refrigeration process at the facility is subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1. TABLE 1: Inspection Information Summary Inspection Team Lead Inspector: Jordan Noles, EPA Inspector-In-Training: Bethany Terpin, EPA Date of Facility Visit: August 17, 2021 Facility Identification Name: Unilever Street Address: 2000 Hwy. 51 North City: Covington County: Tipton EPA Facility ID No: 1000 0021 4993 Dun & Bradstreet (D&B) No: N/A Latitude: 35.613395 Longitude: -89.623921 State: Tennessee Zip: 38019 Name, address and phone of corporate parent company: Owner/Operator: Conopco, Inc. d/b/a Unilever Mailing Address: 800 Sylvan Avenue City: Englewood Cliffs State: New Jersey Zip: 07632 Phone: (201) 894-4996 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Sundi DiCarlo Title: SHE Manager Phone: (615) 454-2213 Email: Sundi.DiCarlo@unilever.com Name and title of emergency contact: Name: Sundi DiCarlo Title: SHE Manager Day phone: (901) 867-6919 24-hour Phone: (901) 475-5160 Email: Sundi.DiCarlo@unilever.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Sundi DiCarlo Title: SHE Manager Phone: (901) 867-6919 Email: sundi.dicarlo@unilever.com Name: Jules Hinske Title: PSM Manager- Corporate Phone: (269) 832-0125 Email: jules.hinske@unilever.com Name: Drew Waits Title: Ammonia Maintenance Supervisor Phone: (901) 481-7442 Email: ruben.waits@unilever.com Page 2 of 5 Unilever, Covington, TN CAA 112 (r), Risk Management Program, Inspection Report Name: Jake McMackins Title: SHE Supervisor Phone: (901) 867-6714 Email: jake.mcmackins@unilever.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: July 20, 2011 Date of most recent submissions: June 5, 2017 Process as reported in RMP: Ammonia Refrigeration Process: Ammonia Refrigeration Process ID: 1000077731 Program Level as reported in RMP: 3 NAICS code: 31152 (Ice Cream and Frozen Dessert Manufacturing) 3.0 Observations The inspection of the Unilever facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 3) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection included an opening conference where EPA inspectors reviewed documents from the facility's Risk Management Plan, which were provided on a USB drive for further review offsite. The discussion was followed by a tour of the facility's ammonia refrigeration process areas. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Unilever facility are discussed below: 1. 40 C.F.R. 68.67(e) requires the owner or operator to establish a system to promptly address the team's findings and recommendations of the process hazard analysis in a timely manner, to complete the actions as soon as possible, and to communicate the actions to operating, maintenance, and other employees who work in the process and may be affected by the actions. o At the time of the inspection, Unilever's system to address the findings and recommendations of the process hazard analysis showed that most of the corrective actions were completed after the scheduled due date. There was no evidence that the system communicated the actions to operating, maintenance, and other employees who work in the process. 2. 40 C.F.R. 68.69(c) requires operating procedures to be certified at least annually that the procedures are current and accurate. o At the time of the inspection, many of the operating procedures had not been certified annually. Page 3 of 5 Unilever, Covington, TN CAA 112 (r), Risk Management Program, Inspection Report 3. 40 C.F.R. 68.73(d)(4) requires each inspection and test performed on process equipment to be documented and include the date of the inspection or test, the name of the person who performed the inspection or test, and the results of the inspection or test. o Though some records of inspections and tests did include some or all of these requirements, at the time of the inspection, each inspection or test on process equipment did not include the date of the inspection or test, the name of the person who performed the inspection or test, and the results of the inspection or test. 4. 40 C.F.R. 68.93(a) requires coordination with local emergency planning and response organizations to occur at least annually, and more frequently if necessary, to address changes: At the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan. o At the time of the inspection, Unilever did not provide evidence of annual coordination with local emergency planning and response organizations to address changes. 5. 40 C.F.R. 68.93(c) requires the owner or operator to document coordination with local authorities, including: The names of individuals involved and their contact information (phone number, email address, and organizational affiliations); dates of coordination activities; and nature of coordination activities. o At the time of the inspection, Unilever did not provide evidence of coordination with local authorities during the years 2019 and 2020. Page 4 of 5 Unilever, Covington, TN CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, Prepared by: Digitally signed by BETHANY BETHANY TERPIN TERPIN __________________________D_a_te: 2021.10._1_5_1_2_:0_7_:0_2__-0_4_'0_0_' Bethany Terpin, Inspector-In-Training Date North Air Enforcement Section U.S. EPA Region 4 JORDAN Digitally signed by JORDAN NOLES _N__O__L_E__S_______1_2_:1_1_:0_2_-0_4_'0_0_' ___ Date: 2021.10.15 Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 ______________ Date Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER ___________________________D_ate: 2021.10_.1_5_1_7_:0_7_:_5_2_-0_4_'_00_' Jason Dressler, Section Chief Date North Air Enforcement Section U.S. EPA Region 4 Page 5 of 5 Unilever, Covington, TN CAA 112 (r), Risk Management Program, Inspection Report