Document EdDY6qgxyxGQ05GJL3d91Lp9V

SENT VIA ELECTRONIC MAIL Hailey Ramirez Director of Warehouse Operations Al Alabama DC LLC 30800 CR-49 Loxley, Alabama 36551 Hailey.Ramirez@aldi.us Dear Hailey Ramirez: 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 12, 2024, partial compliance inspection of the Al Alabama DC LLC facility, located at 30800 CR-49 Loxley, Alabama, 36551. The EPA previously sent a copy of the draft report in an email on February 5, 2025, allowing Al Alabama DC LLC 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 14, 2025, the Al Alabama DC LLC, 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. Enclosure Sincerely, PHYLLIS WARRILOW Digitally signed by PHYLLIS WARRILOW Date: 2025.02.19 13:55:11 -05'00' 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: Al Alabama DC LLC Location (Address): 30800 CR-49, Loxley, Alabama 36551 Inspection Date: December 12, 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: 3601756355 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. Hailey Ramirez, Director of Warehouse Operations 2. Heidi Streiber, Warehouse Operations Manager 3. Troy Fung, Maintenance Tech 4. Dereck Barnard, Maintenance Tech Report Prepared by: Phyllis Warrilow Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 16 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 445110 - Supermarkets and other grocery retailers (except convenience retailers). 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 Al Alabama DC LLC (Facility) is located at 30800 CR-49, Loxley, Alabama 36551, Loxley, Alabama is classified under NAICS Code 445110 - Supermarkets and other grocery retailers (except Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 16 convenience retailers). The Al Alabama DC LLC facility was commissioned in 2022 and has been in operation since that time. It is located on a 150 acre site and supports stores in the south east United States. The facility includes cold and ambient storage with a total of 564,000 square feet of operations comprised of 250,000 square feet of refrigerated/freezer space and the balance used as dry storage warehouse and regional office space. The facility operates 361 days per year, with 7-day work weeks and 2 shifts plus maintenance per day. The facility employs approximately 160 persons. The facility uses an ammonia refrigeration system to cool inventory and product. The facility had 7,005 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 12, 2024, at approximately 9:05 AM Central Time The EPA Inspector presented credentials to: Hailey Ramirez, Director of Warehouse Operations Heidi Streiber, Warehouse Operations Manager Troy Fung, Maintenance Tech Dereck Barnard, Maintenance Tech Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 16 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 9:27 AM Central Time 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 Aldi Inc., Loxley Division 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. Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 16 Activity 4. Discussed safety issues. Yes No NA Y Comments The inspector discussed Facility-specific safety and emergency procedures. Ear plugs, safety glasses, coats, gloves, shoe, and hair coverings were provided as needed. 5. Discussed which records to be Y reviewed. 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). Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 16 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 Activity 8. Discussed the use of the infrared camera, TVA, PID, and any other equipment. 9. Discussed CBI. Yes No NA N/A Y Comments EPA inspectors indicated that any documents claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 16 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: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 16 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 four compressors. Compressors 1,3,4 and 5 were operating at time of the inspection. Compressors 2 and 3 are swing compressors. At approximately 10:37 AM on Dec 12, 2024: Compressor Number 1 was observed to be operating at a discharge pressure of 150 PSIG and a suction pressure of 3 PSIG. Compressor Number 3 was observed to be operating at a discharge pressure of 150 PSIG and a suction pressure of 3 PSIG. Compressor Number 4 was observed to be operating at a discharge pressure of 150 PSIG and a suction pressure of 19 PSIG. Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 16 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: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 16 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 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 As part of the walk through at approximately 10:30 am on Dec 12, 2024, the EPA inspector observed ammonia detectors in the machine room and throughout the facility. The facility operates 12 ammonia detectors. The last calibration of the ammonia sensors occurred August 21, 2024. The pressure safety relief valves in the machine room were current and will expire in August 2027, they were installed in August of 2022 when the facility was commissioned. Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 16 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). Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 16 Comments Activity 21. Were any visible emissions observed? (if yes, identify the location and equipment). Yes No NA N/A 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? 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: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 16 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 The closing meeting was conducted starting at 11:30 AM on December 12, 2024. Attendees were the EPA inspector and Hailey Ramirez, Director of Warehouse Operations Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 16 Activity 30. Summarize any additional information needed, if applicable? 31. Accept a declaration of CBI, if applicable? Yes No NA Y N/A Comments Facility had all requested documents except for the Process Hazard Analysis. Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 14 of 16 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 not given at time of inspection. Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 15 of 16 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 N/A 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 12, 2024, at approximately 11:50 AM the Region 4 inspector left the Facility and concluded the inspection. Process Hazard Analysis for the ammonia refrigeration system was not presented at the time of the inspection. EPA Investigator/Inspector Signature:__P_H__Y_L__L_IS__W__A__R_R__IL__O_W___D_a_te_: 2_0_25_.0_2._19_1_3:_56:18 -05'00' Digitally signed by PHYLLIS WARRILOW EPA Supervisor Signature & Title Digitally signed by TODD _T_O_D__D__G_R__O_E_N__D__Y_K_E__G_RO_E_N_D_YK_E_________ Date: 2025.02.19 14:19:38 -05'00' ___________________________________ Date Report Finalized: __2/19/2025_ Project Name: Aldi Inc. Loxley Division ICIS/Project No. 3601756355 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 16 of 16 APPENDICES AND ATTACHMENTS Appendix A: Document Receipt Log No documents were obtained from Facility representatives during the on-site inspection.