Document EmDXM5yL469kGG5zVg08X24b4

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Sanderson Farms, LLC Flowood, Mississippi September 13, 2023 1.0 Introduction The U.S. Environmental Protection Agency's (EPA) 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 Sanderson Farms, LLC (Sanderson Farms) facility located in Flowood, Rankin County, Mississippi. This facility was selected for inspection because it had never been inspected under the RMP. The inspection, which was conducted on September 13, 2023, 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. Requested 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 Sanderson Farms facility is located in Flowood, Mississippi. The facility uses anhydrous ammonia as a refrigerant to store food products for distribution. The refrigeration process, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for cold food storage. The process is regulated as program level 3. According to facility records, the facility has a maximum of 36,861 pounds of anhydrous ammonia 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: Justin Stark, EPA Inspector: Laura James, Mississippi Department of Environmental Quality (MDEQ) Inspector: Riley Moss, MDEQ Date of Facility Visit: September 13, 2023 Facility Identification Name: Sanderson Farms, LLC Street Address: 4418 Magnum Drive City: Flowood County: Rankin EPA Facility ID No: 100000088638 Dun & Bradstreet (D&B) No: 96043708 Latitude: 32.320556 Longitude: -090.104167 State: Mississippi Zip: 39208 Name, address and phone of corporate parent company: Owner/Operator: Sanderson Farms, LLC Mailing Address: 127 Flynt Road City: Laurel State: Mississippi Zip: 39443 Phone: (601) 649-4030 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Mickey Kelly Title: Operations Manager Phone: (601) 939-9790 Email: mickey.kelly@waynesanderson.com Name and title of emergency contact: Name: Mickey Kelly Title: Operations Manager Day phone: (601) 939-9790 24-hour Phone: (601) 718-7973 Email: mickey.kelly@waynesanderson.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: DeWayne Woodard Title: Assistant Operations Manager Phone: (601) 939-9790 Email: Dwayne.woodard@waynesanderson.com Name: Aaron Henderson Title: Health & Safety Manager Phone: (601) 939-9790 Email: aaron.henderson@waynesanderson.com Page 2 of 6 Sanderson Farms, LLC, Flowood, MS CAA 112 (r), Risk Management Program, Inspection Report Name: Darryl Harris Title: Maintenance Manager Phone: (601) 622-8464 Email: Darryl.harris@waynesanderson.com Name: Shannon Franklin Title: Environmental Manager Phone: (601) 832-0095 Email: shannon.franklin@waynesanderson.com Name: Anthony Smith Title: Refrigeration Phone: (601) 739-1138 Email: anthony@yahoo.com Name: Chris Eavenson Title: Regional Safety Manager Phone: (601) 319-2804 Email: Christopher.eavenson@waynesanderson.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: June 21, 1999 Date of most recent submissions: March 21, 2023 Process: Ammonia Refrigeration Process ID: 1000130427 Program Level as reported in RMP: 3 NAICS code: 311991 (Perishable Prepared Food Manufacturing) 3.0 Observations The inspection of the Sanderson Farms 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 began with an opening discussion of facility operations. The discussion was followed by a tour of the facility's ammonia refrigeration process areas. EPA inspectors then requested paperwork associated with the facility's Risk Management Plan (RMPlan). The documents were reviewed by EPA inspectors on-site and provided for review off-site. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Sanderson Farm facility are discussed below: Page 3 of 6 Sanderson Farms, LLC, Flowood, MS CAA 112 (r), Risk Management Program, Inspection Report 1. 40 C.F.R. 68.65(d)(2) requires the owner or operator to document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP). During the facility walkthrough, the inspection team noted the emergency shutoff valve (King Valve) on top of the high-pressure receiver just outside of the engine room was not labeled. o American National Standards Institute/International Institute of Ammonia Refrigeration (ANSI/IIAR) 2 Section 5.14.4 states, "Valves listed as emergency shut off valves in the system emergency shutdown procedure shall be clearly and uniquely identified at the valves themselves and in the system schematic drawings." o ANSI/IIAR 9 Section 7.2.9.3 states, "Valves required for emergency shutdown of the system shall be clearly and uniquely identified at the valve itself and in the system schematic drawing." During the facility walkthrough, the inspection team noted some insulation on ammonia pipes associated with the outdoor equipment was torn or gaping at the seams, exposing the pipes underneath to moisture. o ANSI/IIAR 2 Section 5.10.1 states, "piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup." o ANSI/IIAR 9 Section 7.2.6.1 states, "Piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system." During the facility walkthrough, the inspection team noted corrosion, rust, and pitting on piping and valve groups associated with the outdoor ammonia equipment. o ANSI/IIAR 6 (2019) Section 11.1.1 states, "Where pitting, surface damage, general corrosion, or a combination thereof, is visually observed on a metal surface of the piping, deficient areas shall be further evaluated per Sections 11.1.1.1 - 11.1.1.3." ANSI/IIAR 6 (2019) Section 11.1.1.1 states, "Where pitting, surface damage, general corrosion, or a combination thereof, has materially reduced the remaining pipe wall thickness, the piping remaining wall thickness shall be measured using appropriate techniques." Page 4 of 6 Sanderson Farms, LLC, Flowood, MS CAA 112 (r), Risk Management Program, Inspection Report  ANSI/IIAR 6 (2019) Section 11.1.1.2 states, "Where pitting, surface damage, general corrosion, or a combination thereof, has not materially reduced the remaining pipe wall thickness, the piping metal surface shall be cleaned and recoated to arrest further deterioration." ANSI/IIAR 6 (2019) Section 11.1.1.3 states, "Where pitting, surface damage, general corrosion, or a combination thereof, has materially reduced the remaining pipe wall thickness beyond the owner's established acceptance criteria, the piping shall be evaluated to determine suitability for continued operation." During the facility walkthrough, the inspection team noted excessive ice buildup on some of the pipes and valve groups associated with the outdoor ammonia equipment. Excessive ice buildup may interfere with turning valves and can add weight, compromising the structural integrity of the pipes. There was also ice underneath some of the insulation. Moisture trapped under insulation may accelerate corrosion of pipes. o ANSI/IIAR 6 Section 5.6.8 states, "Equipment and piping shall be kept free from excessive ice buildup. 5.6.8.1 Ice buildup shall not interfere with the operation of emergency shutoff valves. 5.6.8.2 Ice accumulation shall not be permitted to deflect or bend pipes, displace components, or negatively impact the system's structural integrity." o Table 11.1 (Piping Inspection, Testing, and Maintenance Tasks) in ANSI/IIAR 6 requires annual visual inspections for damage or moisture incursion in insulation (i.e. dampness, condensation, frost, ice buildup). 2. 40 C.F.R. 68.87(c)(3) requires the contract owner or operator to document that each contract employee has received and understood the training required by 40 C.F.R. 68.87. The contract owner or operator shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training. When asked for by the inspection team, facility representatives could not produce any documentation demonstrating the method of training contract employees. Page 5 of 6 Sanderson Farms, LLC, Flowood, MS CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, Prepared by: Digitally signed by JORDAN JORDAN NOLES NOLES Date: 2023.10.27 15:22:26 -04'00' ____________________________ Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER _______________________D_at_e_: 2_0_23_._10_.3_0_1_1_:2_2_:1_3_-0_4_'0_0' Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4 Page 6 of 6 Sanderson Farms, LLC, Flowood, MS CAA 112 (r), Risk Management Program, Inspection Report