Document G6B6VkRNy4vbqbwzpNbeyaM2q

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Inspection Report FACILITY INFORMATION: Name: Sitka Sound Seafoods Physical Address: 329 Katlian Street, Sitka, AK 99835 Phone Number: (907) 747-6662 Latitude/Longitude: 57.052722 / -135.335056 RMP Facility ID# 1000 0018 2811 FRS ID#: 110000730193 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Tim Ryan Phone Number: (907) 747-6662 E-mail: tryan@npsi.us EMERGENCY CONTACT INFORMATION: Name: Tim Ryan Phone (24-hr): (907) 738-6660 E-mail: tryan@npsi.us Website: www.northpacificseafoods.com TRIP DETAILS: Inspection Date: September 20, 2022 Inspection Time: 0900 hours through 1600 hours EPA Inspection Team: Peter Phillips, EPA Region 10, Lead RMP Inspector Terry Garcia, EPA Region 10, RMP Inspector Edward Johannes, EPA Region 10, RMP Inspector Mike Wolski, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: June 22, 2003 Date of Latest Update: August 22, 2019 Page 1 of 6 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID NAICS Code 1000102584 Refrigeration 1000128535 System 31171 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664- 41-7) Quantity (lbs) 22,834 PURPOSE: The purpose of this inspection was to determine whether this facility is in compliance with Section 112(r) of the Clean Air Act (CAA) and Title 40 of the Code of Federal Regulations (CFR) Part 68, Chemical Accident Prevention Provisions. The facility has been previously inspected in the past 5 years: No Yes The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? No Yes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 2/10/2022 No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 2/10/2022 INSPECTION ENTRY: Peter Phillips led the EPA Inspection Team (EPA) in the inspection entry at the Sitka Sound Seafoods facility in Sitka, Alaska (the facility). Alaska Department of Environmental Conservation (ADEC) representative Kathy Shea accompanied EPA during the inspection. EPA arrived at the facility at 0900 hours and was joined by the following facility personnel: Name Cassady Surfleet Margaret DeGravelle Gordon L. Grant Kendall Didrickson Bill Grant Title EHS Intern Environmental Compliance Officer EHS Coordinator Chief Engineer Plant Manager Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: Kathy Shea, ADEC No Yes The facility is a first responder: If No, Responding Agency: Sitka Fire Department No Yes Page 2 of 6 Facility representatives escorted EPA to a conference room located in the facility's office building. Lead inspector, Peter Phillips, introduced all parties present, provided a summary of the risk management program (RMP), and explained the purpose of the visit. Each EPA Inspector presented his/her credentials. Facility representatives Margaret DeGravelle and others at the meeting gave a brief description of the facility, operations, and personal protective equipment (PPE) required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives (such as a union representative) have the right to participate in the RMP inspection, that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: No Yes An employee representative present during the facility visit: No Yes GENERAL INFORMATION: The facility is regulated under the RMP as a Level 3 facility and is operated by Sitka Sounds Seafoods, a subsidiary of North Pacific Seafoods. The facility produces fresh and frozen seafood products such as salmon, herring, crab, herring roe, halibut, and black cod, and utilizes an anhydrous ammonia refrigeration/freezing system to process and preserve the seafood products. Two engine rooms support the facility's single refrigeration system, which utilizes 22,834 pounds of anhydrous ammonia. Two high pressure receiver (HPR) tanks for the refrigeration system are located at an exterior area of the facility property. The facility was built in the late 1960s and began seafood processing operations as Sitka Sounds Seafoods. Operations expanded in the late 1980s and early 1990s, and North Pacific Seafoods fully acquired the facility in 1997. The facility added an Icehouse in 2018. There are 170-180 full time employees on site during peak operations, including three operators who oversee the RMP regulated processes at the facility. Staff supports the ammonia refrigeration system 24 hours a day, seven days a week while the facility is in operation. ON-SITE OBSERVATIONS: EPA and ADEC toured the facility from approximately 0900 hours to 1600 hours, escorted by facility representatives. EPA inspected exterior and interior areas of the facility, including the Icehouse, Bait Room, one Cool Room, Engine Room 1, Engine Room 2, blast freezers and plate freezer areas, Holding Room 1, and other refrigeration system components at exterior areas of the facility property. EPA observed exterior overhead ammonia lines which carry anhydrous ammonia to different areas of the facility (photos 1-2) and noted a windsock at the facility exterior (photo 3). EPA inspected the facility Icehouse. Exterior areas of the Icehouse include an emergency stop (E-Stop) for refrigeration system processes (photo 4) and hazard communication signage on the Icehouse access door (photo 5). EPA inspected refrigeration system components inside the Icehouse including ammonia lines, ammonia detectors, E-Stops, and ice machines (photos 6-13). EPA inspected climate-controlled rooms supported by the facility refrigeration system. A fifteen ton evaporator cools the Bait House (photo 14), and a 7.5 ton evaporator supports the Cold Room (photo 15). Page 3 of 6 EPA inspected Engine Room 1, which is locked and accessible to select authorized personnel. EPA observed a hazard communication signage posted on the access door and an shower/eye wash station at the exterior of Engine Room 1 (photo 16), as well an emergency vent switch, emergency cross over, three emergency shunt trips, and an ammonia alarm (photo 17). EPA observed an shower/eye wash station inside Engine Room 1 (photo 18). Refrigeration system components in Engine Room 1 include five compressors, ammonia lines and valves, one ammonia detector and alarm, the refrigeration system control panel (photos 19-25), and one low pressure receiver tank (LPR). Pressure release valve (PRV) tags showed PRVs as installed in August 2020 (photo 24). A control panel in Engine Room 1 controls the refrigeration system (photo 26), and maintenance is logged and managed on hardcopy forms (photo 27). Two inlet vents and two outlet vents provide ventilation to Engine Room 1 (photo 28). Two high pressure receiver tanks (HPRs) located at the exterior of the facility support the facility refrigeration system. The first HPR designated as HPR 1 supports both engine rooms and the single refrigeration system at the facility (photo 29). The second HPR designated as HPR 2 provides additional storage for anhydrous ammonia (photo 30). EPA inspected Engine Room 2, which features two access doors accessible by select authorized personnel (photos 31-32). EPA observed a hazard communication signage posted on both access doors, as well as an shower/eye wash station, emergency switches for refrigeration and ventilation, and an ammonia alarm at the exterior of Engine Room 2 (photo 32). One inlet vent and one outlet vent provide ventilation for Engine Room 2 (photo 33). An emergency shunt trip supporting all facility operations is located at the exterior of Engine Room 2 (photo 34). A second shower/eye wash station is located inside Engine Room 2 (photo 35). Refrigeration system components in Engine Room 2 include two compressors, ammonia piping and valves, and an ammonia detector (photos 36-39). EPA observed the ammonia detector in Engine Room 2 as out of operation (photo 38), and service tags on pressure relief valves as dated January 2020 (photo 39). Facility representatives stated that a repair order was in place for the ammonia detector. EPA inspected several refrigeration system components and safety features at exterior areas of the facility near Engine Room 2, including the facility ammonia valve manifold and crossover piping (photo 40), an exterior shower/eye wash station and exterior ammonia alarm (photos 41-42), and the accumulator and associated pump shutdown for the facility (photo 43). EPA also observed three evaporator condenser units (photo 53), ammonia piping and valves supporting the evaporator units (photo 54), and the vent to atmosphere pipe from Engine Room 2 (photo 55). EPA inspected interior areas of the facility where blast freezers and plate freezers process seafoods. The facility operates eight blast freezers, six of which are supported by 60-ton evaporators and two supported by 40-ton evaporators (photos 47-49). Two plate freezers at the facility provide flash freezing of seafoods (photos 48). EPA inspected freezer system components including ammonia piping, compressors, a system control panel, and an ammonia leak detector (photos 48-52). The plate freezer control panel is located on a mezzanine in the plate freezer area (photo 50), and ammonia detection components are located at a lower level in the room. EPA inspected the Holding Room which holds finished seafood products at minus 15 degrees Fahrenheit (photos 51-52). EPA also toured the welding gas storage area holding chemicals reportable under Tier II Rule. EPA observed argon, oxygen, and acetylene cylinders as properly labeled and secured (photo 56). Page 4 of 6 Photographs were taken of the anhydrous ammonia process. Photographs taken during the inspection are included in Attachment A to this report. After touring the RMP-covered process areas at the facility, EPA returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Kendall Didrickson, Bill Grant, Gordon Grant, Margaret DeGrevelle, Cassady Surfleet and Eric Pangburn, with Kathy Shea of ADEC also present. INFORMATION COLLECTED FROM FACILITY: 1. North Pacific Seafoods, Inc /Sitka Sounds Seafoods SPCC Plan Attachment 7 2. Compliance Audit April 2018 Recommendation Table 3. Management Responsibilities for RMP/PSM 4. Documentation of Employee Participation (blank form) 5. Invoice (Double Kold/Sitka Sounds Seafood) for 5-year Mechanical Inspection dated 9/22/22 6. Email Quote for 5-year Mechanical Audit dated 9/9/22 AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Mechanical Integrity: Sitka Sound Seafoods was unable to provide training documentation for each employee involved in maintaining the on-going integrity of process equipment. [68.73(c)]. 2. Compliance Audits: Sitka Sound Seafoods' 2018 Compliance Audit report was not certified for evaluating compliance. [68.79(a)]. 3. Compliance Audits: Sitka Sound Seafoods' 2018 Compliance Audit report did not document an appropriate response to each of the findings (approximately 18 items) of the audit and document that deficiencies have been corrected. [68.79(d)]. 4. Contractors: Sitka Sound Seafoods was unable to provide documentation on evaluating information regarding the contract owner or operator's safety performance and programs when selecting a contractor such as Doubl-Kold and Sitka Electric. [68.87(b)(1)]. 5. Emergency Response: Sitka Sound Seafoods was unable to provide emergency response coordination documentation with local emergency responders for the years 2018, 2019, 2020 and 2021. [68.93]. DOCUMENTS REQUESTED INCLUDED IN REPORT: The following documents were requested during or after the inspection but are included in this report. These documents were reviewed to determine compliance with Section 112(r) of the Clean Air Act. The following information from the facility was received via email on 10/12/2022. Document Requested PSI - Process chemistry PSI - Safe upper and lower limits of equipment PSI - Evaluation of the consequences of deviation PSI - a discussion of safety systems PHA - 15 items (purchase labels) scheduled for 2020 ER - coordination meetings since 2021 Training summary form completed. SOP - Safety Systems and Functions 68.69(a)(4) Engine Room 2 Detector - Non-functional: provide documentation to show equipment orders in progress Status Provided and evaluated as satisfactory Provided and evaluated as satisfactory Provided and evaluated as satisfactory Provided and evaluated as satisfactory Purchase order submitted. Not provided Completed Issue was clarified Purchase order submitted. Page 5 of 6 INSPECTION REPORT CERTIFICATION: This is to certify that I, Peter Phillips, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 6 of 6