Document G8pXpqjz6edn69vz1ed88vKm

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 - Acme, 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 - Acme Facility Location: 544 Acme Street, Green Bay, Wisconsin 54302 Date of Virtual Inspection: September 19, 2022 Date of On-Site Inspection: September 21, 2022 EPA Inspector(s): 1. Vicky Mei, Environmental Engineer Other Attendees at the Virtual Inspection: 1. Nate Green, EHS Manager 2. Kevin Tschetter, PSM Maintenance Staff 3. Eric Johnston, PSM Director 4. Nick Ossi, Environmental Manager Other Attendees at the On-Site Inspection: 1. Nate Green, EHS Manager 2. Kevin Tschetter, PSM Maintenance Staff 3. Nick Ossi, Environmental Manager 4. Ryan Heintz, Maintenance Manager 5. Raul Colom, Refrigeration Maintenance Staff Contact Email Address: ngreen@americanfoodsgroup.com Page 1 of 5 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: 11:10 AM Arrival Time of On-Site Inspection: 1:00 PM Departure Time of On-Site Inspection: 1:40 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 through a Part 68 program document review unless otherwise noted. Process Description: American Foods Group is the owner of the Green Bay Dressed Beef Acme 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 into liquid and sent to the high-pressure receiver. Staff Virtual Interview: American Foods Group purchased the facility in 2006. The amount of ammonia on-site is 70,000 pounds in two ammonia refrigeration systems that are identical. Each system contains 35,000 pounds of ammonia. One system is on the west side and the other system is in a central location. Both systems were analyzed for off-site consequences. A release from the high temperature recirculator on the west system was decided as the worst-case scenario because its radius of impact encompasses the radius of impact from any release from the central system. The Page 2 of 5 residential population impacted would be 200, which was rounded up from 191. A revised Risk Management Program file was submitted within 6 months of when the engine room was added to the west machine room in 2020. The operating procedures are readily accessible in the refrigeration room to employees who are involved in a process. The control over entrance into the facility is maintained by the guard shack. The facility maintains documents from the manufacturer for each piece of equipment, and sources maintenance materials, spare parts, and equipment through contractors. The facility is a non-responder. Emergency coordination activities occur every 6 months with the local fire department, with the most recent coordination activity being on September 12, 2022. The annual emergency response coordination activities required under 68.93 were missed in 2020 due to covid. The last accident was a release on October 17, 2019. Staff On-site Interview: EPA interviewed a refrigeration staff member. The member verbally relayed that the preventative maintenance processes and process hazard analysis are reviewed every month. The standard operating procedures are reviewed throughout the year. The staff member said that the standard operating procedures are good and that the staff has input on the type of training that they want to receive. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA toured the facility on September 21, 2022 during the on-site inspection and saw four compressors in service, four compressors on stand-by, the water chiller, evaporator, water tank, high pressure receiver, recirculator, and evaporative condensers. 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 Page 3 of 5 13. Employee participation program 14. Hot work permits 15. Contractor policy information 16. Emergency response plans and meetings CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Process safety management meeting agendas Management of change template form Contractor safety review 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 process safety information does not contain the following information: safe upper and lower limits such as temperatures, pressures, flows, or compositions; and an evaluation of the consequences of deviation. The initial process hazard analysis was performed but not retained. The following factors were not considered in selecting the alternative release scenario: the five-year accident history provided in 68.42, and failure scenarios identified under 68.50. When a change resulted in a change in the process safety information and operating procedures or practices, no documentation using the facility's Management of Change template form was available. After the October 17, 2019 release, the incident report findings and recommendations were not promptly addressed and resolved. The report was not prepared until May 13, 2022. 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). The facility has not performed the annual emergency response coordination in 2018. Thus, the facility has not addressed changes: at the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community response plan. The facility stated that they informally conducted notification exercises, but the staff was not familiar with the notification process if there is a need for emergency response and there was no documentation. Page 4 of 5 DIGITAL SIGNATURES Digitally signed by VICKY VICKY MEI Date: 2022.09.22 MEI Report Author: ______________11_:0_8:_30_-0_5_'00_' ____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan _N_a_t_h_a_n_______1_6_:55_:2_5_-0_5'0_0_' _____________ Date: 2022.09.22 Page 5 of 5 General: General: General: - - : : : . : . : : : : : : 55. 56 57 : 58 59 60 61 ] : 62 63 64 65 66