Document KeNvyvqr82OYdXZzVpnjDN42

Clean Air Act - Risk Management Program - Section 112(r) Emergency Planning Community Right-to-Know Act - Sections 302, 311 and 312 On-site Compliance Inspection Report DOT Foods, Inc. PURPOSE The purpose of this On-site Compliance Inspection was to determine compliance with the Clean Air Act Section 112(r) Risk Management Program (40 C.F.R. Part 68) and the Emergency Planning and Community Right to Know Act Sections 302, 311 and 312. CAA Section 112(r)(7) requires facilities that hold more than a threshold quantity of a regulated substance in a process to develop and implement a Risk Management Program. EPCRA Section 311 requires facilities that hold chemicals above reporting threshold to submit copies of the SDSs or a list of these chemicals to the State Emergency Response Commission, the Local Emergency Planning Committee and the local fire department. EPCRA Section 312 requires the Annual Chemical Inventory Reports (Tier II) for the current calendar year to be submitted by March 1 of the following year. The Tier II is required to be submitted to the SERC, LEPC and fire department. EPCRA Section 302 requires any facility that has any EHS above the threshold planning quantities to notify the SERC and LEPC. LEPCs should also include the EHS(s) in their emergency response plans. Facilities covered under EPCRA Section 312 are required to indicate on the Tier II if they are subject to EPCRA Section 302 emergency planning requirements. COMPANY INFORMATION Name: DOT Foods, Inc. Mailing Address: 1541 West 27th Street Burley, Idaho 83318 Website: www.dotfoods.com FACILITY INFORMATION Name: DOT Foods, Inc. Facility Address: 1541 West 27th Street Burley, Idaho 83318 Latitude/Longitude: 42.517844 / -113.811953 RMP Facility ID#: 100000208125 FRS ID#: 110041623703 EJ Concerns: No Page 1 of 6 CONTACT INFORMATION (RMP Implementation) Name: Anthony Soto Title: General Manager Phone Number: (877) 812-7192 E-mail: asoto@dotfoods.com EMERGENCY CONTACT INFORMATION Name: Mark Gratzer Title: Maintenance Manager Phone Number: (877) 812-7192 E-mail: mgratzer@dotfoods.com INSPECTION DETAILS Inspection Date: Thursday, September 19, 2024 Inspection Time: Start to Finish Inspectors: Peter Phillips, US EPA R10, SEE Grantee, Lead RMP/EPCRA Inspector Mhara Coffman, US EPA R10, RMP/EPCRA Inspector Edward Johannes, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Ryan Bowlsby, US EPA R10, RMP/EPCRA Inspector-in-Training On 9/4/2924, EPA emailed a Notice of Inspection Letter to the facility informing them of a planned RMP and EPCRA inspection. The letter included 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. A copy of the letter must be provided to the employee representatives and the letter posted in a manner accessible to employees in the facility. Is the facility is unionized? If yes, name of union: Was an employee representative present during the inspection? If yes, name/title: Yes No Yes No GENERAL INFORMATION The facility is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by DOT Foods, Inc. There are 347 full-time employees on site. DOT Foods, Inc. is a food redistributor that provides distribution services to other distributors, including those serving military installations. The facility was constructed in 2008. The facility's operations encompass the management of a diverse range of food products through refrigerated, frozen, and dry storage facilities. Key operational areas include a dry goods warehouse, a cooler area, a freezer area, and the engine room. DATE AND PROGRAM LEVELS OF SUBMITTED RMP Initial Submission Date: 6/9/2009 Date of Latest Update: 11/23/2022 Has the facility has been inspected in the past 5 years? If yes, date of last inspection: Yes No Page 2 of 6 Is the facility High Risk? Yes No Process (as reported in the RMP) Process ID Description 1000128342 Refrigerated Warehousing and Storage Process Chemical ID 1000160917 NAICS Code 49312 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs.) 12,870 CAA TITLE V AIR PERMIT Does the facility have a CAA Title V Permit? Yes No EMERGENCY RELEASE / ACCIDENT HISTORY Did an RMP reportable release occur in the past 5 years? Did a CERCA/EPCRA reportable release occur in the past 5 years? If either yes, date and description of release: Yes No Yes No EPCRA 312 - TIER II REPORT Was the 2024 Tier II report submitted to the SERC? If yes, date Tier II was submitted: 02/07/2024 Was the 2024 Tier II submitted to the LEPC/fire department? If yes, date Tier II was submitted: 02/07/2024 Is the facility subject to EPCRA Section 302? If yes, is it correctly checked on the Tier II? Is the subject to RMP correctly checked on the Tier II? Is RMP facility ID correct on the Tier II? Yes No Yes No Yes No Yes No Yes No Yes No EPCRA CHEMICALS OVER THRESHOLD According to the most recent Tier II, the facility stores the following hazardous chemicals over the reporting threshold. Chemical Name Ammonia, Anhydrous Diesel Fuel Lead Sulfuric Acid EHS (Yes or No) Yes No No Yes CAS Number 7664-41-7 68334-30-5 7439-92-1 7664-93-9 EPCRA 302 - LEPC Coordination The facility does not regularly participate in LEPC meetings. LEPC Agency: Program Contact: Address: Address 2: Phone Number: Cassia County LEPC Jennifer Gee 1459 Overland Avenue Burley, Idaho 83318 (208) 878-8610 Page 3 of 6 Email: Website: jgee@cassiacounty.org https://ioem.idaho.gov/county-and-tribal-emergency-managers-contact INSPECTION ENTRY Peter Phillips led the inspection entry. The inspection team met with Mark Gratzer at the DOT Foods, Inc. facility in Burley, Idaho. The team arrived at the facility at Start and was joined by the following facility personnel: Name Courtney Worthington Dan Callet Dustin Critchfield Jeffrey Dean Title Refrigeration Operator General Manager PSM Coordinator Quality Manager Were any SERC, LEPC or fire department representative present? Yes No Is the facility a first responder? Yes No If no, responding agency: Burley Fire Department, Cassia County Fire Department The inspection team was escorted to a conference room. Introductions were made by Peter Phillips, who provided a summary of the risk management program and explained the purpose of the visit. Each team member presented their credentials. EPA requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. The facility requested that EPA personnel wear eye and hearing protection, high-visibility vests, and closed-toe shoes. The facility operates 24 hours a day, 7 days a week. The facility has three operators and six maintenance personnel dedicated to managing and maintaining refrigeration systems and other critical processes. Operations are structured into two 10-hour shifts to ensure continuous functionality and efficiency. FACILITY TOUR / ON-SITE OBSERVATIONS The facility tour was conducted from approximately 9:25 A.M. to 10:15 A.M. The inspection team was escorted by Mr. Gratzer, Mr. Critchfield, Mr. Dean, and Ms. Worthington. Areas observed were the dry food area, cooler area, freezer area, and engine room. Dry Food Area: The facility currently operates approximately 30 battery-powered forklifts and has established a dedicated charging area for their maintenance within the dry food area (Photo 1). The facility has implemented an emergency shutdown mechanism for the battery chargers (Photo 2). Additionally, emergency shower and eyewash stations are readily available to ensure employee safety (Photo 2). The dry room does not have any anhydrous ammonia detectors, piping, or vessels. Page 4 of 6 Cooler Area: The cooler area contains three ammonia evaporators (Photo 4). Three ammonia detectors and green ammonia alarm strobes are present (Photos 5, 6 and 7). Ammonia pipe labeling signage indicating was displayed (Photo 3). Piping to the evaporators were labeled (Photo 4). Freezer Area: The freezer area contains three evaporators (Photo 8). Light icing was visible on some of the units. Two ammonia detectors are located in the area (Photo 9). Engine Room: The engine room contains three screw compressors (Photo 21), a low-temperature recirculator vessel (Photo 23), a high-temperature recirculator vessel (Photo 22), and a High Pressure Receiver (HPR) with a king valve (Photos 23 and 26). The valves for the low-temperature recirculator vessel have visible ice buildup and no labeling (Photo 23). The engine room interior entrance door has ammonia hazard placards and an authorized personnel only notice posted next to the door (Photo 16). An emergency shower is located by the entrance door (Photo 16). The refrigeration control panel, computer station, lockout/tagout station, P&IDs and process flow diagrams are located in the control room (Photos 17 to 20). Ammonia audio/visual alarm, emergency ventilation controls, and emergency shutdown button are located outside the engine room (Photo 17). The engine room ventilation system has three air intakes and ceiling exhaust fans (Photos 24 and 28). An emergency shower/eyewash station is located in the engine room (Photo 21). Ammonia piping in the engine room is labeled with flow directions and identifies ammonia (Photos 21, 22, 24, 29, and 31). Pressure relief valves (PRVs) for compressors were tagged with an install date of May 2023 (Photo 25). Push bars were observed on the engine room exit doors. Audio/visual alarms were observed in the engine room (Photo 30). The HPR has a manual king valve (Photo 26) and a gas king solenoid valve is located in the engine room (Photo 31). The condenser is located on the roof (Photo 14) and a windsock was observed (Photo 15). Three ammonia detectors are located in the engine room that activate the alarm at 25 ppm, initiates emergency ventilation at 150 ppm, and triggers a system shutdown, excluding ventilation, at 300 ppm (Photos 27 and 32). EPCRA Areas: Diesel is stored in a 500-gallon above-ground tank (Photo 10) and a 30,000-gallon underground tank (Photo 11). An emergency response trailer equipped with Level A suits and SCBAs is located in the parking lot (Photo 12). The facility participates in emergency preparedness drills, including a May 8, 2024, exercise with the Burbank Fire Department and a June 10, 2024, evacuation drill, demonstrating a proactive approach to safety and readiness. Photographs were taken of the covered process and other storage areas. The photographs are included in Attachment A. After touring the RMP-covered process areas and the EPCRA chemical storage areas, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to facility staff listed above. INFORMATION COLLECTED FROM FACILITY 1. Site map 2. Emergency Action Plan 3. Process flow diagram Page 5 of 6 AREAS OF CONCERNS No areas of concern were identified during the inspection. FOLLOW-UP DOCUMENTS REQUESTED The following documents were unable to be located during the inspection by the facility representatives. The documents were requested to be sent to EPA by 10/3/2024. These documents were reviewed after the inspection to determine compliance with Section 112(r) of the Clean Air Act. 1. 2022 PHA recommendations 2. 2020 Compliance Audit findings 3. 2023 Compliance Audit findings ON-SITE INSPECTION REPORT CERTIFICATION This is to certify that I, Peter Phillips, as the lead inspector for the On-site Compliance Inspection and that I have verified the accuracy of the information in this report. __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator Signature __________________________________________________________ EPCRA Coordinator Signature __________________________________________________________ Land Enforcement Section Manager Signature ATTACHMENTS A. Photo Log and Photographs Page 6 of 6 Attachment A Photo Log Site Name: DOT Foods, Inc. City, State: Burley, ID Photographer: Ryan Bowlsby File Photo1.jpeg Photo2.jpeg Photo3.jpeg Photo4.jpeg Photo5.jpeg Photo6.jpeg Photo7.jpeg Photo8.jpeg Photo9.jpeg Photo10.jpeg Photo11.jpeg Photo12.jpeg Photo13.jpeg Photo14.jpeg Photo15.jpeg Photo16.jpeg Photo ID 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Photo17.jpeg 17 Photo18.jpeg 18 Photo19.jpeg 19 Photo20.jpeg 20 Photo21.jpeg 21 Photo22.jpeg 22 Photo23.jpeg 23 Photo24.jpeg 24 Photo25.jpeg 25 Photo26.jpeg 26 Photo27.jpeg 27 Photo28.jpeg 28 Photo29.jpeg 29 Photo30.jpeg 30 Photo31.jpeg 31 Photo32.jpeg 32 Date 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 9/19/2024 Time 9:30 AM 9:31 AM 9:32 AM 9:33 AM 9:34 AM 9:35 AM 9:36 AM 9:37 AM 9:38 AM 9:39 AM 9:40 AM 9:41 AM 9:42 AM 9:43 AM 9:44 AM 9:45 AM 9:46 AM 9:47 AM 9:48 AM 9:49 AM 9:50 AM 9:51 AM 9:52 AM 9:53 AM 9:54 AM 9:55 AM 9:56 AM 9:57 AM 9:58 AM 9:59 AM 10:00 AM 10:01 AM Description Forklift charging and emergency shower Emergency shower and charger emergency stop Ammonia Pipe lableing diagram Evaporators in Cooler Area Ammonia detector in Cooler Area Red and green strobe light visual alarms Ammonia detector in Cooler Area Freezer room evaporator Ammonia detector in freezer room Diesel fuel storage Diesel fueling area for trucks Emergency response trailer Outside View of Warehouse Dock Area Roof condensers Windsock Engine room entrance door with hazcom signage and emergency shower Ammonia audio/visual alarm, emergency ventilation controls, and emergency shutdown button Refrigeration control panel Lockout/tagout station Process flow diagram in Control Room Compressors and emergency shower/eyewash station in engine room High Temperature Recirculator vessel and piping in engine room V-1 High Pressure Receiver (HPR) and V-3 Low Temperature Recirculator vessel Air intakes for engine room ventilation system Pressure relief valves (PRVs) with install/replacement tags for Compressor RC-2 Manual liquid ammonia king valve for HPR Ammonia detector in engine room Ceiling exhaust fan and LEL detector in engine room Ammonia piping with labeling Audio/visual alarms Ammonia gas king solenoid valve Ammonia detector