Document MJzGYw1xGGNVoGaxjGB3w7d1y

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 8/21/2024-8/23/2024 Air Clean Air Act (CAA) 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Risk Management Plan (RMP) Program 3 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Hillshire Brands Company Hillshire Brands Company 3900 Meacham Boulevard Haltom City, TX 76117 3900 Meacham Boulevard Haltom City, TX 76117 Tarrant Graham Hancock 817-427-7970 graham.hancock@tyson.com Plant Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: 110033023163 1000 0009 4122 1000115441 311612 Meat Processed from Carcasses Personnel participating in inspection: Blake Sieminski Lead Inspector/Enforcement Officer John Penland Enforcement Officer Todd Hutson Environmental Manager Shaun Thompson Sr. PSM/RMP Area Manager Patrick Schuster Maintenance Manager Maribel Cruz PSM Coordinator Victor M. Irigoyen Safety Manager Eric Rodriguez Sr. Environmental Manager Graham Hancock Plant Manager Ron Black CI Manager Matthew Hernandez Logistics Manager U.S. EPA U.S. EPA Tyson Foods Tyson Foods Tyson Foods Tyson Foods Tyson Foods Tyson Foods Tyson Foods Tyson Foods Tyson Foods EPA Lead Inspector Signature/Date Supervisor, ECDSC Signature/Date 6ENFORM-019-R8.2 (02/12/2020) Digitally signed by BLAKE BLAKE SIEMINSKI SIEMINSKI Date: 2024.10.29 10:40:04 -05'00' Blake Sieminski Date SAMUEL TATES Date: 2024.10.29 10:46:37 -05'00' Digitally signed by SAMUEL TATES Samuel Tates Date 1 Hillshire Brands Company Inspection Dates: 08/21/2024 - 08/23/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTON I, Blake Sieminski and John Penland, the Environmental Protection Agency (EPA) Region 6 inspectors arrived at the Hillshire Brands Company Facility at approximately 9:00 a.m. on August 21, 2024, for an announced inspection. I met with Hillshire Brands Company (Hillshire) facility representatives at the opening meeting. I presented my credentials and informed them that this was an EPA led inspection to determine compliance with the Clean Air Act (CAA) Section 112(r). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the compliance with 40 C.F.R. Part 68 - Chemical Accident Prevention Provisions, CAA Section 112(r)(7), and the General Duty Clause (GDC), CAA Section 112(r)(1). FACILITY DESCRIPTION Hillshire Brands, Haltom City, Texas plant is engaged in the wholesale production of corn dogs for human consumption. Raw materials received are beef, pork franks, turkey franks, corn, flour, sugar, cooking oil, sticks, and packaging materials. The corn dogs are processed, cooked, frozen, packaged, and stored for shipment. The facility processes beef franks from frozen beef but does not handle live animals or carcasses. The facility is located at 3900 Meacham Blvd. Haltom City, Texas 76117. The NAICS code is 311612 (meat processed from carcasses. Normal hours of operation are 5:45 a.m. to 11:15 p.m., six days per week. Normal hours for sanitation operations are 11:15 p.m. to 5:45 a.m., six days per week. The facility currently has 760 full time employees onsite, including plant and administrative personnel. Section II - OBSERVATIONS We conducted a walk-through of the facility, accompanied by facility representatives, to observe the facility process equipment, and overall operations. I used the Forward Looking Infrared (FLIRTM) Series GF320 camera, and observed no spills, leaks, or fugitive hydrocarbon emission trails. Other inspection findings and observations are noted in the RMP Program Level 3 Checklist, located in Appendix #1. During the walk-through, I observed that the facility was missing proper markings on piping - e.g., direction of flow, color-coding to identify the hazardous material present, placement of pipe labels, and type and size of letters on pipe labels, as required by the American National Standards Institute (ANSI) and the American Society of Mechanical Engineers (ASME) Standard ANSI/ASME A13.1, Scheme for the Identification of Piping Systems. This standard is considered a recognized and generally accepted good engineering practice for above ground piping systems [AOC 1: 68.65(d)(2)]. Closing Meeting - EPA convened a closing meeting on August 23, 2024, to discuss the Areas of Concern (AOC) noted during the inspection, the inspection completion process, and to answer questions from plant representatives. Section III - AREAS OF CONCERN 1. 40 C.F.R. 68.65(d)(2)- Process safety information. (d)(2) The owner or operator shall ensure and document that the process is designed and maintained in compliance with recognized and generally accepted good engineering practices. Hillshire Brands Company failed to properly label and maintain the equipment and associated piping as required by ANSI/ASME Standard A13.1, Scheme for the Identification of Piping Systems. 2 Hillshire Brands Company Inspection Dates: 08/21/2024 - 08/23/2024 2. 40 C.F.R. 68.73(d)(1)- Mechanical Integrity (d)(1) - Inspections and Testing. Inspections and tests shall be performed on process equipment. Hillshire Brands Company failed to completely fill out the daily shift log sheet on December 30, 2022. Out of 180 potential inspection response, zero were selected. 3. 40 C.F.R. 68.73(d)(4)- Mechanical Integrity (d)(4) - The owner or operator shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. Hillshire Brands Company failed to document and correctly identify person who performed the inspection on process equipment. Specifically on the daily shift, an individual named Max signed the document as the individual conducting the inspections. However, this was not the name of the person conducting the inspection. During the document review it was explained that Max was a nickname for another individual and that was seen throughout multiple other documents during the inspection. 4. 40 C.F.R 68.85(b)- Hot work Permit (b) The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. Hillshire Brands Company failed to complete authorized hot work permits. Specifically, multiple hot work permits were missing review and closure signatures. Copies of the hot work were provided showing carbon copies of the forms were being filled out after the initial copy was separated. 5. 40 C.F.R. 68.90 - 68.96- Emergency Response 68.93(b) - Emergency response coordination activities. Coordination shall include providing to the local emergency planning and response organizations: The stationary source's emergency response plan if one exists; emergency action plan; updated emergency contact information; and other information necessary for developing and implementing the local emergency response plan. For responding stationary sources, coordination shall also include consulting with local emergency response officials to establish appropriate schedules and plans for field and tabletop exercises required under 68.96(b). The owner or operator shall request an opportunity to meet with the local emergency planning committee (or equivalent) and/or local fire department as appropriate to review and discuss those materials. Hillshire Brands Company failed to provide the local emergency planning and response organization with an Emergency Action Plan that accurately represents their facility. Specifically, Hillshire submitted an Emergency Action Plan to the LEPC on 8/15/24 and that plan incorrectly identified SOPs that were not applicable to the subject facility and it's covered process. 3 Section IV - FOLLOW UP Hillshire Brands Company Inspection Dates: 08/21/2024 - 08/23/2024 There were no additional records requested and no additional follow up for this inspection. Section V - LIST OF APPENDICES Appendix #1 - RMP Program 1 Checklist Symbol Key: Y - Yes, N - No, N/A - Not Applicable; S - Satisfactory, M - Marginal, U - Unsatisfactory. 4 Tyson Foods/Hillshire Bands Company Inspection Date 08/21/2024 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Hillshire Brands Company City: Haltom City County/Parish: Tarrant State: TX UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Hillshire Brands Company City: Haltom City County/Parish: Tarrant State: TX UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Hillshire Brands Company City: Haltom City County/Parish: Tarrant State: TX