Document QJDgLQoVLXEM99Zo5dR60nDyo

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report General Mills Yoplait Murfreesboro, Tennessee December 15, 2021 1.0 Introduction The U.S. Environmental Protection Agency's 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 an ammonia refrigeration process at the General Mills Yoplait facility located in Murfreesboro, Rutherford County, Tennessee. This facility was selected for inspection because it hasn't been inspected within the last five years under the RMP. The inspection, which was conducted on December 15, 2021, consisted of a discussion of and request for program documentation, as well as a site review of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Documents were provided by email for review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The General Mills Yoplait facility is located in Murfreesboro, Tennessee. This facility uses anhydrous ammonia for cold food storage. The process is regulated as program level 3. According to facility records, the facility can have a maximum of 18,250 pounds of anhydrous ammonia on site. The ammonia 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-In-Training: Bethany Terpin, EPA Date of Facility Visit: December 15, 2021 Facility Identification Name: General Mills Yoplait Street Address: 2695 General Mills Way City: Murfreesboro County: Rutherford EPA Facility ID No: 1000 0019 1062 Dun & Bradstreet (D&B) No: 1326438 Latitude: 35.798333 Longitude: -086.391667 State: Tennessee Zip: 37127 Name, address and phone of corporate parent company: Owner/Operator: General Mills Operations, LLC Mailing Address: 1 General Mills Blvd, MN City: Golden Valley State: Minnesota Phone: (260) 490-3000 Zip: 55426 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: James D Tincher Title: Plant Manager Email: david.tincher@genmills.com Name and title of emergency contact: Name: Josh Wagner Title: Safety Manager Day phone: (615) 225-1454 24-hour Phone: (615) 715-7307 Email: joshua.wagner@genmills.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Aaron Stewart Title: Sr. Facilities Engineer Phone: (615) 225-1451 Email: aaron.stewart@genmills.com Name: John DeCuir Title: Senior Project Manager Phone: (615) 225-1225 Email: john.decuir@genmills.com Name: Mark Holland Title: PSM Planner Phone: (615) 225-1901 Email: mark.holland@genmills.com Page 2 of 5 General Mills Yoplait, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report Name: Matt Martin Title: Utility Foreman Phone: (931) 703-1042 Email: matt.martin@genmills.com Name: Josh Wagner Title: HSE Manager Phone: (615) 715-7307 Email: joshua.wagner@genmills.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: March 14, 2005 Date of most recent submissions: July 29, 2020 Process as reported in RMP: Ammonia Refrigeration Process: Ammonia Refrigeration Process ID: 1000110211 Program Level as reported in RMP: 3 NAICS code: 31151 (Dairy Product (except Frozen) Manufacturing) 3.0 Observations The inspection of the General Mills Yoplait 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. EPA inspectors requested paperwork associated with the facility's Risk Management Plan (RMPlan) to be sent by email due to risks associated with the COVID-19 pandemic. The documents were later reviewed by EPA inspectors off-site. At the time of the drafting of this report, some documents may still be requested for further investigation. The discussion was followed by a tour of the facility's ammonia refrigeration system. An inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the General Mills Yoplait facility are discussed below: 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. At the time of the inspection, cardboard boxes, drums, buckets, and other combustible materials were found in the machinery room. ANSI/IIAR 2-2014 section 6.4 states, "Combustible materials or flammable liquids shall not be stored in machinery rooms outside of approved fire-rated storage containers." At the time of the inspection, the inspection team observed damaged and missing insulation on an ammonia pipe associated with one of the compressors in the Page 3 of 5 General Mills Yoplait, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report engine room. ANSI/IIAR-6, Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems states, "11.1.2 For insulated piping, where insulation is removed, partly or completely, for visual inspection or remaining wall thickness measurement(s), a protective coating shall be applied to the exposed metal surface and insulation shall be replaced in accordance with the manufacturer's installation instructions after arresting any identified exposed piping metal surface corrosion." 2. 40 C.F.R. 68.67(e) requires the owner or operator to establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; and communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. The facility provided the inspection team with the 2019 Process Hazard Analysis revalidation with a log to document action items. There were six action items listed on the log; however, the response section of the log was not filled out. The response section includes columns for actions, who the actions are assigned to, the due dates for each action, the date the action was completed, and verification; however, each column was left blank. 3. 40 C.F.R. 68.73(d)(2) requires the inspection and testing procedures to follow recognized and generally accepted good engineering practices. The facility provided the inspection team with the log used for pressure safety valve (PSV) replacement. There were six PSVs that had an expiration date of August 2021. According to the facility's own log, the PSVs should have been replaced in August of 2021. According to Table 13.1 in ANSI/IIAR 6 - Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems, pressure relief valves must be changed every five years. 4. 40 C.F.R. 68.79(d) requires the owner or operator to promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. The facility produced the last two compliance audits that were conducted in 2016 and 2019. The 2019 compliance audit has 15 incomplete items that have target completion dates in 2020. 5. 40 C.F.R. 68.93(a) requires coordination with the local fire department to occur at least annually, and more frequently, if necessary, to address changes: At the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan. Page 4 of 5 General Mills Yoplait, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report  When asked by the inspection team, the facility could not produce documentation that they have been coordinating annually with the local fire department. Inspection Report, Prepared by: Digitally signed by JORDAN JORDAN NOLES NOLES Date: 2022.01.25 14:58:46 -05'00' ____________________________ Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 ______________ Date Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER __________________________D_a_te: 2022.01.2_5__17_:_0_1:_1_2_-0_5_'_00_'_ Jason Dressler, Section Chief Date North Air Enforcement Section U.S. EPA Region 4 Page 5 of 5 General Mills Yoplait, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report