Document RpXL9Z9Oa7EVn9y7oLEKNQna8

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: Fruitsmart Physical Address: 1125 Sheridan Ave. Phone Number: 509-882-9956 Latitude/Longitude: 46.205833/-119.772500 RMP Facility ID# 100000107555 FRS ID#: 110000554196 EJ Concerns: Yes - greater than 80 percent CONTACT INFORMATION (RMP Implementation): Name: Scott Evenson, Director of Facilities Phone Number: 509-882-9956 E-mail: sevenson@fruitsmart.com EMERGENCY CONTACT INFORMATION: Name: Elton Brown, Maintenance Manager Phone (24-hr): 509-882-9956 E-mail: ebrown@fruitsmart.com Website: www.fruitsmart.com TRIP DETAILS: Inspection Date: Inspection Time: Inspectors: 6/27/2023 09:00 through 14:45 Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP/EPCRA Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP/EPCRA Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP/EPCRA Inspector Mhara Coffman, US EPA Region 10, RMP/EPCRA Inspector DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: 6/21/1999 Date of Latest Update: 3/23/2023 Page 1 of 6 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID Refrigerated 1000083177 Warehousing 1000163164 and Storage NAICS Code 49312 Program Level 3 Chemical Name CAS Number Ammonia (anhydrous) 7664-41-7 Quantity (lbs) 21,157 PURPOSE: The purpose of this inspection was to determine whether this facility is in compliance with Section 112(r) of the Clean Air Act and Title 40 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: No Yes Joint EPCRA inspection: 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: 2/1/2023 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: 2/1/2023 INSPECTION ENTRY: Peter Phillips led the inspection entry. The inspection team met with Paul Dickman at the Fruitsmart facility in Prosser, Washington. The team arrived at the facility at 09:00 and was joined by the following facility personnel: Vanessa Flores Arasele Zuniga Scott Evenson Elton Brown Eli Asevedo Deanna Davis Name Title Safety Specialist HR Manager Product Planning Maintenance Manager Logistics Manager Benton County LEPC Was a state/county/or local emergency representative present? No Yes If Yes, Name and Title of Representative: Deanna Davis, Benton County LEPC The facility is a first responder: If No, Responding Agency: Prosser Fire Department No Yes Page 2 of 6 The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Peter Phillips, who provided a summary of the risk management program (RMP) and explained the purpose of the visit. Each team member presented his/her credentials. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Elton Brown gave a brief description of the facility, operations, and personal protective equipment required for the tour. The facility required closed-toe shoes, hearing protection, safety glasses, and hair nets for the facility 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, and 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, owned and operated by Fruitsmart, Inc. (Fruitsmart), is under the jurisdiction of the Risk Management Program as a Program Level 3 facility. Fruitsmart functions primarily as a cold storage facility and utilizes anhydrous ammonia (at a quantity of 21,157 pounds) as a refrigerant. The amount of anhydrous ammonia stored and used at the facility exceeds the threshold quantity of 10,000 pounds. The facility employs approximately 50 full-time personnel includes two individuals specifically assigned to operate and maintain the ammonia refrigeration process. The facility is located in Prosser, a city in Benton County, Washington. Originally constructed in the 1940s, the facility underwent its most recent modification in 1992 with the inclusion of a cold storage room. Fruitsmart's 335,000 square foot, 19-acre campus contains dry ingredient processing, a freezer facility, and corporate offices. The primary output of the facility consists of juice products, fruit pomace, seed oil, and cider-producing bases. The facility operates 24/7 with 4 rotating shifts. A mechanical integrity audit was performed in 2017 by Kemper. All identified deficiencies have been addressed. The next mechanical integrity will be conducted by AAPCO and will start during the last week of July 2023. Standard Operating Procedures are accessible in both binder and digital forms. The facility's ammonia refrigeration process consists of the following major equipment: 1 engine room o 2 compressors (one compressor was out of service) o 4 ammonia detectors 3 interconnected vessels comprise the high pressure receiver (HPR) 1 low pressure receiver (LPR) 1 cold room o 9 evaporators o 3 ammonia detectors 6 condensers 1 dry storage room (no anhydrous ammonia present) There have not been any significant additions or modifications of the covered process. Page 3 of 6 ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 09:45 to 10:15. The inspection team was escorted by Vanessa Flores, Arasele Zuniga, Scott Evenson, Elton Brown, Eli Asevedo, and Deanna Davis. The inspection team observed the major process areas of the ammonia refrigeration process given below. Engine Room: The doors were placarded and accessible only by authorized personnel (photos 2 and 4). Emergency eyewash and shower stations were located adjacent to the doors (photo 2). Audible and visual alarms, as well as emergency shutdown switches and ventilation controls, were present (photos 3 and 4). The main equipment observed were two screw compressors (photo 5), three interconnected vessels comprise the high-pressure receiver (photo 6), one low-pressure receiver (photo 8), and four ammonia detectors (photo 20). The King Valve on the high-pressure receiver was clearly labeled (photo 15). The ventilation system has two fresh air intakes (photo 14) and two exhaust fans (photo 16). Pressure relief valves (PRV) were scheduled for replacement in 2025 (photo 9). Piping in the engine room were labeled with flow direction and ammonia state (photo 6). Several non-destructive testing points from the 2017 mechanical integrity audit were observed (photos 10, 13, and 19). There were several decommissioned vessels and one reciprocating compressor that have not yet been removed due to cost and logistics (photos 7 and 17). A series of six condensers and a windsock were observed atop the engine room (photo 1). Cold Room: Fruitsmart has a single high rack storage room where products are held until shipment. The cold storage room is equipped with nine evaporators and three ammonia detectors (photos 20 and 21). Safety Systems: The facility has a number of process safety equipment located throughout the facility. Ammonia detectors in the engine room and cold storage room are set to warn at 25 ppm and alarm at 150 ppm. The ammonia detector in the PRV vent stack is set to alarm at 1,000 ppm (photo 12). Several emergency showers/eye wash stations were observed along with emergency shutoff and ventilation switches (photos 2, 3, and 4). Other safety systems observed were strobes, alarms, and a fire sprinkler system (photos 2, 3, and 4). Photographs were taken of the ammonia refrigeration system. The photographs that were taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at the Fruitsmart facility, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Vanessa Flores, Arasele Zuniga, Scott Evenson, Elton Brown, and Eli Asevedo. INFORMATION COLLECTED FROM FACILITY: 1. A site map of the facility 2. 2017 mechanical integrity summary AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Process Hazard Analysis (PHA) [68.67(a)]: Fruitsmart could not produce the initial PHA performed in 1999. The facility is required to retain all PHAs for the life of the process. Page 4 of 6 2. Training [68.71(a)(1)]: Fruitsmart could not produce documentation that their operator, Elton Brown (hired on 1/3/1979) received initial training on the process. Initial training includes emphasis on safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. 3. Mechanical Integrity [68.73(c)]: Fruitsmart could not produce documentation that their operators, Elton Brown (hired on 1/3/1979) and Casey Hofstadt (hired on 9/6/1994) received training in maintaining the integrity of the process equipment. 4. Contractors [68.87(b)(5)]: Fruitsmart could not produce documentation that periodically evaluated the performance of Kemper Northwest, Empire Controls, and All Phase in fulfilling their obligations (as described at 68.87(c)(l)-(c)(5)). 5. Emergency Response [68.93(c)]: Fruitsmart was unable to provide documentation of coordination with local emergency response authorities. The documentation requested included the names, contact information, and organizational affiliations of the individuals involved, as well as the dates and details of coordination activities. The only relevant documentation Fruitsmart provided was an email sent to the West Benton County Fire District on July 5, 2023, and an Emergency Action & Response Plan Drill/Evacuation Critique Form. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. These documents will still be reviewed to determine compliance with Section 112(r) of the Clean Air Act. The follow-up information requested was received via email on 7/19/2023. Follow-up Request 1. Initial training for Elton Brown and [68.67(a)] 2. Process maintenance training for Elton Brown and Casey Hoffstadt 3. The initial 1999 PHA Status Not provided Not provided Not provided 4. RMP organizational responsibilities 5. Contractor vetting for Empire Controls, Kemper, and All Phase 6. Contractor periodic evaluation for Empire Controls, Kemper, and All Phase 7. Evacuation coordination documentation Provided Provided for Empire Controls and All Phase Not provided Email to West Benton County Fire District dated 7/5/2023 and an Emergency Action & Response Plan Drill/Evacuation Critique Form 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 Page 5 of 6 __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 6 of 6 Site Name: Fruitsmart City, State: Prosser, WA Photographer: Peter Phillips File Name IMG_0138.JPG IMG_0139.JPG IMG_0140.JPG IMG_0141.JPG IMG_0142.JPG IMG_0143.JPG IMG_0144.JPG IMG_0145.JPG IMG_0146.JPG IMG_0147.JPG IMG_0148.JPG IMG_0149.JPG IMG_0150.JPG IMG_0151.JPG IMG_0152.JPG IMG_0153.JPG IMG_0154.JPG IMG_0155.JPG IMG_0156.JPG IMG_0157.JPG IMG_0158. JPG IMG_0159.JPG Photo 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Date 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 6/27/2023 Time 9:47 AN 9:48 AM 9:48 AM 9:48 AM 9:49 AM 9:49 AM 9:50 AM 9:50 AM 9:51 AM 9:51 AM 9:52 AM 9:52 AM 9:53 AM 9:53 AM 9:54 AM 9:55 AM 9:56 AM 9:56 AM 9:57 AM 10:02 AM 10:03 AM 10:07 AM Description Condensers atop engine room Engine room door and shower/eye wash station Engine room door emergency stop Engine room door opposite side Engine room compressor overview Engine room vessel overview Out of service compressor Low pressure receiver Pressure relief tag NDT points and corrosion under insulation (CUI) on pipe Engine room ammonia detector Vent line ammonia detector NDT points on vessel Engine room ventilation intake HPR king valve Engine room exhaust fan Out of service vessels in engine room Cutaway of out of service vessel in engine room Valve CUI Cold storage ammonia pipe from engine room Cold storage room evaporator Forklift charging station