Document RpqvpgDnJOoG5Ej8gwNVZ6ap8

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: OFD Foods, LLC Plant 2 & 3 Physical Address: 525 25th Ave SW, Albany, OR 97322 Phone Number: 541-926-6001 Latitude/Longitude: 44.617944, -123.107111 RMP Facility ID# 1000 0019 8458 FRS ID#: 110000544929 EJ Concerns: No (below 80%) CONTACT INFORMATION (RMP Implementation): Name: Gray Johnson Phone Number: 541-967-6413 E-mail: gray.johson@ofd.com EMERGENCY CONTACT INFORMATION: Name: Gray Johnson Phone (24-hr): 541-967-6413 E-mail: gray.johson@ofd.com Website: ofd.com TRIP DETAILS: Inspection Date: Inspection Time: EPA Inspection Team: June 28, 2022 0900 hours through 1430 hours Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Tom Vroman, CIH, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: March 22, 2007 Date of Latest Update: March 1, 2022 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID NAICS Code 1000118169 Anhydrous Ammonia 1000147751 311423 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantit y (lbs) 40,000 Page 1 of 5 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: 3/15/2022 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: 3/15/2022 INSPECTION ENTRY: Peter Phillips led the inspection entry. The inspection team met with Gary Johnson at the OFD Foods, LLC main office in Albany, Oregon. The team arrived at the facility at 09:00 and was joined by the following facility and contracted personnel: Gary Johnson Jason Luty Jacques Muluc Bradley Marshall Greg Skaer Name Title OFD Engineer HSE Manager Maintenance Manager OFD Refrigeration Coordinator OFD Consultant Was a state/county/or local emergency representative present? No Yes The facility is a first responder: If No, Responding Agency: Albany Fire Department No Yes Facility representatives escorted the EPA Inspection Team (EPA) 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. Gary Johnson gave a brief description of the facility, operations, and personal protective equipment required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of Page 2 of 5 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 is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by OFD Foods, LLC. OFD operates an anhydrous ammonia refrigeration process within Plants 2 & 3 to refrigerate and freeze dry food, pharmaceuticals, and medical devices. Anhydrous ammonia runs through system components within the facility and on the roof. There are no process modifications in the anhydrous ammonia refrigeration process. Plants 2 & 3 are supported by approximately 150 employees. The plant operates 24 hours a day, seven days a week, with two, 12-hour shifts each day. OFD has four trained operators for their ammonia refrigeration system. OFD maintains in internal facility response team, consisting of 33 employees who receive annual training. Supplies for their response team are located next to the parking lot of Plant 1, and at an exterior area of Plants 2 and 3 (Photo 3). OFD also coordinates with the Albany Oregon Fire Department for emergency response preparedness. ON-SITE OBSERVATIONS: The facility tour for Plants 2 & 3 was conducted from approximately 1000 hours to 1100 hours. Plants 2 & 3 (Photos 1, 2) were undergoing annual maintenance during inspection. The inspection team was escorted by Gary Johnson, Jacques Muluc, and Greg Skaer. Plants 2 & 3 have 40,000 pounds of anhydrous ammonia contained in two adjacent engine rooms designated as South Engine Room and North Engine Room. The engine rooms are labeled on the exterior of the building, and each includes audio/visual alarms installed outside and inside each room (Photo 4, 15, 18). The facility is equipped with ammonia alarms that are set with a low alarm at 25 ppm and a high alarm of 2 percent concentrations of ammonia in the air (Photos 8, 16). The engine rooms contain control panels which enable emergency stops for the refrigeration system (Photo 5), and includes emergency washing stations (Photos 6, 17). EPA observed refrigeration equipment at the exterior areas of Plants 2 & 3, South Engine Room, and North Engine Room. The South Engine Room equipment include a pressure relief valves (Photo 7, 12,13, 14), intake vent (Photo 9), exhaust vents (Photo 10), and an ammonia high pressure receiver (HPR) tank (Photo 11). The North Engine Room equipment include intake vents (Photo 19), and an ammonia HPR tank coved with ice (Photos 20, 21). The facility area designated as LPR3 and ammonia supply lines and associated ammonia sensors and alarms were observed (Photos 22, 23, 24). EPA observed that facility representatives could not provide a specific list of employees who held access door to LPR3 (Photo 25). EPA observed one of four cold rooms at Plants 2 and 3. The Cold Room includes freeze dry chambers where chillers/evaporators utilize anhydrous ammonia to freeze dry product (Photo 26, 27), a lowpressure receiver tank (Photo 31) and ammonia supply lines to the chillers/evaporators (Photos 30, 31, 32). The Cold Room safety controls include ammonia sensors and alarms (Photos 30, 32, 33), a lockout tagout system (Photos 29, 34), and control panels with emergency stops (Photos 28, 29). Page 3 of 5 The refrigeration system equipment on the rooftop of Plants 2 and 3, include ammonia supply lines (Photos 36, 37, 38), operational and decommissioned condensers (Photos 39, 40), and external engine room intake vents (Photos 38, 41, 42). Safety features observed on the rooftop include a windsock (Photo 35), and a lockout/tagout system supporting facility processes (Photo 43). During the inspection, EPA observed that the facility was actively implementing the lockout/tagout system on the rooftop to support employees performing maintenance in South Engine Room (Photo 43). Photographs taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at Plants 2 & 3, EPA returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to the following people: Gary Johnson, Jason Luty, Jacques Muluc, Bradley Marshall, and Greg Skaer. INFORMATION COLLECTED FROM FACILITY: 1. Visitor Rules and Regulations (1 page) 2. 2022 PSM/RMP Audit Report (7 pages) 3. Site Plan - Plant 1 (1 page 11 x 14 inches) AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: No areas of concern were identified in the closing conference. 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. On 7/22/2022, OFD provided the requested information via email. 1. Updated 2022 RAGAGEPs List. The document was reviewed, and no issues were identified. 2. 2022 Compliance Audit Finding Tracking Sheet. The document was reviewed, and no issues were identified. All findings were assigned, completed, or had completion dates assigned. 3. Contractor Evaluations from Human Resources. OFD provided evaluation forms and OSHA 100 forms for the four contractors performing work on or near the refrigeration process. The document was reviewed, and no issues were identified. 4. Updated OFD Piping Specifications. The document was reviewed, and no issues were identified. 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 4 of 5 __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 5 of 5 Attachment A - Photo Log Site Name: OFD Plant 2 & 3 City, State: Albany, OR Photographer: Tom Vroman File Picture 1.jpg Picture 2.jpg Picture 3.jpg Picture 4.jpg Picture 5.jpg Picture 6.jpg Picture 7.jpg Picture 8.jpg Picture 9.jpg Picture 10.jpg Picture 11.jpg Picture 12.jpg Picture 13.jpg Picture 14.jpg Picture 15.jpg Picture 16.jpg Picture 17.jpg Picture 18.jpg Picture 19.jpg Picture 20.jpg Picture 21.jpg Picture 22.jpg Picture 23.jpg Picture 24.jpg Picture 25.jpg Picture 26.jpg Picture 27.jpg Picture 28.jpg Picture 29.jpg Picture 30.jpg Picture 31.jpg Picture 32.jpg Picture 33.jpg Picture 34.jpg Picture 35.jpg Picture 36.jpg Picture 37.jpg Picture 38.jpg Picture 39.jpg Picture 40.jpg Picture 41.jpg Picture 42.jpg Picture 43.jpg Photo Layout ID 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Date 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 6/28/2022 Time Description 10:08 AM NFPA placard, Plant 2 & 3 exterior 10:08 AM Windsock, Plant 2 & 3 exterior 10:11 AM Ammonia Emergency PPE, South Engine Room 10:12 AM NH3 alarms outside of South Compressor Room 10:12 AM Controls with emergency stop, South Engine Room 10:13 AM Emergency washing station, South Engine Room 10:15 AM Pressure relief valves, South Engine Room 10:15 AM Ammonia alarms - 25 ppm and 2% concentration sensors, South Engine Room 10:16 AM Ventilation intake for Engine Room South system, Compressor Room 10:16 AM Ventilation exhaust, South Engine Room 10:16 AM Ammonia receiver, South Engine room 10:17 AM Pressure relief valve, South Engine Room 10:17 AM Pressure relief valve, South Engine Room 10:17 AM Tags indicating maintenance, South Engine Room 10:20 AM Door from South Engine Room to North Engine Room 10:20 AM Ammonia alarms, North Engine Room 10:21 AM Emergency washing station, North Engine Room 10:22 AM Door from North Engine Room to South Engine Room 10:23 AM Ventilation intake, North Engine Room 10:25 AM Iced over receiver, North Engine Room 10:26 AM Placard on receiver tank, North Engine Room 10:27 AM Alarms in LPR3 10:27 AM Iced over components, LPR3 10:28 AM Alarms outside of LPR3 10:29 AM LPR 3 access door, list of personnel with access unconfirmed 10:29 AM Chiller/evaporator with ice on side plates to cool products on trays, Cold Room 10:30 AM Chiller/evaporator with side plates under maintenance, Cold Room 10:30 AM Control panel with emergency stops and lockable components, Cold Room 10:33 AM Control panel wall with lockout/tagout locks, Cold Room 10:34 AM Ammonia system components behind chamber aisle and ammonia alarm, Cold Room 10:34 AM Low pressure receiver behind chamber aisle, Cold Room 10:34 AM Ammonia alarms behind chamber aisle, Cold Room 10:36 AM Hot work permit dated 6/22/22 and ammonia alarm, Cold Room 10:40 AM Lockout tagout system, Cold Room 10:43 AM Windsock, Rooftop 10:43 AM Refrigeration system vents and pipelines, Rooftop 10:43 AM Refrigeration system vents and pipelines, Rooftop 10:43 AM Refrigeration system vents and pipelines, Rooftop 10:46 AM Decommissioned condenser, Rooftop 10:46 AM Plant 2 & 3 condenser, Rooftop 10:47 AM Engine room intake, Rooftop 10:47 AM Engine room intakes, Rooftop 10:47 AM Lockout/tagout system on Rooftop, supporting maintenance workers in South Engine Room