Document XOkGXjenj5mYO1MvEp0VojaZ4

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 1 - NEW ENGLAND 5 POST OFFICE SQUARE, SUITE 100 BOSTON, MASSACHUSETTS 02109-3912 CAA 112 (r), Risk Management Plan (RMP), CAA 112(r)(1) General Duty Clause (GDC), CERCLA 103, and EPCRA 302-313 Compliance Evaluation Inspection of: Houlton Farms Dairy, Inc. 25 Commonwealth Ave Houlton, Maine 04730 10/26/2023 ______________________________ Date of Inspection 1/8/2024 ______________________________ Date Inspection Report Approved 1/8/2024 ______________________________ Date Inspection Report Finalized Leonard Wallace Wallace, Leonard Digitally signed by Wallace, Leonard __________________D_a_te_: 2_02_4._01_.0_9 0_6_:59_:3_9 _-0_5'0_0'__ Waste and Chemical Compliance Section Digitally signed by MARY MARY ODONNELL ODONNELL ___________________Da_te_: 2_0_24_.0_1.0_8_1_4:3_7_:43_-_05_'00' Mary Jane O'Donnell, Manager Waste and Chemical Compliance Section 1/9/2024 _______________________________ Date Inspection Report Transmitted to Facility Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Date: January 8, 2024 From: Leonard Wallace IV, and Andrew Meyer, USEPA Inspectors Through: Mary Jane O'Donnell, Chief Waste and Chemical Compliance Section To: File Subject: Chemical Accident Investigation and Inspection, Clean Air Act (CAA) Risk Management Plan (RMP) Section 112(r) and General Duty Clause (GDC) Section 112 (r) (1) and Emergency Planning and Community Right-To-Know Act (EPCRA) Sections 302-312, and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 103 of Houlton Farms Dairy located in Houlton, Maine. GENERAL INFORMATION Facility Name: Houlton Farms Dairy, Inc. Dun and Bradstreet Number: 00-110-8885 RMP Number: N/A Address: 25 Commonwealth Ave Houlton, Maine 04730 Inspector Names: Leonard B. Wallace IV, U.S. Environmental Protection Agency (EPA) Region 1 Andrew Meyer, U.S. EPA Region 1 Amy Federoff, ERG Tyler Evans, Weston Solutions Charles Colley, U.S. Department of Homeland Security (DHS) Inspection Date: October 26, 2023 Type of Inspection: CAA 112(r)(1) General Duty Clause (GDC), CERCLA 103, and EPCRA 302313 Compliance Evaluation Inspection Purpose of Inspection: This inspection was conducted as a routine EPA CAA 112(r)(1)/EPCRA compliance evaluation inspection. The Houlton Farms Dairy facility in Houlton, Maine was selected for inspection because it is a stationary source with an unknown amount of ammonia onsite. Current Owner: Houlton Farms Dairy, Inc. Current Operator: Houlton Farms Dairy, Inc. Product Trade Name: N/A Primary NAICS codes: 311511 (Fluid Milk Manufacturing) Number of full-time employees: 48 (total across all locations) Estimated Annual Sales: 4.99M 2 Relationship to other firms, parent corporation, subsidiaries, and location of off-site facilities: Parent Corporation: Houlton Farms Dairy, Inc., Houlton, ME (headquarter location) Houlton Farms Dairy, Inc. also owns and operates three ice cream shops located in ME. I. GENERAL FACILITY DESCRIPTION The Houlton Farms Dairy, Inc. in Houlton, ME (Houlton Farms Dairy or Facility) produces and packages milk and milk products, including butter, buttermilk, ice cream, sour cream, half-and-half and whipping cream. The milk and milk products are refrigerated or frozen before being shipped out for sale at commercial grocery markets and ice cream stores. The Facility is a non-union workplace and employs approximately 14 staff at the production location. The ammonia refrigeration system onsite was originally installed in 1962 and Facility personnel estimated that the system contained 450-lbs of ammonia. Equipment for the ammonia refrigeration system is located in the can room of the Facility and includes two compressors, a high-pressure receiver, and two evaporators. A condenser is located along the rear exterior of the Facility. The Facility is in a residential area of Houlton, ME. Private residences surround the Facility where the closest is located within 125 ft. Attachment 1 is a Google Earth aerial photograph of the Houlton Dairy Farms in Houlton, ME. At the time of the inspection the ammonia refrigeration system was inactive, and the Facility was using a freon refrigeration system to chill their products. Facility Owner, Jim Lincoln, stated that in September 2023 the Facility stopped operating the ammonia refrigeration system and drained all the ammonia into the high-pressure receiver. Mr. Lincoln provided the EPA inspection team with an invoice (see Document "Contractor Ammonia Decommission Sales Order") for a contractor to remove the ammonia from the Facility and Mr. Lincoln stated that ammonia removal was scheduled to occur in December 2023. The Facility planned to decommission the ammonia refrigeration system entirely with no intended future use. II. IN-BRIEF/OPENING CONFERENCE The EPA inspection team including Leonard Wallace, IV, Andrew Meyer, Amy Federoff (EPA contract inspector), Tyler Evans (EPA contract air monitoring specialist), and Charles Colley of the U.S. DHS entered the Facility at approximately 10:00 a.m. The inspection team was supported by Darren Curtis from Maine Emergency Management Agency (MEMA), Derrick Ouellette from Aroostook County Emergency Management Agency (AC EMA) and Milton Cone and Brent Estabrook from the Houlton Fire Department. The inspection team presented identification to Mr. James Lincoln, Houlton Farms Dairy Owner, and Inspector Wallace subsequently conducted the opening meeting and explained the reason and scope of the inspection. Inspector Wallace presented the EPCRA Notice of Inspection to Mr. Lincoln, who signed as the Recipient of the Notice. Mr. Lincoln did not attempt to deny facility entry to the inspectors and did not invoke any claims of Confidential Business Information (CBI) for purposes of the inspection. Facility Representatives: Name James Lincoln Title/Company Houlton Farms Dairy, Owner Phone Number 207-694-1068 E-mail houltonfarmsdairy@gmail.com Inspector Wallace shared the following guidance documents with facility representatives: 1. Guide to the Emergency Planning and Community Right-to-Know Act (Fall 2020) 2. EPCRA Quick Reference Fact Sheet (Fall 2020) 3 3. List of Lists (EPA 550-B-20-001, August 2020) 4. Small Business Resource Information Sheet (February 2020, EPA-300-F-20-002) 5. National Response Center Oil and Chemical Spill Reporting flyer 6. Chemicals in Your Community brochure (EPA 550-K-99-001, December 1999) Inspector Wallace stated that after the opening meeting, the inspectors would do a walk-through inspection of the refrigeration process and all facility areas. He stated the inspection team would be taking photographs of items and areas of interest and a copy of all photographs taken would be made available to the Facility representatives after the inspection. III. PHYSICAL INSPECTION The EPA inspection team conducted a walk-through of the following areas at the Facility: 1. Building Exterior 2. Indoor Ammonia Equipment Inspector Wallace took a total of 20 digital photographs during the inspection to provide reference documentation of conditions observed. The photographs are referenced throughout the document. The following include areas of concern identified in each of the areas during the physical inspection. Building Exterior The EPA inspection team toured the perimeter of the Houlton Farms Dairy building and focused on the rear exterior housing the Facility's outdoor refrigeration equipment. An elevated steel platform sits against the rear exterior of the building and supports an ammonia condenser so that it is almost level with the roof of the building. A freon refrigeration unit also sits on the steel platform underneath the ammonia condenser. Multiple truck bays are also located in the rear exterior of the Houlton Farms Dairy building to allow for shipping and delivery of both raw materials and final products. EPA inspectors identified the following areas of concern based on a tour of the area: No windsocks were installed at the front of the Facility to inform emergency responders and evacuating personnel of the prevailing wind direction (see Photographs P1130920 and P1130921) The doors to access the can room were not posted with NFPA 704 signage to indicate the presence of chemical hazards (see Photograph P1130923). The doors to access the can room were not posted with restricted access signage to indicate that only authorized personnel are permitted to enter the ammonia machinery room (AMR) (see Photograph P1130923). No ammonia audible/visual alarms were observed (see Photograph P1130923). No emergency stop ("E-Stop") button or emergency ventilation switch was located next to the primary door to the ammonia refrigeration system (see Photograph P1130923). No Emergency Contact List and Emergency shut down procedures were poet outside the AMR (see Photograph P1130923). No Piping and Instrumentation Diagram (P&ID) post outside the AMR door to show the critical emergency shutoff valves clearly identified (see Photograph P1130923). No emergency eyewash and safety shower station outside the primary door to the AMR (see Photograph P1130923). 4  The ammonia piping outside and off the condenser were either faded and illegible or missing altogether (see Photograph P1130923, P1130924, and P1130927). None of the new freon refrigeration Pipes were labeled to indicate the contents and direction of flow (see Photograph P1130923). The Pressure relief valves (PRV) to the condenser were not 7.25 feet above the roof of the building point down and (see Photograph P1130927). The Pressure relief pipe was point down (see Photograph P1130927). The exhaust opening from the AMR was not ducked to have the ammonia vent upward (see Photograph P1130923). No air inlet to AMR (see Photograph P1130923). The Propane tank next to the building was not protected against bumps (see Photograph P1130923). Indoor Ammonia Equipment The equipment for the ammonia refrigeration system is in an area called the can room at the Facility. The ammonia refrigeration equipment includes two compressors, a high-pressure receiver, and two evaporators. The system was not operating at the time of the inspection. EPA inspectors identified the following areas of concern based on a tour of the area: The ammonia refrigeration equipment and vessels were not marked with the equipment's name or associated identifier (see Photographs P1130928, P1130933 and P1130934). There is no emergency shower/eyewash station located inside of the can room near the ammonia refrigeration system (see Photograph P1130928). There is no ammonia detector or alarm system located inside of the can room near the ammonia refrigeration system to warn of any elevated ammonia levels (see Photographs P1130928 and P1130933). Some of the ammonia pipes showed signs of rusting (see Photograph P1130931). V. OUT-BRIEF/CLOSING CONFERENCE A brief closing conference was conducted at the conclusion of the on-site inspection where Inspector Wallace discussed the planned ammonia removal and additional document requests regarding the removal and decommissioning process. Mr. Wallace then explained the next steps in the enforcement process. On December 14, 2023, Tanner Industries removed the ammonia from the facility. VI. FACILITY COMPLIANCE STATUS AND ELEMENTS OF PROOF - EPCRA EPCRA 302 (1) Does facility have on-site, at any one time, extremely hazardous substances (EHS) at or above the TPQ? No, the Facility removed its ammonia. (2) List or obtain documentation: Inspectors' observations; self-reporting. (3) How was maximum quantity on-site determined or calculated? Inspectors' observations; Facility self-reported ammonia quantity within the refrigeration equipment. EPCRA 303 (1) Facility Coordinator identified per Sec. 303 and date LEPC was notified? Unknown 5 EPCRA 311 (1) Is facility required to maintain SDSs under the OSHA Hazard Communication Standard 29 CFR 1910.1200.? Yes (2) Has the facility conducted a comprehensive audit to identify SDS chemicals on-site and to determine if 500 lb./10,000 lb./TPQ thresholds were exceeded? Unknown (3) List of OSHA chemicals manufactured, processed, used/stored, and obtained? Unknown (4) How were the maximum amounts determined? Inspectors' observations. (5) Section 311 info supplied to the: SERC (Y/N): LEPC (Y/N): Local Fire Department(Y/N): Date: Chemical List: Unknown Unknown Unknown Unknown Unknown SDSs: Yes (6) Have any new hazardous chemicals, mixtures, or substances been introduced into the facility in the last 5 years? Freon refrigerant 404A (7) If yes, has the facility submitted updated lists or SDSs? Unknown EPCRA 312 (due March 1 of year following reporting calendar year) (1) Was Tier II form submitted for all required chemicals? No, by removing the ammonia from the facility there are no chemicals above the reporting threshold. (2) What procedures are used to update Section 312 information for annual submittal and to ensure additional or new chemical data is submitted within 90 days? Based on inspectors' observations, this is not applicable (3) Was facility aware of annual reporting requirements under Section 312? No. (4) Had the facility completed and signed a list of all reportable chemicals on site on date of the inspection? No. (5) Table of EPCRA 312 Reportable Substances: CAS # Source: Inspection Observations Chemical Approx. Max. Wt. on Site (Lbs.) None TPQ (Lbs.) Approx. Ratio (Actual/TPQ) VII. ENFORCEMENT HISTORY A search of EPA's ECHO database found no violations for enforcement actions for the Houlton Farms Dairy located at 25 Commonwealth Ave. in Houlton, Maine. 6 VIII. ENVIRONMENTAL JUSTICE The EPA Environmental Justice (EJ) MAP data indicate that the Facility is located inside a census block group with at least one EJ index over the 90th percentile Nationally and State Block group: 230039524003. 7 Attachment 1 Google Earth Image of Houlton Dairy Farms 8