Document aJ70nrgL15vqk6wRdNzwjZq1y

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Interstate Warehousing Murfreesboro, Tennessee December 14, 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 Interstate Warehousing 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 14, 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 International Warehousing 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 27,000 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 14, 2021 Facility Identification Name: Interstate Warehousing Street Address: 2125 Joe B. Jackson Parkway City: Murfreesboro County: Rutherford EPA Facility ID No: 1000 0019 4951 Dun & Bradstreet (D&B) No: 800635091 Latitude: 35.775900 Longitude: -086.384600 State: Tennessee Zip: 37127 Name, address and phone of corporate parent company: Owner/Operator: Tippmann Group Mailing Address: 9009 Coldwater Road City: Fort Wayne State: Indiana Zip: 46825 Phone: (260) 490-3000 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Grant Chapman Title: Facilities Engineer Email: gchapman@tippmanngroup.com Name and title of emergency contact: Name: Rich Hale Title: Maintenance Manager Day phone: (615) 904-3000 24-hour Phone: (615) 542-3388 Email: rhale@tippmanngroup.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Rich Hale Title: Maintenance Manager Phone: (615) 542-3388 Email: rhale@tippmanngroup.com Name: Grant Chapman Title: Facilities Engineer Phone: (317) 752-8017 Email: gchapman@tippmanngroup.com Name: Brett Livingston Title: Corporate Safety Director Phone: (317) 504-6523 Email: blivingston@tippmanngroup.com Page 2 of 4 Interstate Warehousing, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report Name: Justin Haynes Title: Safety Manager Phone: (615) 663-9497 Email: jhaynes@tippmanngroup.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: April 12, 2006 Date of most recent submissions: March 31, 2020 Process as reported in RMP: Ammonia Refrigeration Process: Ammonia Refrigeration Process ID: 1000107874 Program Level as reported in RMP: 3 NAICS code: 49312 (Refrigerated Warehousing and Storage) 3.0 Observations The inspection of the Interstate Warehousing 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 Interstate Warehousing 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, the inspection team observed that none of the doors had panic-type hardware exiting the engine room. ANSI/IIAR 2-2014 section 6.10.2 (Door Features) states, "Machinery room doors shall be self-closing and tight fitting. Doors that are part of the means of egress shall be equipped with panic hardware and shall be side hinged to swing in the direction of egress for occupants leaving the machinery room." At the time of the inspection, the inspection team observed one door entering the engine room had the wrong NFPA placard. The placard displayed a "1" for the degree of flammability; the correct degree for flammability for indoor ammonia refrigeration equipment is "3." ANSI/IIAR 2-2014 section 5.14.2 (NFPA 704 Placards) states, "Buildings and facilities with refrigeration systems shall be Page 3 of 4 Interstate Warehousing, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report provided with placards in accordance with NFPA 704. For equipment located outdoors, the placard shall display the following degrees of hazard: Health-3, Flammability-1, Instability-0. For equipment located indoors, the placard shall display the following degrees of hazard: Health-3, Flammability-3, Instability-0." At the time of the inspection, frost build-up was observed around piping in the engine room where valve groups were present, which could cause issues when trying to operate those valves. ANSI/IIAR 2-2014 section 5.10.1 (Condensation and Frost Control) states, "Piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system." Inspection Report, Prepared by: Digitally signed by JORDAN JORDAN NOLES Date: 2022.01.25 14:56:26 NOLES __________________-_05_'0_0_' ______ 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_1_7_:0_4_:1_4_-_0_5_'0_0_' _ Jason Dressler, Section Chief Date North Air Enforcement Section U.S. EPA Region 4 Page 4 of 4 Interstate Warehousing, Murfreesboro, TN CAA 112 (r), Risk Management Program, Inspection Report