Document evj3x9Yogx8J5yXOJYOx3bDv4

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: Honeybear Growers Physical Address: 15 Honeybear Lane, Brewster, WA 98812 Phone Number: 509-689-3479 Latitude/Longitude: 48.062722 / -119.443456 RMP Facility ID# 100000238799 FRS ID#: 110071177435 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Steve Stewart Phone Number: 509-689-3479 E-mail: steve.stewart@honeybeargrowers.com EMERGENCY CONTACT INFORMATION: Name: Ryan Moses Phone (24-hr): 509-846-9243 E-mail: ryan.moses@honeybeargrowers.com TRIP DETAILS: Inspection Date: Inspection Time: Inspectors: May 24, 2022 0900 hours through 1230 hours Terry Garcia, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, EPCRA Inspector Lisa Graves, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: May 17, 2018 Date of Latest Update: May 17, 2018 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000087547 Description Ammonia Refrigeration Process Chemical ID 1000109260 NAICS Code 49312 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 15,000 7/22/22 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 If Yes, Date of Last Inspection: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the 2021 Tier II report to the SERC? No Yes If Yes, Date the Tier II was submitted: 1/27/2022 If No, calendar year of the most recent Tier II: 2021 Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 1/27/2022 INSPECTION ENTRY: Terry Garcia led the inspection entry. The EPA Inspection Team met with facility representative Ryan Moses at the Honeybear Growers facility in Brewster, Washington. EPA arrived at the facility at 0900 hours and was joined by the following facility personnel: Name Ryan Moses Michael Kok Carol Davis Mike Davis Title Production/Refrigeration Manager, Honeybear Growers Refrigeration Operator, Honeybear Growers Ammonia Compliance Consulting Ammonia Compliance Consulting Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes The facility is a first responder: No Yes If No, Responding Agency: Brewster Fire and Yakima Fire. Okanogan LEPC The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Terry Garcia, 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 Page 2 of 5 should be taken during the site tour. Ryan Moses 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 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: If Yes, Name of Union: No Yes An employee representative present during the facility visit: No Yes If Yes, Name/Title: Ryan Moses, Refrigeration Manager and Michael Kok, Refrigeration Operator GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by Honeybear Growers, a Washington Corporation. Honeybear Growers (the facility) is located outside the City of Brewster, Okanogan County, Washington. The facility operates as an apple packing and refrigeration warehouse which utilizes an ammonia refrigeration system. The ammonia refrigeration system, as reported in their latest RMP (first time submission in 2018) is 15,000 lbs. At time of inspection the quantity of ammonia in the largest vessel was 10,238 lbs. The facility's 2021 Tier II reports a maximum amount of ammonia at 14,804 lbs. There are 135 full-time employees including two Operators, Mr. Ryan Moses (15 years) and Mr. Mike Kok (1 years) who are responsible for refrigeration operations at the facility. The hours of operations are Monday - Friday 6:30 AM - 3:30 PM. Honeybear Growers (the facility) first time submission was in 2018. Honeybear Growers facility packages and stores apples in refrigerated rooms while the produce awaits shipment. A single refrigeration system supports ten controlled atmosphere rooms within the facility. The facility refrigeration operator checks the ammonia refrigeration system each operating workday, and refrigerated areas are continuously monitored by an ammonia leak detection system. A computer system remotely notifies refrigeration operators when an alarm is triggered, or refrigeration parameters are out-of-range. There are no process modifications that impact the facility's refrigeration system. The facility has established an Emergency Action Plan (EAP) in the event of an ammonia release. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 0930 hours to 1030 hours. The EPA Inspection Team was escorted by facility representatives Ryan Moses, Michael Kok, and Mike Davis. PPE required and worn by EPA inspectors and facility representatives included: high visibility vests, safety eyewear, hearing protection in the machine rooms, and safety shoes. EPA observed the Refrigeration Office; the Refrigeration Machine Room (Engine Room); exterior exit door clearly marked with NFPA 704 diamond signage and Restricted Access Area Hazcom (Photo 30). Visual and audible alarms and Manual and Emergency Shutoff switches were also observed. There was one (1) ammonia detector located in the Engine Room. EPA also observed safety signage at access doors to two additional controlled atmosphere rooms (CA 19 and CA 20). EPA observed two controlled atmosphere rooms (CA 19 and CA 20), and Common Storage 1 Mezzanine (Photo 1), Cold Room 18 (Photos 2 and 3), and Common Storage 2 (Photos 10-12) that included evaporators, ammonia sensor intakes, and ammonia leak detection tubes. The ammonia piping and ammonia sensor network panel from a mezzanine in the area were observed in Common Storage 1 Page 3 of 5 (Photos 1 and 4-6). Pressure relief valves are located on the roof top (Photos 7-9). The Engine Room contains the main equipment for the ammonia refrigeration system, including the highpressure receiver (HPR) vessel and associated king valve, exhaust fan, intake vents, (3) three screw compressors (Photo 20), valves, and the ammonia leak detection device (Photos 18-28). There were (2) two condensers located on the building rooftop (Photo 29). A dedicated Refrigeration Office adjacent to the Engine Room includes a computer terminal and ammonia sensor network panel (Photos 13-17) which allow facility personnel to monitor refrigeration equipment parameters in all process areas. The facility ammonia refrigeration equipment was clearly labeled and tagged. In addition, safety features were observed throughout the facility including Safety Data Sheets and PPE (Photo 19), rooftop windsocks (Photo 29), manual emergency shut offs (Photo 30), and Hazcom signage visible (Photos 31 and 32). Photographs of the refrigeration system components and pertinent safety measures are included in Attachment A to this report. After touring the RMP-covered process areas at the Honeybear Growers 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 Ryan Moses, Michael Kok, Mike Davis, and Carol Davis. INFORMATION COLLECTED FROM FACILITY: 1. Facility Site Map - 1 page 2. Engine Room Layout - 1 page 3. Email to Emergency Management regarding Tier II submittal - 1 page 4. PSM 8 Mechanical Integrity - 2 pages 5. HBG Relief Data - 2 pages 6. Contractor Mailing List - 1 page 7. Employee SOP Training Log - 1 page AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. The facility does not adequately document the refrigeration operator's knowledge to safely carry out responsibilities specified in the operating procedures [68.71(a)(1-3)]. The training documentation did not show that the facility has documented site specific operator training for Tony Perez, Ryan Moses and Mike Kok. 2. The facility did not show that each employee involved in maintaining the on-going integrity of process equipment, was trained in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner, as required [68.73(c)]. Training documents provided does not document means used to verify training was understood by operators. Training summary form showed means used was observation only. 3. The facility did not have documentation of safety procedures or performance evaluations for four contracted service providers [68.87]. The contractors are DoublKold; Pacific CA; Shifflets aWenatchee Company and Schmitt Electric, a Wenatchee Company. 4. The facility did not update emergency contact information required within thirty days of the change [68.195(b)]. Jason Stocker, emergency contact name listed on 2018 RMP, left the company two years ago. The Emergency phone number and 24 -hour phone line listed in RMP Page 4 of 5 dated 17-May-2018 is a non-working number. EPA attempted to dial the 24 -hour phone line on August 8, 2022, and received the non-working status message. Facility follow up email dated August 12, 2022, confirmed that emergency contact person was updated on June 21, 2022. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested post inspection but are not included in this report. These documents were reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. Additional training documentation for Honeybear Operators and Maintenance employees who work on ammonia process areas and equipment was requested. 2. Updated information was requested for the emergency contact. INSPECTION REPORT CERTIFICATION: This is to certify that I, Terry Garcia, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 5 of 5 Attachment A - Photo Log Site Name: Honeybear Growers City, State: Brewster, Washington Lisa Graves File DSCN2430 DSCN2431 DSCN2432 DSCN2433 DSCN2434 DSCN2435 DSCN2436 DSCN2437 DSCN2438 DSCN2439 DSCN2440 DSCN2441 DSCN2442 DSCN2443 DSCN2444 DSCN2445 DSCN2446 DSCN2447 DSCN2448 DSCN2449 DSCN2450 DSCN2451 DSCN2452 DSCN2453 DSCN2454 DSCN2455 DSCN2456 DSCN2457 Photo Layout ID 1 2 3 31 32 6 5 9 8 4 7 10 11 12 13 Date 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 Time 9:33 AM 9:33 AM 9:33 AM 9:34 AM 9:35 AM 9:35 AM 9:36 AM 9:37 AM 9:38 AM 9:38 AM 9:38 AM 9:38 AM 9:39 AM 9:40 AM 9:41 AM 9:44 AM 9:44 AM 9:44 AM 9:44 AM 9:44 AM 9:47 AM 9:47 AM 9:48 AM 9:51 AM 9:51 AM 9:52 AM 9:53 AM 9:56 AM Description Common Storage 1 - Entry/Exit Cold Room 18 - Evaporator Cold Room 18 - Evaporator, Sensor Tube Cold Room 18 - Entry/Exit CA 19 - Entry/Exit "Room Open" Signage CA 20 - Entry/Exit "Do Not Enter" Signage CA 20 - Entry/Exit "Do Not Enter" Signage Mezzanine - Corridor Mezzanine - Ammonia Lines Mezzanine - Ammonia Sensor Network Panel Mezzanine - Ammonia Sensor Cell Mezzanine - Ammonia Sensor Network Panel Mezzanine - Ammonia Sensor Network Panel Mezzanine - Ammonia Lines Mezzanine - Ammonia Lines Rooftop - Overview Rooftop - Overview Rooftop -Pressure Relief Valve Tags Rooftop -Pressure Relief Valve Tags Rooftop - Overview Mezzanine - Corridor Rooftop - Entry/Exit Mezzanine - Carbon Scrubbers Common Storage 2 - Entry/Exit Common Storage 2 - Evaporators Common Storage 2 - Staircase to Mezzanine Common Storage 2 - Evaporators Refrigeration Office - Computer Terminal Page 1 of 2 File DSCN2458 DSCN2459 DSCN2460 DSCN2461 DSCN2462 DSCN2463 DSCN2464 DSCN2465 DSCN2466 DSCN2467 DSCN2468 DSCN2469 DSCN2470 DSCN2471 DSCN2472 DSCN2473 DSCN2474 DSCN2475 DSCN2476 DSCN2477 DSCN2478 DSCN2479 DSCN2480 DSCN2481 DSCN2482 DSCN2483 DSCN2484 DSCN2485 DSCN2486 DSCN2487 DSCN2488 Photo Layout ID 14 15 16 17 18 19 20 21 22 25 24 26 27 23 28 30 29 Date 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 5/24/2022 Time 9:59 AM 9:59 AM 10:00 AM 10:01 AM 10:01 AM 10:01 AM 10:04 AM 10:05 AM 10:06 AM 10:07 AM 10:07 AM 10:07 AM 10:08 AM 10:08 AM 10:09 AM 10:09 AM 10:09 AM 10:10 AM 10:10 AM 10:10 AM 10:11 AM 10:12 AM 10:13 AM 10:14 AM 10:14 AM 10:14 AM 10:16 AM 10:16 AM 10:18 AM 10:20 AM 10:28 AM Description Refrigeration Office - Daily Log Refrigeration Office - Certificate of Inspection Refrigeration Office - Certificate of Inspection Refrigeration Office - Ammonia Sensor Network Panel Refrigeration Office - Ammonia Sensor Network Panel Refrigeration Office - Ammonia Sensor Cell Refrigeration Machine Room - Entry/Exit Refrigeration Machine Room - SDS Binder Refrigeration Machine Room - Compressors Refrigeration Machine Room - Inactive Compressor Flagged Refrigeration Machine Room - Ammonia Leak Detector System Refrigeration Machine Room - Ammonia Leak Detector System Refrigeration Machine Room - Ammonia Leak Detector System Refrigeration Machine Room - Alarm Refrigeration Machine Room - Pressure Relief Valve Tag Refrigeration Machine Room - Pressure Relief Valve Tag Refrigeration Machine Room - High Pressure Receiver and King Valve Refrigeration Machine Room - High Pressure Receiver Refrigeration Machine Room - Louver Intake Refrigeration Machine Room - Exhaust Fan Refrigeration Machine Room - Pressure Relief Valve Tags Facility - Forklift Chargers Facility - Forklift Chargers Refrigeration Machine Room - Entry/Exit Refrigeration Machine Room - Daily Log Refrigeration Machine Room - Manual Emergency Shutoff Refrigeration Machine Room - Condensers Refrigeration Machine Room - Condensers and Windsock Rooftop - Pressure Relief Valve Facility - Propane Tank Facility - RMP Executive Summary Page 2 of 2