Document g22njqEnMnZEwRqkxNjE9qqBL

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See Date of Section Chief Signature Below CLEAN AIR ACT INSPECTION REPORT Sysco Food Service - Freezer, Des Plaines, Illinois Natalia Vazquez, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: Sysco Food Service - Freezer Facility Location: 501 S. Wolf Road, Des Plaines, Illinois 60016 Date of Inspection: September 27-29, 2021 EPA Inspector(s): 1. Natalia Vazquez, Environmental Engineer 2. Greg Chomycia, Environmental Engineer 3. Manojkumar Patel, Environmental Engineer Other Attendees: 1. Victor Arciga, Fleet and Facility Maintenance Director 2. Andre Harris, Safety Director Contact Email Address: victor.arciga@sysco.com Purpose of Inspection: compliance with Clean Air Act (CAA) 112r Facility Type: wholesale food distributer and warehouse Regulations Central to Inspection: Level 3 Program under CAA 112r Arrival Time: 9/28/2021 9:00am Departure Time: 9/28/2021 4:00pm Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Will be provided with inspection report Provided CBI warning to facility This inspection included a virtual Microsoft TEAMs opening conference on September 27, 2021; a site visit on September 28, 2021; and a virtual closeout conference on September 29, 2021. The following information was obtained verbally from Victor Arciga and Andre Harris unless otherwise noted. Process Description: Sysco Food Service ("Sysco") has on site two Level 3 processes under the CAA 112r. EPA inspectors focused on one of the processes which is refer to as the "freezer" and this report is limited to the freezer process. The ammonia refrigeration is in operations 24 hours, 7 days of the week. Most employees are present Sunday through Friday. Saturdays has almost no employees on site. The warehouse freezer has about 70 employees. Ten maintenance employees are shared by the freezer building and the other building. The facility has a union representing the staff but does not represent the maintenance staff. The freezer warehouse was built in 2008. The freezer is a warehouse building that is refrigerated at 0 F with multiple doors for trucks. The warehouse has an engine room that contains a high-pressure receiver (HPR) vessel, high temperature pump recirculator (HTPR) vessel, low temperature pump recirculator (LTPR) vessel, low-low temperature suction trap (LLTST) vessel and four compressors. The fourteen evaporators are in the roof, some of the evaporators were inside several penthouses (two or four per penthouse). Staff Interview: The Risk Management Plan available in the EPA database before the inspection had Jason Briana as the emergency contact. Mr. Briana left in February 2021. The facility has had no accidents, spills or major leakage. Sysco has an in-house response group for ammonia releases as long as the concentration is below 250 ppm. Once the ammonia concentration reaches 250 ppm, the facility requires its response group to vacate the building and it calls the fire department (HAZMAT team). The response Page 2 of 6 group has cartridge respirators and two-way radios as part of their emergency equipment. The cartridge respirators can protect up to 250 ppm. The facility had the fire department on site in February 2021 for a tour of the facility. The facility hasn't done a drill exercise with in-house response group since COVID-19 pandemic started in March 2020. Ammonia detectors (sniffer) are calibrated once a year. The facility has infrequent additions of ammonia. According to Steve Adams (staff member that works in ammonia refrigeration process) the facility installed a new ammonia addition station 3 to 4 years ago. The facility `s representatives were not able to locate an MOC and pre-startup safety review for the ammonia addition station. The facility started using a software called ePSM to maintain its 112r related records. The facility has three main contractors: 1. Harbor Environmental and Safety - provides assistance with 112r program and helped develop the ePSM, 2. Dual Temp - responsible for preventative maintenance, assist fix issues, on call for accidents/emergency, and 3. F.E. Moran - preventative maintenance, emergency, ammonia sensor calibration. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Eric Esparza assisted Mr. Arciga and Mr. Harris during the site tour. EPA inspectors observe corrosion at the bottom of the high temperature pump recirculator (HTPR) vessel. Compressor RC-1 was built in 2008 and had its pressure relief valve replaced 2018. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW The following records were provided by the facility through a OneDrive web-link, before the inspection. 1. Site map 2. P&ID diagrams 3. Off-site Consequence Analysis - CBI Page 3 of 6 4. Process Safety Information 5. 2018 Process Hazard Analysis 6. Process Hazard Analysis Policy 7. Emergency Response and Evacuation Plan and Ammonia Emergency Procedures 8. 2019 Five-year Mechanical Integrity Report 9. 2018 and 2020 PSM Audits 10. 2008 Pre-startup safety review of the ammonia refrigeration system 11. Ammonia safety data sheet (Airgas) 12. Relief valve calculation CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. Management 2. Ventilation Room calculations 3. Release system pressure relief valve and header 4. Compressors, Evaporators, HPR vessel, HTPR vessel, LTPR vessel, LLTST standard operating procedures (SOP) 5. 2020 and 2021 SOP certification 6. Training Policy 7. Level 1 and Level 2 training description 8. Employee Participation Policy 9. Cooler and Freezer Charging lines proposal (July 19, 2019) 10. Mechanical Integrity Resolution list (recommendation tracking) 11. Process Hazard Analysis Resolution list (recommendation tracking) 12. Ammonia invoices, including initial ammonia invoice (September 25, 2008) vessel Concerns: 1. Facility doesn't have the Safe Upper and Lower Limits information pertaining to the technology of the process for temperatures, pressures, flows or compositions (the limits in the SOP appear to be operational limits) 2. Release scenario doesn't document what information the facility relied on to identify environmental receptors 3. Facility is not implementing its Management of Change and/or Pre-Startup Safety Review policies after a change in process. 4. According to the Emergency Plan, the facility waits until the ammonia concentration reaches 250ppm to call the fire department. Cartridge respirators used by emergency responding staff protects only up to 250 ppm of ammonia. This could lead to responding staff being in a dangerous situation and a delay in the emergency response. 5. The Risk Management Plan in the database still has an outdated emergency contact. Page 4 of 6 DIGITAL SIGNATURES NATALIA Digitally signed by NATALIA VAZQUEZ RIVERA Report Author: _V_A_Z_Q__U_E_Z__R_I_V_E_R__A_D-_0a5_t'e0_:02'_02_1_.1_1._01_0_9:_04_:4_8___ Section Chief: __________________________________ Page 5 of 6 Facility Name: Sysco Food Service Freezer Facility Location: 501 S. Wolf Road, Des Plaines, Illinois 60016 Date of Inspection: September 28, 2021 APPENDICES AND ATTACHMENTS 1. Digital Image Log 2. Inspection Checklist Page 6 of 6 Facility Name: Sysco Food Service Freezer Facility Location: 501 S. Wolf Road, Des Plaines, Illinois 60016 Date of Inspection: September 29, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Greg Chomycia 2. Archival Record Location: OneDrive Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 File Name IMG_0345.JPG IMG_0346.JPG IMG_0347.JPG IMG_0348.JPG IMG_0349.JPG IMG_0350.JPG IMG_0351.JPG IMG_0352.JPG IMG_0353.JPG IMG_0354.JPG IMG_0355.JPG IMG_0356.JPG IMG_0357.JPG IMG_0358.JPG IMG_0359.JPG IMG_0360.JPG IMG_0361.JPG Date and Time (incl. Time zone and DST) 2021:09:28 09:19:28 2021:09:28 09:20:05 2021:09:28 09:27:51 2021:09:28 09:27:57 2021:09:28 09:28:05 2021:09:28 09:28:33 2021:09:28 09:30:51 2021:09:28 09:32:44 2021:09:28 09:34:01 2021:09:28 09:34:48 2021:09:28 09:35:48 2021:09:28 09:44:48 2021:09:28 09:55:03 2021:09:28 10:02:55 2021:09:28 10:08:15 2021:09:28 10:09:44 2021:09:28 10:09:45 Latitude and Longitude 42.043194, -87.910156 42.043144, -87.91095 42.043167, -87.910661 42.043158, -87.910828 42.043378, -87.910867 42.0438, -87.910872 42.042969, -87.910744 42.043442, -87.911156 42.043053, -87.910819 42.043133, -87.911514 42.0434, -87.911164 42.043622, -87.911033 42.043483, -87.90995 42.044406, -87.910278 42.044572, -87.911111 42.044575, -87.911111 42.044575, -87.911111 Description of Image Freezer Engine Room Door Freezer Engine Room Second Door HPR-1 Vessel HPR-1 Vessel Plate HTPR Vessel HTPR Vessel Plate HTPR Pump HTPR Oilpot RC-1 Service Record RC-1 PRV RC-1 Roof Pipping Evaporator EV-11 in Penthouse Float Valve PRV Evaporator no. 10 (flooded evaporator) with surge tank Evaporator Surge Tank Plate Evaporator Surge Tank Plate Appendices Page 1 of 2 Facility Name: Sysco Food Service Freezer Facility Location: 501 S. Wolf Road, Des Plaines, Illinois 60016 Date of Inspection: September 29, 2021 18 IMG_0362.JPG 201241:2:079:1:248 42.043514, -87.911142 Ammonia Loading Valves Appendices Page 2 of 2