Document g24m0zbBO0VvZ1LVGnK9Ba7Ze

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Freezer Services of Michigan, Detroit, Michigan Jason Schenandoah, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Freezer Services of Michigan (Freezer Services) Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Erin DuMontelle, Environmental Engineer 3. Danny Nguyen, Environmental Engineer Other Attendees: 1. Andy Monks, Plant Manager, Freezer Services 2. Dan Margherio, Operator, Freezer Services 3. Dan Margherio Jr., Operator, Freezer Services Contact Email Address: andrewmonks@sbcglobal.net Purpose of Inspection: To assess compliance with the Chemical Accident Prevention Provisions (CAPP) at 40 C.F.R. Part 68 Facility Type: Ammonia refrigeration facility Regulations Central to Inspection: The CAPP at 40 C.F.R. Part 68 Arrival Time: 9:15 am Departure Time: 4:00 pm Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Provided CBI warning to facility The following information was obtained verbally from Freezer Services personnel unless otherwise noted. Process Description: Freezer Services operates an ammonia refrigeration system to regulate temperature at a logistics warehouse. The facility stores frozen foods and vegetables obtained from customers in its operational region. Product is received by and leaves the facility via truck. There are 7 freezer rooms, 1 cooler room, and 1 inspection room at the facility that are serviced by the ammonia refrigeration system. The rooms are maintained at different temperatures based on product need. The facility reports as a program level 3 process. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: In the north rail dock, some evaporators were mounted approximately 12 feet above the ground level. The north rail dock is used as a staging area for loading and unloading. Several pallets of materials were in the north rail dock during the tour. When asked if pallets in the north rail dock were ever stacked, Andy Monks said that the pallets were stacked, if necessary. The following evaporators were noted to have no guards to protect from any incidental contact and product is trafficked, staged, or stored within a short distance (e.g. within a forklift turning radius) from the evaporator: RD1 RD2 Page 2 of 8 Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 I1 I2 *a dent was observed in the sheet metal of this evaporator 3A 4A 4B 5A 5B 6A 6B 7A 7B No emergency stop button was located outside of the ammonia refrigeration machine room. Each door to the machine room was not locked, they did not have a quick escape capability, and they did not appear to be fire rated doors. The north machine room door did not have a National Fire Protection Association (NFPA) label. No eyewash station or portable eye wash units were located inside the machine room. Ammonia sensors in use at the facility were calibrated in May 2023. The sensors will alarm if ammonia concentration reaches 100 parts per million (ppm), but not before. The sensors are located one at the eastern side of the machine room and another that was outdoors, approximately 10 to 15 feet to the northwest, from the exhaust of the machine room ventilation, and at a lower elevation. The machine room ventilation is on the west wall, with the ammonia refrigeration equipment in the middle of the room, and the indoor ammonia sensor to the east of the equipment. Ammonia odors were detected near compressor 2 in the machine room and outside near the low temperature accumulator. Some of the ammonia refrigeration equipment is located in a caged area just outside of the machine room. Pressure relief valves on the high-pressure receiver, the intercooler, the flush tanks, and the low temperature accumulator exhaust between, approximately, 7 to 15 feet from the ground. Some valves on the ammonia refrigeration equipment were frozen over and would not be able to turn without the ice being removed. There were portions of the ammonia piping with exposed insulation. The horizontal tank in the caged area had insulation missing from portions of it and the label was peeling off. The main shut off valve for the ammonia refrigeration system was obstructed by other piping. The ammonia piping on the roof of the facility was missing labels in many areas and some labels that were existent were worn away. There are no audio or visual alarms located in the caged-in equipment area. Photos and/or Videos: were taken during the inspection. See Appendix A: Digital Image Log Field Measurements: were not taken during this inspection. RECORDS REVIEW The following files were submitted to EPA prior to and reviewed during the inspection: 1. Hamtramck Fire Dept.docx 2. 2014 Compliance Audit Recommendation Tracking.pdf Page 3 of 8 Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 3. 2014 Compliance Audit Report.pdf 4. 2017 Compliance Audit Recommendation Tracking.pdf 5. 2017 Compliance Audit.pdf 6. cont qualif 2023.pdf 7. Contractor Policy.pdf 8. Contractor Qualification Form - Blank.pdf 9. SWP#5 Plant Entry and Security.pdf 10. Crisis Management Plan.pdf 11. emergency action rev 2023.doc 12. Employee Participation Plan of Action.pdf 13. Hot Work Permits & Safe Work Practices.pdf 14. Incident Investigation Blank.pdf 15. LOTO Procedure.pdf 16. Management Chart.pdf 17. Management Structure.pdf 18. MOC - Blank print out from APSM.pdf 19. MOC - Ventilation Upgrade 2009.pdf 20. 2010 MI Inspection.pdf 21. MI Procedure.pdf 22. Alternate Release Scenario.pdf 23. Off-Site Consequence Analysis.pdf 24. Worst Case Scenario.pdf 25. SOP Certification History.pdf 26. SOPs - TOS.pdf 27. PSSR - Blank print out from APSM.pdf 28. 2013 PHA Recommendation Tracking.pdf 29. 2013 PHA Revalidation.pdf 30. 2018 PHA Recommendation Tracking.pdf 31. 2018 PHA Report.pdf 32. Process Hazard Analysis Policy.pdf 33. Anhydrous-Ammonia-SDS.pdf 34. P&ID Reference Library.pdf 35. PSI Library.pdf 36. Training Dates for Operators.pdf 37. Training Program.pdf The following findings were discovered while reviewing the facility's Risk Management Plan (RMP): Process Safety Information (PSI): The facility's ventilation system was upgraded in 2009 and the PSI was not updated to include the new system design. Page 4 of 8 Operating Procedures: Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 The emergency shutdown procedures did not include a description of the conditions in which the emergency shutdown should be initiated. The operating procedures were not reviewed on an annual basis; the last two times the operating procedures had been reviewed were May 17, 2023, and December 15, 2017. Mechanical Integrity: The mechanical integrity procedures include an annual in-depth mechanical integrity inspection that is to be conducted. Records indicate that the inspection had not occurred since 2010. Compliance Audit: The last two compliance audits completed by the company were in 2014 and 2017. Many of the recommendations from the 2017 compliance audit were not documented as resolved until May 2023; some recommendations had yet to be completed. Management Structure: The management structure did not delineate and define the responsibilities of the RMP. Process Hazard Analysis (PHA): The 2018 PHA team did not include an operator knowledgeable in the process. The PHAs were not actively shared with employees whose work assignments are in the process or may be affected by the PHA recommendations. The 2013 and 2018 PHAs still have action items that have not been resolved. The PHAs did not include consequences of failure of engineering and administrative controls. Management of Change: There were no written procedures to manage changes to process chemicals, technology, equipment, and procedures that affect covered process. The management of change form for the 2009 ventilation upgrade had checked the "no" checkbox for whether process safety information should be updated. Page 5 of 8 Training: Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 Refresher training had not been completed every three years for the process operators. Off-site Consequence Analysis (OCA): Environmental and public receptors were not included in the OCA documentation. Emergency Response: Freezer Services personnel was not aware if the facility is included in the community emergency response plan. Freezer Services has only communicated to emergency response officials through an annual walkthrough by the fire department and through Tier II submittals. RMP submittal: The Local Emergency Planning Committee (LEPC) contact information was not included in the RMP submittal. The most recent date of coordination with emergency responders was not included in the RMP submittal. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Compliance Assistance: EPA inspectors made the following suggestions: Product stored at the same height and within a turning radius of an evaporator should no longer be stored in that section of the racks until guards can be placed around the evaporators. The ammonia sensor in the machine room should be between the ammonia refrigeration equipment and the ventilation. Pressure relief valve exhaust piping height should be reassessed to assure compliance with the International Institute for Ammonia Refrigeration (IIAR) standards. A low-level alarm should be associated with the ammonia detection system for early detection of potentially hazard ammonia conditions. Concerns: The RMP findings listed in the Records Review section were expressed as concerns and they should be addressed by the facility. Machine room doors need: o To be locked Page 6 of 8 Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 o Have a quick escape capability o Be fire rated o Need NFPA labels displaying hazards There should be an eyewash station or portable eye wash unit inside the machine room. Valves on ammonia refrigeration equipment should not be frozen over to the point that they're unable to turn. There should be audio and visual alarms located in the caged in equipment area. The alarm setpoint for the ammonia sensors were set at 100ppm DIGITAL SIGNATURES JASON Digitally signed by JASON SCHENANDOAH SCHENANDOAH Date: 2023.07.19 Report Author: _____________1_8:_17_:0_9 -_05_'0_0'_____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2023.07.20 _N_a_t_h_a_n_______1_6:_46_:5_8 _-05_'0_0'______________ Page 7 of 8 Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 8 of 8 Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Erin DuMontelle; Jason Schenandoah 2. Archival Record Location: Photos are stored in the Electronics Record Center in case file Enf_FreezerServicesofMichigan_MI_23 Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 File Name IMG_0381.JPG IMG_0382.JPG IMG_0383.JPG IMG_0384.JPG IMG_0385.JPG IMG_0386.JPG IMG_0387.JPG IMG_0388.JPG IMG_0389.JPG IMG_0390.JPG IMG_0391.JPG IMG_0392.JPG IMG_0393.JPG IMG_0394.JPG IMG_0395.JPG Date and Time (EDT) 5/25/2023 1:34 PM 5/25/2023 1:35 PM 5/25/2023 1:38 PM 5/25/2023 1:38 PM 5/25/2023 1:44 PM 5/25/2023 1:45 PM 5/25/2023 1:48 PM 5/25/2023 1:50 PM 5/25/2023 1:55 PM 5/25/2023 1:34 PM 5/25/2023 2:07 PM 5/25/2023 2:07 PM 5/25/2023 2:08 PM 5/25/2023 2:11 PM 5/25/2023 2:14 PM Description of Image Evaporator the north loading dock Ice buildup in the top corner of freezer room #1 to the left of the north loading dock entrance Inspection Room I2 evaporator with dent Inspection Room I2 evaporator with dent - closer view of IMG_0383.JPG 3A evaporator 3A evaporator - closer view of IMG_0385.JPG 6B evaporator - underside view next to storage shelving 7A evaporator - underside view next to storage shelving Machine Room - main door from inside the facility that leads into the machine room Machine Room - ice buildup on overhead insulation Duplicate photo of IMG_0390.JPG* Machine Room - broken label on Compressor 2 Machine Room - main door from inside the facility that leads out of the machine room Machine Room - door from outside of the facility that leads into the machine room Duplicate photo of IMG_0394.JPG* Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 16 IMG_0396.JPG 5/25/2023 PRV tag on main ammonia tank 2:14 PM 17 IMG_0397.JPG 5/25/2023 Duplicate photo of IMG_0396.JPG* 2:16 PM 18 IMG_0398.JPG 2:16 PM view of IMG_0396.JPG 5/25/2023 PRV tag on main ammonia tank - closer 19 IMG_0399.JPG 5/25/2023 Duplicate photo of IMG_0398.JPG* 2:16 PM 20 IMG_0400.JPG 2:16 PM away view of IMG_0396.JPG 5/25/2023 PRV tag on main ammonia tank - further 21 IMG_0401.JPG 5/25/2023 Duplicate photo of IMG_0400.JPG* 2:16 PM 22 IMG_0402.JPG 2:18 PM away view of IMG_0396.JPG 5/25/2023 PRV tag on main ammonia tank - farthest 23 IMG_0403.JPG 5/25/2023 Duplicate photo of IMG_0402.JPG* 2:18 PM 24 IMG_0404.JPG 2:20 PM tank 5/25/2023 PRV tags on left side of the Intercooler 25 IMG_0405.JPG 2:23 PM from the right side of the tank 5/25/2023 PRV on front of the Intercooler tank - view 26 IMG_0406.JPG 5/25/2023 Duplicate photo of IMG_0405.JPG* 2:23 PM 27 IMG_0407.JPG 5/25/2023 Low Temp tank - left side view 2:25 PM 28 IMG_0408.JPG 5/25/2023 Duplicate photo of IMG_0407.JPG* 2:25 PM 29 IMG_0409.JPG 5/25/2023 Low Temp tank - front view 2:25 PM 30 IMG_0410.JPG 5/25/2023 Duplicate photo of IMG_0409.JPG* 2:25 PM Receiver tank (center) with external vent 31 IMG_0411.JPG 5/25/2023 from the Machine Room (upper right) and 2:29 PM the outdoor ammonia sensor (bottom left along wall) 32 IMG_0412.JPG 5/25/2023 Duplicate photo of IMG_0411.JPG* 2:29 PM 33 IMG_0413.JPG 5/25/2023 External vent from the Machining Room - Point of View from next to the outdoor 2:30 PM ammonia sensor Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 34 IMG_0414.JPG 5/25/2023 Duplicate photo of IMG_0413.JPG* 2:30 PM 35 IMG_0415.JPG 5/25/2023 Main shut-off valve (King valve) located between the High-Pressure Receiver (HPR) 2:31 PM tank and the Intercooler tank 36 IMG_0416.JPG 5/25/2023 Duplicate photo of IMG_0415.JPG* 2:31 PM 37 IMG_0417.JPG 5/25/2023 Corrosion on the HPR tank 2:34 PM 38 IMG_0418.JPG 5/25/2023 Duplicate photo of IMG_0417.JPG* 2:34 PM 39 IMG_0419.JPG 5/25/2023 Corrosion on the HPR tank 2:34 PM 40 IMG_0420.JPG 5/25/2023 Duplicate photo of IMG_0419.JPG* 2:34 PM 41 IMG_0421.JPG 5/25/2023 Iced-over valve on the Intercooler tank 2:36 PM 42 IMG_0422.JPG 5/25/2023 Duplicate photo of IMG_0421.JPG* 2:36 PM 43 IMG_0423.JPG 5/25/2023 Iced-over valve near the Low Temp tank 2:36 PM 44 IMG_0424.JPG 5/25/2023 Duplicate photo of IMG_0423.JPG* 2:36 PM 45 IMG_0425.JPG 5/25/2023 Iced-over valve near the Low Temp tank 2:36 PM 46 IMG_0426.JPG 5/25/2023 Duplicate photo of IMG_0425.JPG* 2:36 PM 47 IMG_0427.JPG 5/25/2023 Machine Room - secondary door from inside the facility that leads into the 2:38 PM Machine Room 48 IMG_0428.JPG 2:44 PM worn ammonia labeling 5/25/2023 Ammonia pipe racks near condensers with 49 IMG_0429.JPG 5/25/2023 Duplicate photo of IMG_0429.JPG* 2:44 PM 50 IMG_0430.JPG 2:46 PM dock area with worn labels 5/25/2023 Ammonia piping rack above the 1900 aisle 51 IMG_0431.JPG 5/25/2023 Duplicate photo of IMG_0430.JPG* 2:46 PM 52 IMG_0432.JPG 2:49 PM worn labels 5/25/2023 Ammonia piping above the 1500 aisle with Facility Name: Freezer Services of Michigan Facility Location: 8350 St. Aubin Street, Detroit, MI 48211 Date of Inspection: May 25, 2023 53 IMG_0433.JPG 5/25/2023 Duplicate photo of IMG_0432.JPG* 2:49 PM 54 IMG_0434.JPG 5/25/2023 Ammonia piping rack supports 2:52 PM 55 IMG_0435.JPG 5/25/2023 Additional ammonia piping 2:53 PM 56 IMG_0436.JPG 5/25/2023 Duplicate photo of IMG_0435.JPG* 2:53 PM *An error occurred with the camera during certain photos and a duplicate was created