Document gDX32Od6VpjxjXLwBqOejQdqN

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Monogram Assembled Foods Dickson, Tennessee July 28, 2022 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 the ammonia refrigeration process at the Monogram Assembled Foods facility located in Dickson, Dickson County, Tennessee. This facility was selected for inspection because it had not been inspected since change of ownership under the RMP. The inspection, which was conducted on July 28, 2022, consisted of an examination of program documentation, as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Requested program documents were provided for further review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Monogram Assembled Foods facility is located in Dickson, Tennessee. The facility uses anhydrous ammonia as a refrigerant to manufacture packaged frozen foods. The process is regulated as program level 3. According to facility records, the facility has a maximum of 27,099 pounds of anhydrous ammonia on site. The ammonia refrigeration 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: Bethany Terpin, EPA Inspector: Jordan Noles, EPA Inspector-In-Training: Chet Gala, EPA Date of Facility Visit: July 28, 2022 Facility Identification Name: Monogram Assembled Foods Street Address: 1655 Old Columbia Road City: Dickson County: Dickson EPA Facility ID No: 1000 0019 4452 Dun & Bradstreet (D&B) No: NA Latitude: 36.047500 Longitude: -087.345278 State: Tennessee Zip: 37055 Name, address and phone of corporate parent company: Owner/Operator: Monogram Food Solutions Mailing Address: 530 Oak Court Drive Suite 400 City: Memphis State: Tennessee Phone: 901-685-7167 Zip: 38117 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Willie Gordon Title: Plant Manager Phone: (803) 439-6816 Email: wgordon@monogramfoods.com Name and title of emergency contact: Name: Evan Ingersoll Title: EHS Manager Day phone: (615) 229-1841 24-hour Phone: (724) 552-7622 Email: eingersoll@monogramfoods.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Don Morgan Title: Maintenance Manager Phone: (731) 418-9003 Email: dmorgan@monogramfoods.com Name: Lynn Buldhaupt Title: Director of Environmental Compliance Phone: (507) 227-5304 Email: lbuldhaupt@monogramfoods.com Name: Evan Ingersoll Title: EHS Manager Phone: (724) 552-7622 Email: eingersoll@monogramfoods.com Page 2 of 4 Monogram Assembled Foods, Dickson, TN CAA 112 (r), Risk Management Program, Inspection Report Name: Randy Horseman Title: PSM Phone: (615) 289-2792 Email: rhorseman@monogramfoods.com Name: Kent Munich Title: HR Manager Phone: (615) 864-1469 Email: kmunich@monogramfoods.com Name: Willie Gordon Title: Plant Manager Phone: (803) 439-6816 Email: wgordon@monogramfoods.com Name: Tom Jenson Title: QA/FS Manager Phone: (763) 732-2958 Email: tjenson@monogramfoods.com Name: Deborah Spradlin Title: PSM Consultant Phone: (713) 818-7751 Email: dspradlin@hcgassoc.com Note: This is not a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: March 22, 2022 Date of most recent submissions: March 22, 2022 Process: Refrigeration System Process ID: 1000124286 Program Level as reported in RMP: 3 NAICS code: 311991 (Perishable Prepared Food Manufacturing) 3.0 Observations The inspection of the Monogram Assembled Foods 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. The discussion was followed by a tour of the facility's ammonia refrigeration process areas. EPA inspectors then requested paperwork associated with the facility's Risk Management Plan (RMPlan). The documents were reviewed by EPA inspectors on-site and provided for review off-site. An Page 3 of 4 Monogram Assembled Foods, Dickson, TN CAA 112 (r), Risk Management Program, Inspection Report inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Monogram Assembled Foods 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, there were four pressure relief valves (Valves # OP-1-5, OP-2-5, C-1-9, and C-1-10) that were required to be replaced in April 2021, but were still in service. Section 13.1.1 of ANSI/IIAR 6 (2019) states, "All pressure relief valves (PRVs) that relieve to atmosphere shall be recertified or replaced on the 5-year time-based frequency." Section 13.1.1.1 of ANSI/IIAR 6 (2019) states, "The service life of the PRV shall not exceed 5 years of service after it is installed on the system." Inspection Report, Prepared by: Digitally signed by BETHANY BETHANY TERPIN TERPIN Date: 2022.09.19 10:23:40 -04'00' ____________________________ Bethany Terpin, Inspector North Air Enforcement Section U.S. EPA Region 4 Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER ______________________D_a_te_:_2_02_2_.0_9_.1_9_1_4:_0_2:_20_-_0_4'_0_0' Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4 Page 4 of 4 Monogram Assembled Foods, Dickson, TN CAA 112 (r), Risk Management Program, Inspection Report