Document gEv2YnYnpm2J5rN0z3bpX5ogJ

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Custom Foods of America Knoxville, Tennessee July 18, 2023 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 Custom Foods of America (Custom Foods) facility located in Knoxville, Knox County, Tennessee. This facility was selected for inspection because it has not been inspected in the last five years under the RMP. The inspection, which was conducted on July 18, 2023, 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. Numerous documents were provided for review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Custom Foods facility is located in Knoxville, Tennessee. This facility uses anhydrous ammonia for refrigeration purposes. The refrigeration process, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for cold food storage. The process is regulated as program level 3. According to facility records, the facility has a maximum of 39,000 pounds of 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: Justin Stark (Inspector-In-Training), U.S. EPA Region 4 Inspector: Jordan Noles, U.S. EPA Region 4 Inspector: Chetan Gala, U.S. EPA Region 4 Date of Facility Visit: July 18, 2023 Facility Identification Name: Custom Foods of America Street Address: 3600 Pleasant Ridge Road City: Knoxville County: Knox EPA Facility ID No: 1000 0021 4243 Dun & Bradstreet (D&B) No: 102059615 Latitude: 35.977530 Longitude: -083.971360 State: Tennessee Zip: 37921 Name, address and phone of corporate parent company: Owner/Operator: Custom Foods of America Mailing Address: 3600 Pleasant Ridge Road City: Knoxville State: Tennessee Zip: 37921 Phone: (865) 525-0401 Name, title, and email of person responsible for 40 CFR Part 68 implementation: Name: Tony Williams Title: Vice President of Operations Phone: (865) 525-0401 Email: tonywilliams@rightfromscratch.com Name and title of emergency contact: Name: Tony Williams Title: Vice President of Operations Day phone: (865) 525-0401 24-hour Phone: (865) 405-8653 Email: tonywilliams@rightfromscratch.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Mitch Harrison Title: Refrigeration Contractor Phone: (704) 200-4464 Email: mitchh@republicrefrigeration.com Name: Grant Archdale Title: NA Phone: (865) 335-8222 Email: tnviring@gmail.com Name: Charle LeCroy Title: Maintenance/ Refrigeration Manager Page 2 of 7 Custom Foods of America, Knoxville, TN CAA 112 (r), Risk Management Program, Inspection Report Phone: (865) 307-2430 Email: CLeCroy@rightfromscratch.com Name: Carter Breeding Title: NA Phone: (865) 525-0401 Email: cbreeding@rightfromscratch.com Name: Tony Williams Title: Vice President of Operations Phone: (865) 525-0401 Email: tonywilliams@rightfromscratch.com Note: This is a not a union facility. Date and Program Levels of Submitted Risk Management Plan (RMP) Date of initial submission: April 1, 2011 Date of most recent submissions: March 30, 2021 Process: Ammonia Refrigeration Process ID: 1000115463 Program Level as reported in RMP: 3 NAICS code: 311991 (Perishable Prepared Food Manufacturing) 3.0 Observations The inspection of the Custom 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 inspection out-brief was conducted where EPA inspectors described their observations. Observations from the RMP inspection at the Custom 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 (RAGAGEP). During the facility walk-through, the Inspection Team observed faded and peeling labels on ammonia piping connected to both Low Temperature Recirculated Liquid tanks, and on ammonia piping on top of the "New" and "Old" side of the facility's roof. Lack of adequate pipe labeling for ammonia piping is inconsistent with the following RAGAGEP: Page 3 of 7 Custom Foods of America, Knoxville, TN CAA 112 (r), Risk Management Program, Inspection Report o Section 5.14.5 of American National Standards Institute/International Institute of Ammonia Refrigeration (ANSI/IIAR) 2 (2014) states, "All piping mains, headers and branches shall be identified with the following information: 1. "AMMONIA;" 2. Physical state of the ammonia; 3. Relative pressure level of ammonia, being low or high as applicable; 4. Pipe service, which shall be permitted to be abbreviated; and 5. Direction of flow. The marking system shall either be one established by a recognized model code or standard or one described and documented by the facility owner." o Section 7.2.9.4 of ANSI/IIAR 9 (2020) states, "Ammonia piping mains, headers, and branches shall be identified with the following information: 1. "AMMONIA;" 2. Physical state of the ammonia; 3. Relative pressure level of ammonia, being low or high as applicable; 4. Pipe service, which shall be permitted to be abbreviated; and 5. Direction of flow." During the facility walk-through, the Inspection Team observed corrosion on ammonia piping inside the Ammonia Machinery Room (AMR). Additionally, corrosion was observed on ammonia piping connected to the High-Pressure Receiver and Low Temperature Recirculated Liquid tank, and ammonia piping tagged "V3" and "V4" by the Condensers. Also, corrosion was observed on ammonia piping on the "New" side of the roof near or at tags "CL1", "CL2", "P1", "P2", "P3", "S1", "S2", "S3", and "RF1." Lastly, heavy corrosion was observed on ammonia piping and supports on the "Old" side of the roof near or at tags "BC1", "BC2", "BC4B", "FF1", "FF2", "AU33", and "AU35." Piping with surface damage and corrosion shall be further evaluated and treated in accordance with the following RAGAGEP: o Section 11.1.1 of ANSI/IIAR 6 (2019) states, "where pitting, surface damage, general corrosion, or a combination thereof is visually observed on a metal surface of piping, deficient areas shall be further evaluated per Section 11.1.1.1 - 11.1.1.3." During the facility walk-through, the Inspection Team observed ammonia piping with breached/damaged insulation in the AMR. Additionally, ammonia piping with breached/damaged insulation as well as uninsulated piping with frost buildup on the "Old" side of the roof was observed. Uninsulated piping is inconsistent with the following RAGAGEP: Page 4 of 7 Custom Foods of America, Knoxville, TN CAA 112 (r), Risk Management Program, Inspection Report o Section 5.10.1 of ANSI/IIAR 2 (2014) states, "piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup." o Section 7.2.6 of ANSI/IIAR 9 (2020) 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." During the facility walk-through, the Inspection Team observed exposed wiring in the AMR by the Auto-Purger. Damaged or exposed wiring is inconsistent with the following RAGAGEP: o Section 400.12.1 of National Fire Protection Association (NFPA) 70 (2020) states, "Unless specifically permitted in 400.10, flexible cords, flexible cables, cord sets, and power supply cords shall not be used for the following: 1. As a substitute for the fixed wiring of a structure 2. Where run through holes in walls, structural ceilings, suspended ceilings, dropped ceilings, or floors 3. Where run through doorways, windows, or similar openings 4. Where attached to building surfaces." During the facility walk-through, the Inspection Team observed a single eyewash/safety shower outside the AMR and did not identify an eyewash/safety shower inside the AMR. o Section 6.7.1 of ANSI/IIAR 2 (2014) states, "Each machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room, each meeting the requirements in Section 6.7.3." o Section 6.7.3 of ANSI/IIAR 2 (2014) states, "Installation Standard. Emergency eyewash/safety shower unit installations shall comply with American National Standards Institute/International Safety Equipment Association (ANSI/ISEA) Z358.1." Page 5 of 7 Custom Foods of America, Knoxville, TN CAA 112 (r), Risk Management Program, Inspection Report o Section 7.4.2 of ANSI/ISEA Z358.1 (2009) states, "It is the installer's responsibility to ensure that combination units shall: Be in accessible locations that require no more than 10 seconds to reach. The combination unit shall be located on the same level as the hazard and the path of travel shall be free of obstructions that may inhibit its immediate use." o Section 7.3.7.2 of ANSI/IIAR 9 (2020) states, "Each machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room, each meeting the requirements in Section 7.3.7.3." During the facility walk-through, the Inspection Team observed that there were no audible alarms present outside of the AMR doors to alert employees of an ammonia release as required by Section 6.13.1.3 of ANSI/IIAR 2-2014. 2. 40 C.F.R. 68.73(d)(1) requires the owner or operator to perform inspections and testing on process equipment. 40 C.F.R. 68.73(d)(2) requires inspection and testing procedures to follow recognized and generally accepted good engineering practices. 40 C.F.R. 68.73(d)(3) requires the frequency of inspections and tests of process equipment to be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. 40 C.F.R. 68.73(d)(4) requires the owner or operator to document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. The facility is conducting inspections on its process equipment. However, the facility could not demonstrate that testing is being conducted on process equipment. 3. 40 C.F.R. 68.79(a) requires the owner or operator to certify that they have evaluated compliance with the provisions of 40 C.F.R. Part 68, Subpart D at least every three years to verify that procedures and practices developed under 40 C.F.R. Part 68, Subpart D are adequate and are being followed. A Compliance Audit was required to be completed in 2019. The facility did not complete a Compliance Audit until July 23, 2023. 4. 40 C.F.R. 68.93(a) requires the owner or operator of a stationary source to coordinate response needs with local emergency planning and response organizations at least annually, and more frequently, if necessary, to address changes: At the stationary source; in the stationary source's emergency response and/or emergency action plan; and/or in the community emergency response plan. 40 C.F.R. 68.93(c) requires the owner or operator to document coordination with local authorities, including: The names of individuals involved Page 6 of 7 Custom Foods of America, Knoxville, TN CAA 112 (r), Risk Management Program, Inspection Report and their contact information (phone number, email address, and organizational affiliations); dates of coordination activities; and nature of coordination activities. The facility could not demonstrate that it performs the annual emergency response coordination activities with local responders. Inspection Report, Prepared by: Digitally signed by JUSTIN JUSTIN STARK Date: 2023.09.25 12:32:13 STARK _______________-_04_'0_0'__________ Justin Stark, Inspector-In-Training North Air Enforcement Section U.S. EPA Region 4 JORDAN JORDAN NOLES Digitally signed by _N___O___L__E___S__________1_2_:_5_7_:_01 -04'00' Date: 2023.09.25 Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER ______________________D_at_e:_2_02_3_.0_9_.2_5_14_:3_9_:3_4_-0_4_'0_0_' _ Jason Dressler, Section Chief North Air Enforcement Section U.S. EPA Region 4 Page 7 of 7 Custom Foods of America, Knoxville, TN CAA 112 (r), Risk Management Program, Inspection Report