Document k61o2DR98YDjL2b8xeDGeGZnq

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Kemps LLC, Rochester, Minnesota FROM: Natalia Vazquez, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 EPA Inspector(s): 1. Natalia Vazquez, Environmental Engineer 2. Matthew Walters, Environmental Engineer Other Attendees: 1. Corey Ramer, Plant Manager, Kemps LLC 2. Thomas Jenkins, EHS Manager, Dairy Farmers of America 3. Dawn Robinson, PSM Coordinator, Kemps LLC 4. Brock Cunningham, Sr. PSM Coordinator, JS Compliance 5. Tim Morrow, Chief Engineer, Kemps LLC 6. Josh Lobdell, Union Representative and operator, Kemps LLC Contact Email Address: dawn.robinson@kemps.com, thomas.jenkins@dafamilk.com Purpose of Inspection: ammonia refrigeration system inspection Facility Type: ice cream manufacturing facility and warehouse with an ammonia refrigeration system Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 Regulations Central to Inspection: 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Arrival Time: 9:00 a.m. Departure Time: 2:40 p.m. 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. Provided CBI warning to facility The following information was obtained verbally from Corey Ramer, Tom Jenkins, Dawn Robinson unless otherwise noted. Process Description: Ammonia refrigeration is a 2-stage refrigeration system with a single engine room, controls in the engine room. The system is used for cooling storage silos, ice cream freezers, frozen storage, and area cooling. High stage is used for the silos and area cooling, and low stage is used for the ice cream freezers and storage room. The silos are directly cooled by ammonia. The system was expanded in the 1990s, no current knowledge of its size prior to the expansion. Most of the refrigeration equipment is located in the engine room, but condensers and the three high pressure receivers are on the roof. Staff Interview: The Facility operates five days of the week, 24 hours. Maintenance employees are on site 24 hours, seven days of the week, three shifts. Kemps has about 169 employees on site, about 19 in maintenance and in direct contact with the ammonia refrigeration system. The Facility hasn't had any major changes in the past five years. The Facility had its most recent coordination activity with Rochester Fire Department on July 12, 2024. Kemps Hazards Assessment can be found in the Confidential Business Information Inspection Report Supplement. Kemps had in its process safety information (PSI) records the following codes and standards listed: EPA, API, ASHRAE, NIOSH, and NRC. Jenkins stated that Kemps is in the process of transitioning its Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 paperwork to align with IIAR 6 and they are also following IIAR 9, specifically replacing bulletins. JS Compliance (contractor) is assisting Kemps to follow codes and standards and verify compliance through process hazard analysis (PHA) and compliance audits. The calculated ammonia inventory is 63,692 pounds. Ventilation system is being updated through a capital project that has approved funding. Kemps has ammonia detecting sensors with an alarm system that report to a central location on-site. There is no off-site alarm monitoring, but maintenance employees are on-site 24 hours seven days of the week. Kemps has several portable ammonia sensors at the maintenance shop. Inspectors observed current calibration stickers on these sensors. The process of verifying if P&ID are accurate only takes place if the Facility is doing a new PHA, but not if it's completing a revalidation. The 2014 PHA was a new evaluation due to the change in ownership and the 2019 PHA was a revalidation. The Facility is planning on doing a revalidation for the next PHA as there were no major changes in the system. Kemps uses the PHA matrix to prioritize what recommendations to complete first, that is critical before convenient, while also tackling easy projects right away. The recommendation to install ammonia sensor in vent lines has been time consuming. The Facility has a quote for the ammonia sensors for vent lines and hopes to complete this project before the next PHA. APSM software used for tracking PSM documentation and action list. CMMS software is used to track maintenance records. Maintenance employees do routine per shift walkthrough of the ammonia refrigeration system. If an issue is identified during the walkthrough, it either gets immediately fixed or a work order is put in place. Kemps has a form used for the daily log that records temperatures, pressure, and level for its equipment and it's filled up at each shift (three shifts per day). The form has upper values or ranges for each parameter. Most recent vibration test was completed in March 2023. Cool Air Mechanical is the contractor that Kemps hires for non-routine maintenance on the refrigeration system. Two annual evaluations were documented for November 6, 2023, and September 12, 2022. The other contractor is used to obtain parts and its never in contact with the ammonia refrigeration system. High stage compressors each have an individual control panel and local emergency stop. Oil and filter change is done by contractor. Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 All maintenance employees go through IIAR modules and site-specific training as part of their training program. Online tests for each module are used to demonstrate understanding of the training. Emergency Response Plan has the position "Site Safety Lead" that is not attached to a single person. Kemps will respond to releases up to 150 ppm, above 150 ppm Rochester Fire Department will be expected to respond. Ammonia vapor was released from HS1 compressor on June 19, 2020. The compressor was sent out for evaluation, and it was determined that a piston or connecting rod failure caused the incident. All reviewed MOC were line breaks either for charging ammonia into the system or replacement-inkind. Tracking line breaks through MOC was a corporate decision. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: Ammonia detector in the south side of the engine room. Second floor grated roof above the north side of engine room and it has an ammonia detector. Exhaust fans set at 1,000 ppm. HS6 reciprocating compressor has a discharge pressure at 150 psi. BC4 oil separator discharge 26.5 psig and suction 9.5 Hg. The low-pressure receiver (V16) and intermediate receiver (V12) are located on the second floor above the north side of the engine room. All three high pressure receivers are on the roof. V1 High pressure receiver was at 50% level. It's pressure relief device set at 250 psi with a due date by December 2020. The king valve was located underneath the high-pressure receiver. V2 and V3 high pressure receivers are on a roof location accessible only by a fixed ladder. Pressure Relief Valve with "Replace by" tags Equipment that PRV is located "Replace by" date on tag HS9 oil separator April 2021 BC4 oil separator June 2021 V2 high pressure receiver October (year was not clearly labeled) Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 RECORDS REVIEW Prior to the Inspection 1. 2014 and 2019 Process Hazard Analysis and each respective recommendation tracker; 2. 2020 Compliance audit; 3. Pipe and Instrumentation Diagrams; and 4. List MOC logs for January 2020 to March 2024. During the Inspection 1. Process Safety Information included: a. Hazard Assessment, b. description of process equipment (17 pages), c. pressure relief valve design (3 pages), d. ventilation system design (45 pages), e. ammonia detectors (1 page), f. design codes (1 page), g. RAGAGEP electrical classification, and h. ammonia inventory calculations; 2. Individual MOCs (all replacement in kind); 3. Contractor evaluation; 4. Mechanical integrity policy; 5. Certification of SOPs (all dated July 28, 2023); 6. Emergency Response Plan CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: PSI Section 6 Equipment Description; PSI Section 8 Pressure Relief Valves; PSI Section 9 Ammonia Detectors; PSI Section 11 Design Codes and Standards; PSI Section 13 Ventilation design; MI 2020 Action List; Ammonia Delivery log; PHA action item tracking documentation; MI procedure (inspection summary and equipment list); Procedures (SOP): o Delivery Procedure, o Summary of Normal Operations Procedure, o Summary of Emergency Equipment Shutdown Procedure, and o HS Reciprocating Compressors SOP (HS 1- HS 4, and HS 6); Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 Incident report for June 19, 2020 ammonia release; Daily Round Maintenance Sheets (dates July 14, 2024 through July 16, 2024); and Two most recent work orders for the following MI inspection, testing, and maintenance items: o Functional test of engine room emergency shutdown switch located outside main engine room door, o Functional test of high discharge pressure cutout on reciprocating compressor HS 2, o Functional test of high level switch on Intercooler V-12, o Belt tension inspection/measurement on reciprocating compressor HS 6, o Stem lubrication of King Valve 3 on V-3, o Drive shaft alignment measurement on screw compressor BC 2, and o Visual inspection for damage and/or moisture in insulation for Recirculator V-16. DGITAL SIGNATURES NATALIA Digitally signed by NATALIA VAZQUEZ RIVERA VAZQUEZ RIVERA Date: 2024.09.05 15:10:16 -05'00' Report Author: _________________________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL Date: 2024.09.06 08:33:26 -05'00' __________________________________ APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Natalia Vazquez and Matthew Walters Archival Record Location: Enf_Kemps_MN_24_InspRep_Photos Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 File Name IMG_0775.JPG IMG_0776.JPG IMG_0777.JPG IMG_0778.JPG IMG_0779.JPG IMG_0780.JPG IMG_0781.JPG IMG_0782.JPG IMG_0783.JPG IMG_0784.JPG IMG_0785.JPG IMG_0786.JPG IMG_0787.JPG IMG_0788.JPG IMG_0789.JPG IMG_0790.JPG IMG_0791.JPG IMG_0792.JPG Date and Time (incl. Time zone and DST) 7/17/2024 9:54 7/17/2024 9:56 7/17/2024 10:02 7/17/2024 10:03 7/17/2024 10:06 7/17/2024 10:22 7/17/2024 10:23 7/17/2024 10:24 7/17/2024 10:27 7/17/2024 10:32 7/17/2024 10:34 7/17/2024 10:41 7/17/2024 10:44 7/17/2024 10:45 7/17/2024 10:51 7/17/2024 10:51 7/17/2024 10:54 7/17/2024 10:54 Description of Image Pressure relief valve tag on HS9 oil separator, tag with "Replace By" date of April 2021 Suction line on HS9 compressor Gauge on natural gas engine of HS6 reciprocating compressor - non-operational HS6 reciprocating compressor control panel BC6 screw compressor's pressure relief valve tag with "Replace By" date of June 2021 Pressure relief valve's on BC4 screw compressor oil separator (blurry photograph) Pressure relief valve's nameplate on BC4 oil separator showing set pressure of 300 psig (P&ID indicates set pressure should be 250 psig) BC4 oil separator with visual level indicators, drain line, and instrumentation not shown on P&ID Ammonia detector on the south side of the engine room with hand written date of "7 Aug 21" Ammonia detector on the second floor above the north engine room V16 low pressure receiver (recirculator) V1 high pressure receiver King valve V1KBM.200 with hand wheel underneath the V1 high pressure receiver Relief vent discharge near V1 high pressure receiver V2 and V3 high pressure receivers V2 high pressure receiver pressure relief valve's "replace by" tag with an October date, year is not clearly labeled V2 high pressure receiver's king valve V2KBM.200 with seal cap on stem above the receiver (V2KBM.203 is labeled as King Valve #2 on P&ID) V3 high pressure receiver's king valve V3KBM.200 with hand wheel above the receiver, with access restricted by a wall and piping (V3KBM.203) Image Number 19 20 21 22 23 24 File Name IMG_0793.JPG IMG_0794.JPG IMG_0795.JPG IMG_0796.JPG IMG_0797.JPG IMG_0798.JPG Facility Name: Kemps LLC Facility Location: 406 N Broadway Rochester Minnesota Date of Inspection: July 17, 2024 Date and Time (incl. Time zone and DST) 7/17/2024 10:55 7/17/2024 11:01 7/17/2024 11:07 7/17/2024 11:07 7/17/2024 11:08 7/17/2024 11:09 Description of Image Valves on high pressure liquid line from V3 high pressure receiver: V3KBM.201 globe valve, check valve (strainer shown in place of check valve on P&ID), V3KBM.202 solenoid valve, and V3KBM.203 globe valve (labeled as king valve on P&ID but not in field) hot has defrost (HGD) ammonia lines on roof Ammonia relief vent on north side of engine room with self-closing valve (line with self-closing valve not shown on P&ID) Ammonia relief vent and thermosyphon supply/return lines for HS9 compressor on north side of engine room ammonia recharge line Safety labels on the engine room's door, E-stop, and audible/visible ammonia alarm