Document kmKdQ0YDVmog8rM0R6gMvbrjy

Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Desk Audit Report FACILITY INFORMATION: Name: Dickinson Frozen Foods (IdaCold LLC) Physical Address: 6198 Treasure Valley Way, Nampa, Idaho Phone Number: (208) 467-4992 Latitude/Longitude: 43.609425/-116.498644 EPA Facility ID# 100000139003 CONTACT INFORMATION (RMP Implementation): Name: Todd Campbell, Director of Operations Phone Number: (208) 467-4992 E-mail: (208) 467-4992 EMERGENCY CONTACT INFORMATION: Name: Todd Campbell, Director of Operations Phone (24-hr): (208) 467-4992 E-mail: (208) 467-4992 Website: www.idacold.com AUDIT DETAILS: Contact Date: 9/2/2021 Inspector: Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: 6/24/1999 Date of Latest Update: 11/16/2017 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000083870 Description Ammonia Refrigeration Process Chemical ID 1000104747 NAICS Code 49312 Program Level 3 Chemical Name CAS Number Anhydrous Ammonia 7664-41-7 Quantity (lbs) 14,000 PURPOSE: The purpose of this document review was to determine whether this facility is in compliance with Section 112(r) of the Clean Air Act and Title 40 Code of Federal Regulations (CFR) Part 68, Chemical Accident Prevention Provisions and compliance with Section 312 of the Emergency Planning and Community Right to Know Act (EPCRA) which requires the Tier II Chemical Inventory Reports to be submitted annually. EPA Region 10 RMP inspectors will not be conducting onsite inspections due to the COVID-19 pandemic requiring restricted travel and social distancing by the Centers for Disease Control (CDC) to prevent the spread of COVID-19. EPA Region 10 will coordinate with the RMP facility to schedule an onsite inspection when the CDC has determined it is safe. The facility has been previously inspected in the past 5 years: No Yes Is the emergency contact information current? No Yes The facility is High Risk: No Yes Joint EPCRA inspection: No Yes Page 1 of 5 CAA Title V Air Permit: Does the facility have a CAA Title V Permit? No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? No Yes EPCRA TIER II REPORTING HISTORY: Did the facility submit their 2020 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 1/2/2021 No Yes Did the facility submit a Tier II to the LEPC and local fire department? If Yes, Date the Tier II was submitted: 1/2/2021 No Yes GENERAL INFORMATION: Dickinson Frozen Foods (DBA IdaCold LLC) is owned and operated by Oregon Potato Company since 2018. The facility operates as public refrigeration and cold storage warehouse in Nampa, Idaho. IdaCold LLC (IdaCold) uses and stores 14,000 pounds of anhydrous ammonia as a refrigerant. This quantity exceeds the 10,000-pound threshold limit for RMP and OSHA PSM. The facility typically operates from 4:00 AM to 9:00 PM. When the facility is closed, security is monitored by local law enforcement patrols and a private alarm company (Alarmco Inc.). IdaCold has one full-time employee onsite performing in the capacity of a shipping clerk and no refrigeration operator onsite since June 2021. The refrigeration system is monitored, maintained, and repaired by PermaCold Engineering under a contract with the facility. PermaCold can remotely monitor and shutdown the refrigeration system if there is a release of anhydrous ammonia. The facility is not a first responder and relies on the Nampa Fire Department for release response. The fire department has been onsite and release drills have been conducted in the past. The facility has four storage areas that can be arranged in various configurations by movable partitions. A single engine room houses seven compressors, three of which have been decommissioned and isolated from the refrigeration system. The refrigeration system has two condensers but due to typically light loads, only one condenser is operated on a rotational basis. INFORMATION REQUESTED FROM FACILITY: 1. Process Hazard Analysis - last two updates/revalidations. 2. Compliance Audit - last two compliance audit reports. 3. Training - operator/maintenance initial and refresher training records including safe work practices. 4. Tier II - LEPC and fire department submission documentation ANALYSIS OF DOUCMENTATION SUBMITTED: 1. Process Hazard Analysis (PHA): IdaCold LLC provided their 2014 and 2020 PHA revalidations. The 2014 PHA revalidation was conducted in September 2014. All findings (224 items) and recommendations were completed, and no items were carried over to the 2020 PHA revalidation. The 2020 PHA revalidation was finalized on 10/19/2020, not the reported date of 5/4/2015 as reported in their RMP. The 2020 PHA shows that 219 out of 224 findings and recommendations were completed with assigned staff and completion dates no later than 12/31/2021. The status of the remaining five outstanding PHA findings were submitted via email on 11/16/2021 and are as follows: Open Item Status Update Page 2 of 5 No fire drill due to COVID. What if Emergency Response Personnel responding to an ammonia release were unaware that ammonia is on site? What if the facility's electrical area classification does not segregate flammable from ignition sources? What if a line is isolated while full of NH3? What If piping is mislabeled? What if a PRV lifts and no follow-up action is taken? Fire drill completed on 10/6/2021. Nampa Fire Department tour completed on 10/28/2021. Flammable cabinet ordered on 9/9/2021. Still waiting for delivery. SOP is written and completed 11/9/2021. PermaCold is working on valve tagging and updating the Relief System Design. The target date per Sean Hart at PermaCold is 12/7/2021. Due Date for completion 12/30/2021. SOP for PRV replacement completed on 3/16/2021. The 2020 PHA revalidation was completed six years after the 2014 PHA, not the 5-year interval as required by 40 CFR 68.67(f). The facility states that this delay was due to COVID-19 restrictions. 2. Compliance Audit: IdaCold LLC provided their 2017 and 2020 Compliance Audit reports including finding tracking sheets. All 2017 audit findings and recommendations were completed, and no items were carried over to the 2020 Compliance Audit. Two findings in the 2020 Compliance Audits findings were assigned to staff with a completion date of 12/31/2021. IdaCold LLC is performing their compliance audits every three years as required by 40 CFR 68.79(c). The status of the remaining two outstanding Compliance Audit findings were submitted via email on 11/16/2021 and are as follows: Open Item Ensure the new relief valves that are going to be installed are included in the Relief System design. Ensure when the piping non-destructive testing is complete that all document is retained and placed in the PSM program file online and in the box in front Manager's office. Status Update PermaCold is working on valve tagging and updating the Relief System Design. The target date per Sean Hart at PermaCold is 12/7/2021. Due Date for completion is 12/31/2021. PermaCold completed a non-destructive test on 11/27/2017. Tests are done every 5 years, PermaCold is sending over quote to get another test completed. 3. Training: IdaCold LLC does not have any process operators on site since 6/2021. All ammonia refrigeration system repairs and maintenance are contracted through PermaCold Engineering. The following PermaCold personnel have been assigned and vetted by the facility's Contractor program for the maintenance and repair of the facility's covered process: a. Sean Hart b. Will Mullen c. Austin Burns Page 3 of 5 IdaCold LLC provided training documentation indicating that contract operators and maintenance staff have received training in safe work practices (provided in their Contractor Evaluation packet). IdaCold LLC stated that the PermaCold contract covers the repair, maintenance and operating their refrigeration process. On June 16, 2021, in a phone conversation with Mr. Sean Hart, Regional Manager for PermaCold, he stated that his company does not have a contract with IdaCold to operate their refrigeration process. Their contract with IdaCold extends to maintenance and repair functions and were unable to produce training documentation under 68.71. AREAS OF CONCERNS: 1. Process Hazard Analysis (68.67(f)): IdaCold LLC did not update and revalidate the initial PHA at least every five years. IdaCold's most recent 2020 PHA was conducted six years after their previous 2014 PHA. 2. Risk Management Plan (68.160(b)(6) & 68.195(b)): IdaCold LLC did not update the emergency contact information (name, title, phone number, & email). IdaCold LLC has listed Russ Penrod as the emergency contact. Mr. Penrod left the company in early 2021, longer than the 30-day requirement. 3. Training (68.71(a)(1)): IdaCold LLC did not document that each employee involved in operating a process, and each employee before being involved in operating a newly assigned process, been initially trained in an overview of the process and in the operating procedures. IdaCold LLC's only operator left the company in June 2021 and has not been replaced. IdaCold LLC is operating their refrigeration system without an operator. The findings in this report will be discussed with the facility via telephone and email after certification of this report. DOCUMENTS REQUESTED ON FOLLOW-UP: The following documents were requested after the initial submission of documents. were reviewed to determine compliance with Section 112(r) of the Clean Air Act. 1. The completed Training Summary Sheet. 2. The status of two open items in the 2017 Compliance Audit. 3. The status of five open items in the 2017 PHA. These documents This information was provided via email on 11/16/2021. AUDIT REPORT CERTIFICATION: This is to certify that I, Peter Phillips, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: Digitally signed by PETER PHILLIPS PETER PHILLIPS (Affiliate) (Affiliate) ______________________________D__at_e_: 2_0_2_2_.0_2_.2_8_1_2_:5_0_:1_8_-_08_'_00_'______ Signature Date Digitally signed by JAVIER JAVIER MORALES MORALES ______________________________D__a_te_:_2_0_2_2_._0_2_.2_8__1_3_:5_1__:3_7_-_0_8_'_0_0_' RMP Coordinator/Approval Date Page 4 of 5 ERIN WILLIAMS Digitally signed by ERIN WILLIAMS Date: 2022.05.04 13:28:37 -07'00' __________________________________________________________ EPCRA Coordinator/Approval Date Digitally signed by Jennifer A Jennifer A Sullivan Sullivan Date: 2022.05.04 13:50:49 -07'00' __________________________________________________________ Land Enforcement Section Chief/Approval Date Page 5 of 5