Document mBmo76725YJQO7JBYJXyvQBZ

Clean Air Act - Risk Management Program Section 112(r) Emergency Planning Community Right-to-Know Act Sections 302, 311 and 312 On-site Compliance Inspection Report Americold Logistics, LLC PURPOSE The purpose of this On-site Compliance Inspection was to determine compliance with the Clean Air Act Section 112(r) Risk Management Program (40 C.F.R. Part 68) and the Emergency Planning and Community Right to Know Act Sections 302, 311 and 312. CAA Section 112(r)(7) requires facilities that hold more than a threshold quantity of a regulated substance in a process to develop and implement a Risk Management Program. PCRA Section 311 requires facilities that hold chemicals above reporting threshold to submit copies of the SDSs or a list of these chemicals to the State Emergency Response Commission, the Local Emergency Planning Committee and the local fire department. EPCRA Section 312 requires the Annual Chemical Inventory Reports (Tier II) for the current calendar year to be submitted by March 1 of the following year. The Tier II is required to be submitted to the SERC, LEPC and fire department. EPCRA Section 302 requires any facility that has any EHS above the threshold planning quantities to notify the SERC and LEPC. LEPCs should also include the EHS(s) in their emergency response plans. Facilities covered under EPCRA Section 312 are required to indicate on the Tier II if they are subject to EPCRA Section 302 emergency planning requirements. COMPANY INFORMATION Name: Americold Logistics, LLC Mailing Address: 10 Glenlake Parkway, Suite 600, South Tower Atlanta, Georgia 30328 Website: https://www.americold.com/ FACILITY INFORMATION Name: Americold Burley Plant #80557 Facility Address: 280 West Highway 30 Burley, Idaho 83318 Latitude/Longitude: 42.535258, -113.849761 RMP Facility ID#: 100000159909 FRS ID#: 110000757903 EJ Concerns: Yes (90%) RMP/EPCRA On-site Inspection Report Revision Date: 2/21/2024 Page 1 of 7 CONTACT INFORMATION (RMP Implementation) Name: Jennifer Campbell Title: Regional PSM Phone Number: (971) 221-1105 E-mail: jennifer.campbell@americold.com EMERGENCY CONTACT INFORMATION Name: Nick Bailey Title: EMM Phone Number: (208) 553-1236 E-mail: nick.bailey@americold.com INSPECTION DETAILS Inspection Date: Inspection Time: Inspectors: September 18, 2024 9:00 AM 2:15 PM Edward Johannes, US EPA R10, SEE Grantee, Lead RMP/EPCRA Inspector Peter Phillips, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Erin Williams, US EPA R10, RMP/EPCRA Inspector Mhara Coffman, US EPA R10, RMP/EPCRA Inspector Ryan Bowlsby, US EPA R10, RMP/EPCRA Inspector-in-Training On September 9, 2024, EPA emailed a Notice of Inspection Letter to the facility informing them of a planned RMP and EPCRA inspection. The letter included CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives, such as a union representative, have the right to participate in the RMP inspection. A copy of the letter must be provided to the employee representatives and the letter posted in a manner accessible to employees in the facility. Is the facility is unionized? If yes, name of union: Was an employee representative present during the inspection? If yes, name/title: Yes No Yes No GENERAL INFORMATION The facility is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by Americold Logistics, LLC (Americold). Americold operates with one shift between 8:00 AM to 4:30 PM Monday through Friday. There are twenty-six full-time employees on site. Originally Atlantic Ice & Coal Company, the 120-year-old Americold based in Atlanta, Georgia, has grown to be the second largest temperature-controlled warehousing and distribu on services provider in the world. Americold owns and operates 245 temperature-controlled warehouses, with approximately 1.5 billion refrigerated cubic feet of storage, around the world. Americolds facilities serve food producers, processors, distributors, and retailers to consumers. The facility in Burley, Idaho, is a third-party cold storage warehouse that chills and freezes a variety of food products. The facility uses 24,327 pounds of anhydrous ammonia to maintain temperaturecontrolled atmospheres in two areas (F and G) designated as freezer rooms and one cooler room. The Page 2 of 7 refrigeration process consists of one engine room with four screw compressors, two high pressure receivers, associated piping, valves, and equipment, that cycles anhydrous ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) to provide refrigeration for the cold storage and freezer rooms. The safety equipment in the engine room includes ammonia sensors and alarms, two king valves, pressure relief valves, emergency ventilation via four wall intake louvers and two ceiling exhaust fans, and an eyewash/shower stations located inside and outside the engine room. A maintenance contractor, Superior Industrial Refrigeration calibrates the ammonia sensors every two years. The facility has an Emergency Action Program (EAP) in place. The Emergency Action Team (EAT) is trained as a First Responder Operations Level and gets annual training. All EAT members are fit tested and respiratory trained annually. DATE AND PROGRAM LEVELS OF SUBMITTED RMP Initial Submission Date: August 18, 1999 Date of Latest Update: November 14, 2022 Has the facility has been inspected in the past 5 years? If yes, date of last inspection: Is the facility High Risk? Yes No Yes No Process (as reported in the RMP) Process ID Description 1000128313 Anhydrous Ammonia Process Chemical ID 1000160894 NAICS Code 49312 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs.) 24,372 CAA TITLE V AIR PERMIT Does the facility have a CAA Title V Permit? If yes, permit number: Yes No EMERGENCY RELEASE / ACCIDENT HISTORY Did an RMP reportable release occur in the past 5 years? Did a CERCLA/EPCRA reportable release occur in the past 5 years? If either yes, date and description of release: Yes No Yes No Page 3 of 7 EPCRA 312 TIER II REPORT Was the 2023 Tier II report submitted to the SERC? If yes, date Tier II was submitted: February 7, 2024 If no, calendar year of the most recent Tier II: Was the 2023 Tier II submitted to the LEPC/fire department? If yes, date Tier II was submitted: February 7, 2023 Is the facility subject to EPCRA Section 302? If yes, is it correctly checked on the Tier II? Is the subject to RMP correctly checked on the Tier II? Is RMP facility ID correct on the Tier II? Yes No Yes No Yes No Yes No Yes No Yes No EPCRA CHEMICALS OVER THRESHOLD According to the most recent Tier II, the facility stores the following hazardous chemicals over the reporting threshold. See the attached Tier II, Attachment C, for inventory amounts. Chemical Name Anhydrous Ammonia Sulfuric Acid Lead EHS (Yes or No) Yes Yes No CAS Number 7664-41-7 7664-93-9 7439-92-1 EPCRA 311 SDSs The facility stores two EHS on-site over the TPQ and is subject to EPCRA Section 302. See Attachment B for SDSs and chemical information on the EHSs stored over the reporting threshold at the Facility. EPCRA 302 LEPC Coordination Emailed invitations to the LEPC to conduct joint exercises. LEPC Agency: Program Contact: Title: Address: Phone Number: Email: Website: Cassia County Office of Emergency Management Jennifer Gee Director 129 East 14th Street Burley, Idaho 83318 (208) 878-1002 jgee@cassiacounty.org https://www.cassia.gov/emergency-management Page 4 of 7 INSPECTION ENTRY Edward Johannes led the inspection entry. The inspection team met with Nick Bailey at the Americold facility in Burley, Idaho. The team arrived at the facility at 9:00 a.m. and was joined by the following facility personnel: Nick Bailey Jennifer Campbell Sasha Olsen Name Title Engineering & Maintenance Manager Regional Process Safety Manager General Manager Were any SERC, LEPC or fire department representative present? If yes, names and titles of representatives: Yes No Is the facility a first responder? If no, responding agency: Burley Fire Department Yes No The inspection team was escorted to a conference room. Introductions were made by Edward Johannes, who provided a summary of the risk management program and explained the purpose of the visit. Each team member presented their credentials. EPA requested an explanation of the facilitys operations and any additional safety measures that should be taken during the site tour. Close-toed safety shoes, eye protection, and hearing protection were required while touring the facility. FACILITY TOUR / ON-SITE OBSERVATIONS The facility tour was conducted from approximately 9:30 AM to 10:20 AM. The inspection team was escorted by Nick Bailey, Jennifer Campbell, and Sasha Olsen. The inspection team observed the engine room, freezers, chiller room, condensers on the roof and the forklift battery charging area. Photographs were taken of these areas and are included in Attachment A. Freezers F and G were observed containing piping, evaporators (mounting reinforced above racks), and ammonia detectors (Photos 1 and 2). Facility representatives stated the ammonia detector activates audible and visual alarms at 25 parts per million (ppm) and the emergency ventilation system in the engine room activates at 50 ppm. The emergency shutdown for the compressors activates at an ammonia concentrations reaching 1%. An emergency eyewash station and return hoist were observed in the forklift battery charging area (Photos 3, 4, and 5). In the chiller room an ammonia detector is located on the ceiling and two evaporators are located behind the product racks (mounting was not reinforced above the racks) (Photos 6, 7, and 8). The engine room entrance door has ammonia hazard placards, an air sampling port sign, an authorized personnel only notice, a ventilation control switch next to the door not labeled and emergency/constant fan warning lights above the door (Photo 9). No emergency stop button was seen next to engine room entrance door. An emergency eyewash/shower station is in the maintenance Page 5 of 7 area next to the engine room (Photo 10). An ammonia smell was present in the engine room after oil was drained from the oil separator. In the engine room there are four screw compressors (Photos 11 and 18), high pressure receiver (HPR) (Photo 15), low pressure receiver (LPR), V-4 subcooler (Photo 24), V-4 oil pot (some rust present), and oil separators. Pressure relief valves (PRV) with installation tags for each compressor has an install date of August 2020 (Photos 12 and 25). The engine room ventilation system has two ceiling exhaust fans, and four louvered air intakes (Photos 11, 16, 20, 23, 26, and 32). The engine room exit doors have push bars (Photos 13 and 16). Removed insulation was visible on ammonia piping (blue colored) for a compressor, a valve was marked with a red tag and piping is labeled with directional arrows (Photo 14). The lockout/tagout station is located in the engine room (Photo 19). The HPR manual king valve is labeled (Photo 15). A second manual king valve located at ceiling level is labeled and accessible using a chain (Photo 21 and 22). Ice buildup is visible on valves, piping and equipment (Photos 15 and 25). Two ammonia detectors are in the engine room that alarm at 25 ppm, activate the ventilation at 50 ppm, and shut down the engine room at 1% LEL (Photos 17 and 24). An emergency eyewash/shower station is located in the engine room (Photo 22). A monthly oil management log is kept in the engine room that operators use to record the draining and adding of oil for vessels and equipment (Photo 27). A spill release procedure, emergency contact and safety information and hot works board is in the maintenance area (Photos 28 and 29). Three condensers are located on the roof above the engine room (Photo 30). An emergency stop button and ventilation controls located outside the engine room next to the rollup doors were not labeled (Photo 31). The outside entrance door located on the west side of the engine room has ammonia hazard placards, an authorized personnel only notice, a constant fan notice, and emergency/constant fan warning lights above the door (Photo 32). The Emergency Response Unit trailer is located in the parking lot near the engine room (Photo 33). A windsock is located on the northeast corner of the roof of the engine room (Photo 34). The outside entrance door located on the north side of the engine room has only an authorized personnel only notice; no warning placards are posted (Photo 34). Ammonia diffusion tank, mislabeled MH3, is located adjacent to the condensers. After touring the RMP-covered process areas and the EPCRA chemical storage areas, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Nick Bailey, Jennifer Campbell, and Sasha Olsen. INFORMATION COLLECTED FROM FACILITY No information was collected from the facility during the inspection. AREAS OF CONCERNS 1. Ammonia pipe attached to Compressor #2 is not capped. 2. Ammonia diffusion tank is mislabeled as MH3 (metal hydride). 3. Outside entrance door on north side of engine room has no posted ammonia and NFPA hazard warning placards. 4. Access to the Emergency Response Unit (ERU) trailer by Americolds response team may be impacted during an ammonia release. Americold should consider relocating the ERU trailer away from the engine room. Page 6 of 7 FOLLOW-UP DOCUMENTS REQUESTED The following documents were unable to be located during the inspection by the facility representatives. The documents were requested to be sent to EPA by October 2, 2024. The documents were to be reviewed after the inspection to determine compliance with Section 112(r) of the CAA. The facility did not provide the requested document. 1. 2023 PHA recommendations. 2. 2020 and 2023 CA recommendations. ON-SITE INSPECTION REPORT CERTIFICATION This is to certify that I, Edward Johannes, as the lead inspector for the On-site Compliance Inspection and that I have verified the accuracy of the information in this report. __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator Signature __________________________________________________________ EPCRA Coordinator Signature __________________________________________________________ Land Enforcement Section Chief Signature ATTACHMENTS A. Photo Log and Photographs B. Safety Data Sheets (SDSs) C. Tier II Submission Page 7 of 7 ATTACHMENT A Photo Log and Photographs