Document npBvXmwa8Baq9bJYLD4YJ6YY1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Inspection Report FACILITY INFORMATION: Name: Frosty Packing Co., LLC Physical Address: 2820 River Road, Yakima, WA 98902 Phone Number: 509-245-5231 Latitude/Longitude: 46.616892 / -120.546406 RMP Facility ID# 100000200203 FRS ID#: 110015562764 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Stanley Bostrom Phone Number: 509-248-5231 E-mail: sbostrom@jackfrostfruit.com EMERGENCY CONTACT INFORMATION: Name: Paul Martinez Phone (24-hr): 509-961-4909 E-mail: paulm@jackfrostfruit.com TRIP DETAILS: Inspection Date: Inspection Time: Inspectors: 4/26/2022 0900 hours through 1145 hours Bob Hales, US EPA Region 10 SEE Grantee, Lead RMP Inspector Peter Phillips, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, EPCRA Inspector Lisa Graves, Weston Solutions, Inc., EPA START Contractor 7/01/22 Page 1 of 5 DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: October 1, 2007 Date of Latest Update: January 1, 2018 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000084534 Description Anhydrous Ammonia Process Chemical ID 1000105522 NAICS Code 42448 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 17,883 PURPOSE: The purpose of this inspection 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. The facility has been previously inspected in the past 5 years: No Yes If Yes, Date of Last Inspection: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 2/24/2022 If No, calendar year of the most recent Tier II: No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 2/24/2022 INSPECTION ENTRY: Bob Hales led the inspection entry. The inspection team met with Stanley Bostrom at the Frosty Packing Co., LLC facility in Yakima, Washington. The EPA Inspection Team arrived at the facility at 0900 hours and was joined by the following facility personnel: Stanley Bostrom Mike Davis Carol Davis Vickie Silva Name Title CFO Ammonia Compliance Ammonia Compliance Food Safety Manager Page 2 of 5 Eddie Medino Paul Martinez Refrigeration Operator Managing Partner Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: No Yes The facility is a first responder: If No, Responding Agency: Yakima City Fire Department No Yes The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Bob Hales, who provided a summary of the risk management program (RMP) and explained the purpose of the visit. Each team member presented his/her credentials. EPA then requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Stanley Bostrom gave a brief description of the facility, operations, and personal protective equipment required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the 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, and that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: If Yes, Name of Union: No Yes An employee representative present during the facility visit: If Yes, Name/Title: Vickie Silva, Food Safety Manager No Yes GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by Frosty Packing Co., LLC (Frosty Packing Co., formerly Jack Frost Fruit Co.). The facility operates as an apple packing and refrigeration warehouse throughout the year, and employs an ammonia refrigeration system. There are 230 full-time employees on site, two of whom are responsible for the oversight of refrigeration operations. Frosty Packing Co. (the facility) packages and stores apples in refrigerated rooms while the produce awaits shipment. Designated Refrigeration Operators check the ammonia system each operating workday, and all refrigerated areas are continuously monitored by an ammonia leak detection system. A computer system remotely notifies the Refrigeration Operators when an alarm is triggered, or when refrigeration parameters are out-of-range. There are no process modifications that impact the facility's refrigeration system. The facility has established an Emergency Action Plan (EAP) in the event of an ammonia release, and all employees participate in an annual training and drill for the EAP. Page 3 of 5 ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 0915 hours to 1015 hours. The EPA Inspection Team was escorted by facility representatives Mike Davis, Vickie Silva, and Eddie Medino. EPA observed the single mechanical room supporting the facility ammonia refrigeration system (Mechanical Room #1), the Vessel Room, two cold storage rooms (Cold Storage Room 1A and Cold Storage Room 2A), and two controlled atmosphere rooms (Controlled Atmosphere Room 1 and Controlled Atmosphere Room 19). The condenser units of the facility refrigeration system are located on the building rooftop of the South Complex (Photo 1). Mechanical Room #1 serves as the sole engine room for the facility's refrigeration system (Photos 2-9), and houses primary system components including compressors, regulator valves, exhaust fans, intake vents, and an ammonia leak detection device. A dedicated room identified as the Vessel Room houses one high pressure receiver (HPR) tank with an associated king valve, and an ammonia leak detection device (Photos 24-26). An office adjacent to the Vessel Room houses a computer terminal and an ammonia sensor network panel (Photos 20-23) that allow facility personnel to monitor all facility refrigeration equipment parameters. EPA inspected Cold Storage Room 1A (Photos 13 and 14), Cold Storage Room 2A (Photos 10-12), Controlled Atmosphere Room 1 (Photos 18 and 19) and Controlled Atmosphere Room 19 (Photos 15-17). The primary equipment observed in each of these rooms include an evaporator, an ammonia sensor intake, and an ammonia leak detection device. EPA observed the facility ammonia refrigeration equipment as clearly labeled and tagged, with appropriate safety features in place. Photographs of the refrigeration system components and pertinent safety measures are included in Attachment A to this report. After touring the RMP-covered process areas at the facility, the inspection team returned to the conference room to review the pertinent RMP documentation. Upon completion of the document review, EPA provided a debriefing to Stanley Bostrom, Mike Davis, Carol Davis, Vickie Silva, Eddie Medino, and Paul Martinez. INFORMATION COLLECTED FROM FACILITY: 1. List of PHA Audit Team Members AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Some pressure relief valves (PRVs) were identified as past due for replacement in Machine Room #1. The facility was aware of this issue and were ordering new PRV replacements for installation. [68.73(d)(3)]. 2. The facility Process Hazard Analysis (PHA) documentation from November 2017 provided a recommendation on the replacement of all galvanized pipes for release valves. The recommendation stated "not applicable" without providing the reason why this recommendation was declined. [68.67]. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. These documents will still be reviewed to determine compliance with Section 112(r) of the Clean Air Act. All documents requested from the inspection were reviewed on site or are included in this report. Page 4 of 5 INSPECTION REPORT CERTIFICATION: This is to certify that I, Bob Hales, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 5 of 5