Document rBz3kpjXdpRyad8xoOL8M35MG

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: OFD Foods, LLC Plant 1 Physical Address: 770 29th Ave SW, Albany, OR 97321 Phone Number: 541-926-6001 Latitude/Longitude: 44.614167, -123.111389 RMP Facility ID# 1000 0006 3691 FRS ID#: 110001657733 EJ Concerns: No (below 80%) CONTACT INFORMATION (RMP Implementation): Name: Gray Johnson Phone Number: 541-967-6413 E-mail: gray.johson@ofd.com EMERGENCY CONTACT INFORMATION: Name: Gray Johnson Phone (24-hr): 541-967-6413 E-mail: gray.johson@ofd.com Website: www.ofd.com TRIP DETAILS: Inspection Date: Inspection Time: Inspection Team: June 28, 2022 0900 hours through 1430 hours Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Tom Vroman, CIH, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: July 19, 1999 Date of Latest Update: March 1, 2022 Process (Program 1, 2, 3) as reported in RMP: Process ID Description Process Chemical ID 1000118169 Anhydrous Ammonia 1000147751 NAICS Code 311423 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 48,000 Page 1 of 5 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: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes No Yes 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: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 3/15/2022 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: 3/15/2022 INSPECTION ENTRY: Peter Phillips led the inspection entry. The EPA Inspection Team (EPA) met with facility representative Gary Johnson at the OFD Foods, LLC main office in Albany, Oregon. EPA arrived at the facility at 0900 hours and was joined by the following facility and contracted personnel: Name Gary Johnson Jason Luty Jacques Muluc Bradley Marshall Greg Skaer Title OFD Engineer HSE Manager Maintenance Manager OFD Refrigeration Coordinator OFD Consultant Was a state/county/or local emergency representative present? The facility is a first responder: No Yes No Yes The inspection team was escorted to a conference room located in the facility's office building. Introductions were made by Peter Phillips, 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. Gary Johnson 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 Page 2 of 5 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: An employee representative present during the facility visit: No Yes 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 OFD Foods, LLC (OFD). OFD operates an anhydrous ammonia refrigeration process within Plant 1 to cool rooms and the chambers where the products are freeze dried. Anhydrous ammonia is the regulated substance used in the refrigeration system equipment. Plant 1 is supported by approximately 350 employees. Plant 1 operates 24 hours a day, seven days a week, with two, 12-hour shifts each day. OFD has four trained operators for their ammonia refrigeration system. Operators and shift mechanics can remotely shutdown the refrigeration system from outside the building (Photo 26). OFD maintains an internal facility response team, consisting of 33 OFD employees who receive annual training. Supplies for the response team are located next to the parking lot of Plant 1 (Photos 36-39). OFD also coordinates with the Albany Oregon Fire Department for emergency response preparedness. There are no process modifications in the anhydrous ammonia refrigeration process. ON-SITE OBSERVATIONS: The facility tour for Plant 1 was conducted from approximately 1100 hours to 1200 hours. EPA was escorted by facility representatives Gary Johnson, Jacques Muluc, and Greg Skaer. Plant 1 has 48,000 pounds of anhydrous ammonia which runs through 15 compressors located in two adjacent engine rooms, designated as North Engine Room and South Engine Room. The engine rooms are labeled on the outside and have audio visual alarms installed outside and inside each room (Photos 1-4). Each engine room is equipped with ammonia sensors set with a low alarm at 25 ppm and a high alarm of 2 percent concentrations of ammonia in the air (Photos 7, 17). Each engine room has emergency stops installed on control panels (Photos 11, 19), and includes emergency washing stations (Photos 5, 18). The North Engine Room contains a low temperature ammonia receiver (Photo 6), pressure relief valves (Photos 8-10), the system intake and exhaust ventilation (Photos 12-14), and a high-pressure receiver (HPR) tank and associated king valve (Photos 15-16). Refrigeration components in the South Engine Room include the system intake and exhaust vents (Photos 20-23), an operational compressor designated as Compressor 9B (Photo 24), and a decommissioned compressor attached to Compressor 9B (Photo 25). Additional refrigeration system components were observed at exterior areas of the facility, including emergency shut off controls (Photo 26), ammonia tanks (Photo 27), a second HPR tank and associated king valve (Photo 28), refrigeration system compressors (Photos 32, 33), and rooftop mounted ammonia piping (Photo 34). EPA observed several safety measures in place at the exterior of the facility, including emergency shutoff controls (Photo 26), hazardous communications signage (Photos 29, 30), and a roof mounted windsock (Photo 31). EPA also observed emergency response supplies (Photos 36-39) and the training certificate for the facility ammonia operator (Photo 40). Page 3 of 5 Plant 1 also houses the lead acid battery recharging station (Photo 35), enabling two forklifts to be recharged at a given time. EPA observed the facility ammonia refrigeration equipment as clearly labeled and tagged, with appropriate safety features in place. Photographs taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at Plant 1 of OFD, the inspection team returned to the conference room to review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to the following people: Gary Johnson, Jason Luty, Jacques Muluc, Bradley Marshall, and Greg Skaer. INFORMATION COLLECTED FROM FACILITY: 1. Visitor Rules and Regulations (1 page) 2. 2022 PSM/RMP Audit Report (7 pages) 3. Site Plan - Plant 1 (1 page 11 x 14 inches) AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: No areas of concern were identified in the closing conference. DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. These documents were reviewed to determine compliance with Section 112(r) of the Clean Air Act. On 7/22/2022, OFD provided the requested information via email. 1. Updated 2022 RAGAGEPs List. The document was reviewed, and no issues were identified. 2. 2022 Compliance Audit Finding Tracking Sheet. The document was reviewed, and no issues were identified. All findings were assigned, completed, or had completion dates assigned. 3. Contractor Evaluations from Human Resources. OFD provided evaluation forms and OSHA 100 forms for the four contractors performing work on or near the refrigeration process. The document was reviewed, and no issues were identified. 4. Updated OFD Piping Specifications. The document was reviewed, and no issues were identified. INSPECTION 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: __________________________________________________________ Inspector Signature __________________________________________________________ RMP Coordinator/Approval Page 4 of 5 __________________________________________________________ EPCRA Coordinator/Approval __________________________________________________________ Land Enforcement Section Chief/Approval Page 5 of 5