Document reGXxJVRB7n950ZBG2e6RV847

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 Tyson Foods Inc. PURPOSE The purpose of this On-site Compliance Inspection was to determine compliance with the Clean Air Act (CAA) Section 112(r) Risk Management Program (RMP) and the Emergency Planning and Community Right to Know Act (EPCRA) Sections 302, 311 and 312. CAA Section 112(r) requires facilities that hold chemical over threshold quantities to have an RMP. EPCRA Section 311 requires facilities that store chemicals above reporting threshold to submit copies of the Safety Data Sheets (SDSs) or a list of these chemicals to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), 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 Extremely Hazardous Substance (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: Tyson Foods Inc. Mailing Address: PO Box 4239 Pasco, WA 99302 Website: https://tysonfreshmeats.com/ FACILITY INFORMATION Name: Tyson Fresh Meats, Pasco, WA Facility Address: 13983 Dodd Road Wallula, WA 99302 Latitude/Longitude: 46.136944/-118.913611 RMP Facility ID#: 1000 0000 6405 EPCRA Tier II ID#: WAD099143984 FRS ID#: 110000601616 EJ Concerns: No RMP/EPCRA On-site Inspection Report Revision Date: 2/21/2024 Page 1 of 7 CONTACT INFORMATION (RMP Implementation) Name: Barbara Salter Title: Complex Manager Phone Number: (509) 547-7545 E-mail: barbara.salter@tyson EMERGENCY CONTACT INFORMATION Name: Jose Vergara Title: Complex Engineer Phone Number: (509) 543-4340 E-mail: jose.vergara@tyson.com INSPECTION DETAILS Inspection Date: Inspection Time: Inspectors: May 15, 2024 09:00 a.m.-2:10 p.m. Mhara Coffman, US EPA R10, Lead RMP/EPCRA Inspector Terry Garcia, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Edward Johannes, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Peter Phillips, US EPA R10, SEE Grantee, RMP/EPCRA Inspector Erin Williams, US EPA R10, RMP/EPCRA Inspector Robert Faries, Weston Solutions, Inc., EPA START Contractor On May 2, 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 RMP as a Program Level 3 facility and is owned and operated by Tyson Foods Inc. There are approximately 1,350 full-time employees on site. The facility was built in 1976 and purchased by Tyson Foods in 2001. The facility underwent a renovation to add a wing for Wendy's fast food chain beef production that was operational by 2019. Tyson Fresh Meats, Pasco, WA is a beef processing and packaging facility. The facility utilizes anhydrous ammonia to cool controlled atmosphere (CA) rooms throughout the facility. The refrigeration process is comprised of two components, which the facility identifies as the Harvest Ammonia System and the Processing Ammonia System. Each system features a dedicated engine room. The facility has a threelevel alarm system for atmospheric ammonia and lower explosive limit (LEL). When atmospheric ammonia levels reach 25 parts per million (ppm), the system triggers emergency ventilation and an audible/visible alarm. At 150 ppm emergency ventilation fans engage and ammonia alarms require a Page 2 of 7 manual reset. Refrigeration systems shut down when the atmosphere reaches 2% LEL (20,000 ppm). The facility stores EPCRA-regulated chemicals in the form of cleaning products stored in the Acid Base Storage Room and fuel for facility vehicles located at the Facility Fueling Station. DATE AND PROGRAM LEVELS OF SUBMITTED RMP Initial Submission Date: May 7, 1999 Date of Latest Update: May 6, 2024 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 Process Chemical ID 1000141374 1000141375 Harvest Ammonia System 1000176849 Processing Ammonia System 1000176850 NAICS Code 1000099462 1000099463 Program Level 3 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Ammonia, Anhydrous (7664-41-7) Quantity (lbs.) 55,345 78,495 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 RPM reportable release occur in the past 5 years? Did a CERCA/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: 29 February, 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: 29 February, 2024 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 Lead-Acid Batteries Unleaded Gasoline Peracetic Acid EHS (Yes or No) Yes Yes No Yes CAS Number 7664-41-7 007664-93-9 086290-81-5 79-21-0 EPCRA 311 - SDSs EHS onsite include some cleaning supplies, lead acid batteries used in the facility's forklifts, and anhydrous ammonia used in the facility's refrigeration systems. See Attachment B for SDSs and chemical information on each EHS stored over the reporting threshold at the Facility. EPCRA 302 - LEPC Coordination The facility's last coordination with Walla Walla LEPC was a facility tour on 13 May, 2024. LEPC Agency: Program Contact: Title: Address: Phone Number: Email: Website: Walla Walla County LEPC Chris Lee Director 27 North Second Ave. Walla Walla, WA 99362 (509) 524-2902 clee@co.walla-walla.wa.us co.walla-walla.wa.us Page 4 of 7 INSPECTION ENTRY Mhara Coffman led the inspection entry. The inspection team met with Daniel Goldfarb at the Tyson Fresh Meats, Walla Walla, Washington facility . The team arrived at the facility at 9:00 a.m. and was joined by the following facility personnel: Seth Schwarzkopf Luke Klingenberg Barbara Salter Jose Vergara Bianca Bandurski Daniel Goldfarb Name Title RMP Area Manager Refrigeration Manager Complex Manager Plant Engineer Industrial Engineer Environmental Manager Were any SERC, LEPC or fire department representative present? Yes No If yes, names and titles of representatives: Patrick Purcell, Walla Walla EMD Is the facility a first responder? If no, responding agency: Yes No The inspection team was escorted to a conference room. Introductions were made by Mhara Coffman, who provided a summary of the RMP and explained the purpose of the visit. Each team member presented their credentials. EPA requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. The covered areas of the facility are the Harvest Building, Process Building, and Wendy's Wing. During the outdoor portions of the inspection, the facility requires personnel to wear hardhats, Hi-Vis vests, hearing protection, safety glasses, and close-toed shoes. During the indoor portion of the inspection, the same PPE is required with the addition of a hair net. FACILITY TOUR / ON-SITE OBSERVATIONS The facility tour was conducted from approximately 09:45 a.m. to 11:35 a.m. The inspection team was escorted by Seth Schwarzkopf, Luke Klingenberg, Jose Vergara, Bianca Bandurski, and Daniel Goldfarb. EPA observed the Harvest Engine Room, and other refrigeration process equipment outside the engine room. The condensers are located on the roof above the engine room (Photos 1). The Harvest Engine Room hazcom signage is located on the entrance door (Photo 2). Inside the Harvest Engine Room, EPA observed the system control panel, fire extinguisher, ammonia transfer lines, air intakes and exhaust vents (Photos 3, 5 and 6), emergency shower and eyewash station (Photo 7), and ammonia sensors, and compressors (Photos 4, 8-11). The recirculator and king valve are located outside the engine room (Photos 12 and 13). The Fueling Station stores gasoline and diesel used for onsite vehicles (Photo 14). The liquid carbon dioxide tank stores an EPCRA regulated substance is located in the rendering area near the Process Engine Room (Photo 15). Page 5 of 7 Ventilation system exhaust ducts are located above the Process Engine Room (Photo 16). Emergency audio and visual alarms and shutdown button were located outside the Process Engine Room's entrance door (Photo 17). Emergency information and warning/caution signs were posted on the engine room entrance door (Photo 17). Frost was observed on several sections of piping on refrigeration system equipment in the engine room (Photos 18 and 19). A compressor maintenance log was observed in the engine room (Photo 20). A missing dial for chiller and three, open buckets collecting used oil were observed (Photos 21-24). An emergency shower and eyewash station, four ammonia sensors, and an audio/visual alarm were observed in the engine room (Photos 25-28). An emergency ventilation switch for the Processing Engine Room is located near the pump out room entrance door (Photo 29). The pump out room entrance door had appropriate hazcom signage (Photo 30). The control panel for the Processing Engine Room is located by the pump out room. A vertical high pressure receiver (HPR) is located inside the Processing Pump Out Room (Photo 31). The condensers are located on the rooftop above the Processing Engine Room (Photos 32 and 33). Ammonia transfer lines are located on the rooftop (Photos 34-37). The piping was labeled and color coded. A rusty pump-out ammonia line (orange) was observed on the rooftop (Photo 38). EPCRA-regulated industrial cleaning supplies are stored in the Acid Base Storage Room. Chemicals are separated by acids and bases and an emergency shower and eyewash station is present in the room (Photos 39 and 40). The liquid carbon dioxide and nitrogen vertical storage tanks are located outside on the exterior of the Wendy's wing (Photo 41). EPA Inspectors Mhara Coffman and Erin Williams, and EPA Contractor, Robert Faries continued the tour of the process areas escorted by Luke Klingenburg, and Bianca Bandurski. Ammonia transfer lines and evaporators were observed in the Box Storage Area where beef is packaged and stored (Photos 42-45). Ammonia transfer lines were observed in the Wendy's Wing (Photos 46-47) and the Carcass Storage Area (Photo 48). After touring the indoor 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 Barbara Salter, Seth Schwarzkopf, Luke Klingenberg, Jose Vergara, Bianca Bandurski, Daniel Goldfarb. INFORMATION COLLECTED FROM FACILITY During the inspection no documentation was collected. Page 6 of 7 AREAS OF CONCERNS The following is a list of areas of concern identified. 1. Tyson Fresh Meats has no documentation on emergency coordination activities between 2018 and 2024 and emergency response exercises with the fire department. [68.10(b)-(d)]. The LEPC and Walla Walla County fire department toured the facility on May 13, 2024. 2. Tyson Fresh Meats has not developed and implemented an exercise program for its emergency response program. Tyson Fresh Meats was unable to provide documentation of coordination with emergency response personnel or emergency response contractors for field and tabletop exercises. [68.96(b)(1) and (b)(2)]. 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 29 May, 2024. These documents were reviewed after the inspection to determine compliance with Section 112(r) of the CAA. 1. Provide documentation of emergency coordination since 2018. ON-SITE INSPECTION REPORT CERTIFICATION This is to certify that I, Mhara Coffman, 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 Attachment A: Photo Log and Photographs Attachment B: Tier II Report Page 7 of 7 Attachment A - Photo Log Site Name: Tyson Fresh Meats City, State: Pasco, WA Photographer: Robert Faries, Weston Solutions File Photo1.jpg Photo2.jpg Photo3.jpg Photo4.jpg Photo5.jpg Photo6.jpg Photo7.jpg Photo8.jpg Photo9.jpg Photo10.jpg Photo11.jpg Photo12.jpg Photo13.jpg Photo Layout ID Date 1 5/15/2024 2 5/15/2024 3 5/15/2024 4 5/15/2024 5 5/15/2024 6 5/15/2024 7 5/15/2024 8 5/15/2024 9 5/15/2024 10 5/15/2024 11 5/15/2024 12 5/15/2024 13 5/15/2024 Time 9:45 AM 9:49 AM 9:52 AM 9:52 AM 9:55 AM 9:58 AM 10:00 AM 10:05 AM 10:10 AM Description Roof-mounted condenser atop Harvest Engine Room Location in Facility: Harvest Building Roof Entrance to Harvest Engine Room with hazcom signage Location in Facility: Harvest Engine Room Refrigeration system control panel Location in Facility: Harvest Engine Room Refrigeration system compressor Location in Facility: Harvest Engine Room Ammonia transfer lines and system exhaust vent Location in Facility: Harvest Engine Room Ammonia transfer lines and system air intake Location in Facility: Harvest Engine Room Emergency shower and eyewash station Location in Facility: Harvest Engine Room Ammonia sensors Location in Facility: Harvest Engine Room Ammonia sensors and alarm Location in Facility: Harvest Engine Room 10:12 AM Overview of ammonia transfer lines, system controls, and receivers Location in Facility: Harvest Engine Room 10:12 AM 10:15 AM 10:15 AM Refrigeration system belt-driven compressor Location in Facility: Harvest Engine Room King valve outside engine room Location in Facility: Harvest Engine Room Exterior Harvest recirculator with inspection plate Location in Facility: Harvest Engine Room Exterior Photo14.jpg Photo15.jpg Photo16.jpg Photo17.jpg Photo18.jpg Photo19.jpg Photo20.jpg Photo21.jpg Photo22.jpg Photo23.jpg Photo24.jpg Photo25.jpg Photo26.jpg Photo27.jpg Photo28.jpg Photo29.jpg 14 5/15/2024 10:17 AM Gasoline and diesel fuel storage and pumps Location in Facility: Fueling Station 15 5/15/2024 10:18 AM Liquid carbon dioxide tank Location in Facility: Facility Exterior near Process Engine Room 16 5/15/2024 10:18 AM Process ventilation system, vent outlets are located on the roof Location in Facility: Process Area Exterior 17 5/15/2024 10:18 AM Processing Engine Room entrance with hazcom signage and alarm Location in Facility: Processing Engine Room 18 5/15/2024 10:19 AM Frosted refrigeration system equipment Location in Facility: Processing Engine Room 19 5/15/2024 10:20 AM Frosted refrigeration system equipment Location in Facility: Processing Engine Room 20 5/15/2024 10:20 AM Compressor inspection log Location in Facility: Processing Engine Room 21 5/15/2024 10:21 AM Missing dial on refrigeration system chiller Location in Facility: Processing Engine Room 22 5/15/2024 10:22 AM Used oil bucket staged near refrigeration equipment Location in Facility: Processing Engine Room 23 5/15/2024 10:22 AM Used oil bucket staged near refrigeration equipment Location in Facility: Processing Engine Room 24 5/15/2024 10:22 AM Used oil bucket staged near refrigeration equipment Location in Facility: Processing Engine Room 25 5/15/2024 10:22 AM Ammonia alarm Location in Facility: Processing Engine Room 26 5/15/2024 10:23 AM Emergency shower and eyewash station Location in Facility: Processing Engine Room 27 5/15/2024 10:23 AM Ammonia sensors Location in Facility: Processing Engine Room 28 5/15/2024 10:23 AM Ammonia sensors Location in Facility: Processing Engine Room 29 5/15/2024 10:23 AM Manual ventilation control Location in Facility: Processing Pump Out Room Photo30.jpg Photo31.jpg Photo32.jpg Photo33.jpg Photo34.jpg Photo35.jpg Photo36.jpg Photo37.jpg Photo38.jpg Photo39.jpg Photo40.jpg Photo41.jpg Photo42.jpg Photo43.jpg Photo44.jpg Photo45.jpg 30 5/15/2024 10:24 AM Door to Processing Pump Out Room with hazcom signage and alarm Location in Facility: Processing Pump Out Room 31 5/15/2024 10:24 AM High pressure receiver Location in Facility: Processing Pump Out Room 32 5/15/2024 10:27 AM Condensers Location in Facility: Rooftop of Processing Engine Room 33 5/15/2024 10:27 AM Condensers Location in Facility: Rooftop of Processing Engine Room 34 5/15/2024 10:28 AM Overview of facility refrigeration system transfer lines Location in Facility: Rooftop 35 5/15/2024 10:28 AM Overview of ammonia transfer lines Location in Facility: Rooftop 36 5/15/2024 10:29 AM Overview of ammonia transfer lines Location in Facility: Rooftop 37 5/15/2024 10:32 AM Overview of ammonia refrigeration transfer lines Location in Facility: Rooftop 38 5/15/2024 10:32 AM Rusty pump-out ammonia line (orange) Location in Facility: Rooftop 39 5/15/2024 10:57 AM Emergency shower and eyewash station Location in Facility: Acid Base Chemical Storage Area 40 5/15/2024 10:59 AM Overview of EPCRA regulated chemicals Location in Facility: Acid Base Chemical Storage Area 41 5/15/2024 11:11 AM Carbon dioxide and nitrogen storage tanks Location in Facility: Facility Exterior Wendy's Wing 42 5/15/2024 11:20 AM Ammonia transfer lines Location in Facility: Box Storage Area 43 5/15/2024 11:22 AM Ammonia transfer lines Location in Facility: Box Storage Area 44 5/15/2024 11:23 AM Ammonia transfer lines Location in Facility: Box Storage Area 45 5/15/2024 11:25 AM Ammonia transfer lines and evaporators Location in Facility: Box Storage Area Photo46.jpg Photo47.jpg Photo48.jpg 46 5/15/2024 11:33 AM Ammonia transfer lines Location in Facility: Wendy's Wing 47 5/15/2024 11:35 AM Ammonia transfer lines Location in Facility: Wendy's Wing 48 5/15/2024 11:35 AM Ammonia transfer lines Location in Facility: Carcass Storage Area