Document vy9BDmMKyjVM2Mer9mOeN6zRb

Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 - Tier II Facility Desk Audit Report FACILITY INFORMATION: Name: Sysco Alaska, Inc. Physical Address: 6601 Change Point Drive, Anchorage, Alaska Phone Number: (907) 444-6840 Latitude/Longitude: 61.16183/-149.90472 EPA Facility ID# 100000237004 CONTACT INFORMATION (RMP Implementation): Name: Joshua West Phone Number: (907) 444-6840 E-mail: Joshua.West@Sysco.com EMERGENCY CONTACT INFORMATION: Name: Joshua West Phone (24-hr): Facilities Technician E-mail: Joshua.West@Sysco.com Website: www.sysco.com AUDIT DETAILS: Contact Date: 9/2/2021 Inspector: Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: 11/10/2017 Date of Latest Update: 11/10/2017 Process (Program 1, 2, 3) as reported in RMP: Process ID 1000083593 Description Ammonia Refrigeration Process Chemical ID 1000104261 NAICS Code 42441 Program Level 3 Chemical Name CAS Number Ammonia, Anhydrous (7664-41-7) Quantity (lbs) 15,000 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 Page 1 of 4  Joint EPCRA inspection: 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? If Yes, Date and Description of the Release: 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: 2/23/2021 No Yes Did the facility submit a Tier II to the LEPC and local fire department? If Yes, Date the Tier II was submitted: 2/23/2021 No Yes GENERAL INFORMATION: The facility is regulated under the Risk Management Program as a Program Level 3 process and is owned and operated by Sysco Alaska, Inc (Sysco) whose parent company is the Sysco Corporation. Sysco started as a subsidiary of Sysco Seattle in 2004 leasing the property from Pokel Management, Green Bay, Wisconsin. In 2014, the Alaska facility was purchased from Pokel Management by Sysco and started doing business as Sysco Alaska, Inc. Sysco distributes a full line of food products and a wide variety of non-food products to both independent and chain restaurant customers in 90 countries. Sysco reported an anhydrous ammonia inventory of 15,000 pounds in their RMP exceeding the threshold quantity of 10,000 pounds of anhydrous ammonia for their refrigeration system. There are 60 full-time employees on site. Sysco did not submit an RMP to EPA when the Alaska facility was purchased in 2014. In 2017, they conducted a compliance audit and determined that the total anhydrous ammonia inventory exceeded the 10,000-pound threshold requiring an RMP. INFORMATION REQUESTED FROM FACILITY: 1. Process Hazard Analysis - last 2 PHAs or revalidations 2. Compliance Audit - last 2 compliance audit reports 3. Training - initial and refresher operator/maintenance training on SOPs and safe work practices 4. Tier II submission verification ANALYSIS OF DOCUMENTATION SUBMITTED: The following timeline is provided to provide context to the analysis of documents submitted: Year 2004 2011 2014 2016 2017 Event Sysco Seattle started operations. Leasing property from Pokel Management, Green Bay, Wisconsin. PHA conducted by Sysco Seattle. Facility purchased from Pokel Management and DBA as Sysco Alaska. PHA was due. PHA was conducted. Comment No RMP. 10 items open and differed to 2017 PHA; no mention of filing an RMP with EPA. No RMP submitted to EPA. PHA not conducted. 1 year late, no open items. Page 2 of 4 Year 2017 Event Compliance audit was conducted. 2017 First RMP submitted to EPA. 2020 Compliance audit was conducted. Comment Ammonia inventory recalculation was recommended. Ammonia inventory recalculation exceeds 10,000 pounds threshold quantity. No open items. 1. Process Hazard Analysis (PHA): Sysco provided their 2011 and 2017 PHA revalidations. The 2011 PHA revalidation finalized on 7/21/2011. Ten findings and recommendations items were deferred to the 2017 PHA revalidation. The 2017 PHA revalidation was finalized on 6/21/2017 as reported in their RMP. The 2017 PHA shows that all findings and recommendations were completed or assigned completion dates no later than 7/9/2020. The 2017 PHA revalidation was completed six years after the 2011 PHA. 2. Compliance Audit: Sysco provided their 2017 and 2020 Compliance Audit reports including finding tracking sheets. The 2017 Compliance Audit findings were finalized by 7/26/2019. The 2020 Compliance Audit has finding Item #1 open to correct the emergency contact information in their RMP. The other 2020 audits findings were finalized by 7/31/2020 except for an ongoing issue with fire alarm system and is working with AK OSHA. Sysco is performing their compliance audits at least every three years. 3. Training: Sysco provided training documentation for their two operators for their initial and refresher training. The training included the facility's Standard Operating Procedures (SOP) and safe work practices. Their operators perform a walkthrough of the refrigeration system using the SOPs. All operators acknowledged that they received and understood the training by initialing subject training documentation. According to their RMP, Sysco indicates that a written test is used for competency. Sysco did not provide completed written tests for their operators. AREAS OF CONCERNS: 1. PHA: Sysco did not promptly address the 2011 PHA findings and recommendations and deferred them to the 2017 PHA revalidation for completion. 2. PHA: Sysco conducted their 2017 PHA revalidation six years after their 2011 PHA which was due in 2016. 3. Compliance Audits: Sysco did not promptly correct the deficiency identified in the 2020 audit finding Item #1 to correct the contact information in their RMP within one month. The emergency contact name listed in Sysco's 2017 RMP is Josh West. Mr. West left the company in 2018. The current emergency contact is Don Petersen. 4. RMP: Sysco did not correct their emergency contact information within thirty days of the change. The 2020 Compliance Audit finding Item#1 identified this deficiency. The emergency contact name listed in Sysco's 2017 RMP is Josh West. Mr. West left the company in 2018. The current emergency contact is Don Petersen. 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: No follow-up documentation was requested. Page 3 of 4 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) Date: 2021.12.20 15:08:21 -08'00' __________________________________________________________ Digitally signed by JAVIER JAVIER MORALES MORALES Date: 2021.12.20 15:19:03 -08'00' __________________________________________________________ RMP Coordinator/Approval Date ERIN WILLIAMS Digitally signed by ERIN WILLIAMS Date: 2021.12.21 12:32:33 -08'00' __________________________________________________________ EPCRA Coordinator/Approval Date Digitally signed by Jennifer A Jennifer A Sullivan Sullivan Date: 2021.12.21 13:24:04 -08'00' __________________________________________________________ Land Enforcement Section Chief/Approval Date Page 4 of 4