Document yKqBwo0enDO566DjmMjVOQe4

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 25063 CENTER RIDGE ROAD WESTLAKE, OHIO 44145 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Crossroad Farms Dairy Inc., Indianapolis, Indiana Danny Nguyen, Risk Management Program (RMP) Inspector WECAB, Multimedia Section Mr. Brooke Furio, Section Supervisor WECAB, Multimedia Section File BASIC INFORMATION Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 EPA Inspector(s): 1. Danny Nguyen, Lead RMP Inspector, EPA Region 5 2. Erin DuMontelle, RMP Inspector, EPA Region 5 Other Attendees: 1. Herman Gunawan, Plant Engineer, Crossroad Farms Dairy Inc. 2. Brian Moore, Engine Room Lead, Crossroad Farms Dairy Inc. 3. Scott Basney, Site Leader, Crossroad Farms Dairy Inc. 4. Jeff Dolby, Safety and Regulatory Manager, Crossroad Farms Dairy Inc. Contact Email Address: herman.gunawan@kroger.com Purpose of Inspection: Compliance with the prevention of accidental release provisions found in Section 112(r) of the Clean Air Act (CAA), 42 U.S.C. 7414(r) Facility Type: Fluid Milk Manufacturing Regulations Central to Inspection: The Chemical Accident Prevention Provisions at 40 C.F.R. Part 68 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 Arrival Time: 8:30 AM Eastern Departure Time: 6:00 PM Eastern Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Crossroad Farm Dairy Inc.'s (Crossroad) representatives unless otherwise noted. Process Description: Crossroad Farms Dairy Inc. (Crossroad) was built in 1972 and is a subsidiary The Kroger Company. The facility specializes in manufacturing of fluid milk, ice cream, and novelties. The facility includes one building that is approximately 250,000 square feet under roof and the whole site is approximately 22 acres. Staff Interview: The facility has approximately 400 employees that operate three eight hour production shifts Monday through Friday and two ten hour shifts on Tuesdays and Thursdays. Maintenance, receiving, and distribution operate on the weekends. There were currently eighteen active production lines at the time of the inspection. Mr. Gunawan stated that one production line was removed in 2023. There are five on-site ammonia refrigeration technicians who conduct the maintenance and mechanical integrity program. The refrigeration operators record leaks in a logbook that notes the details of what was fixed by who and how it was completed. The operators are the only ones allowed to shut down the refrigeration system, and there are no E-stops within the production areas. Crossroad reports as Program Level 3 RMP facility with ammonia (anhydrous) as the process chemical. The ammonia is used for refrigeration of ingredients and product in the production lines, storage warehouses, load/unloading docks. Crossroad has 20 trained Hazardous Materials (HAZMAT) emergency responders for ammonia emergencies. Crossroad is considered a responding stationary source. Mr. Gunawan stated that the Page 2 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 covered process is manned by backup ammonia personnel for emergencies on 3rd shift on Fridays and 2nd shift on Saturdays and Sundays when primary ammonia technicians are not working. Mr. Gunawan also noted that during an emergency, the Indianapolis Fire Department would be notified. Records Review: The following observations were made during the records review process: Management: Crossroad did not provide documentation describing or outlining a management system to oversee implementation of the RMP elements. Crossroad did not provide documentation outlining other persons responsible for implementing individual requirements of the RMP and defined the lines of authority through an organization chart or similar document. Process Safety Information (PSI): The Piping and Instrumentation Diagram drawing number R1.1 showed process equipment EC-1 was in the incorrect position compared to actual location on the roof. EPA noted that the Facility does not have a backup power supply in the case of power loss to keep the refrigeration system and emergency safety controls running. Process Hazard Analysis (PHA): EPA reviewed the 2016 and 2021 PHAs as well as the resulting findings and recommendations. There were open action items from the 2021 PHA findings and recommendations. Operating Procedures (OPs): Several OPs reviewed were stated to be obsolete. Several OPs did not have annual 2023 certification of accuracy and currency within the process. Training: Initial training did not emphasize safety and health hazards, emergency operations including shutdown, and safe work practices applicable to employee's job tasks. No documentation was provided of initial training in overview of process and in operating procedures for backup ammonia technicians operating the process on the weekend shifts. Mechanical Integrity (MI): No written procedures were provided for maintaining the on-going integrity of the process equipment. Page 3 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 No documentation was provided of training of employees involved in maintaining the on-going integrity of process equipment. No documentation or certification was provided of following recognized and generally accepted good engineering practices for inspections and testing of process equipment. Contracted welder qualifications were not verified prior to welding on process equipment and piping. Only basic contractor review was documented. Management of Change (MOC): The Facility's MOC procedure requires the completion of a Pre-Startup Safety Review (PSSR) prior to operating new equipment unless the new equipment is a replacement-in-kind. The Facility does not have a requirement or procedure to ensure a final inspection of replacement-in-kind of process equipment prior to operation. Incident Investigation: The Facility did not have an incident investigation procedure, report forms, a system to review incidents and follow-up recommendations, or any documentation to ensure meeting requirements in the prevention program for future incidents. Facility representatives noted they had not had any reportable incidents in their past. Emergency Response (ER): The Facility stated they work with the local fire department and have completed HAZMAT training with them. No documentation was provided of coordination with local emergency planning committee (LEPC), and there was no documentation that the Emergency Response Plan had been sent. No documentation was provided for the exercises conducted or their follow-up evaluation with local fire department and emergency response personnel. The Facility completes regular drills for fire and tornado with all employees, but they do not currently drill for emergencies regarding an ammonia release. TOUR INFORMATION EPA Tour of the Facility: Yes Photos and/or Videos: were taken during the inspection. EPA used a NIKON COOLPIX W300 camera and took photos only. Field Measurements: were not taken during this inspection. Page 4 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 Tour observations: The north end of the Engine Room is seperated from the maintenance area and refrigeration office by a wall that has an egress door and a roll door. The egress door has a turn knob and is not fire rated or able to be sealed off between the Engine Room and the maintenance area. There is an exit door on the north end of the maintenance area (North Door). Based on the observed evacuation map for the maintenance area, the North Door is not the primary route for egress; the primary route is through the Engine Room and out the south end door. The north door has panic hardware. No windsock was visible when exiting the north door. No portable or stationary eye wash station was seen on the north end of the engine room. Emergency Stop (E-stop) button is on the outside on the north door but not immediately outside the engine room. The south end of the engine room is connected with the sump area and loading dock. The entrance to the engine room has a gated doorway into the area that contains the refrigeration equipment and is not able to be entirely isolated from the sump and loading dock areas. Loading dock contained an egress doorway (South Door) and a roll door. Route between the gated entry of the engine room and the south end exit door was partially blocked by deliveries and equipment. Corroded and non-insulated ammonia piping on ceiling next to the receiving vessel (built in 1972). Missing pipe insulation and water leaks causing corrosion to the floor were observed in the engine room. The "Safe Work Practices" document hanging in the engine room expired the following day. Main water line was indistinguishable from the ammonia lines in the sump area. No system shutoff capability with ammonia pipes to ice cream freezer barrel in filler production area. No visual alarms for ammonia were seen in the production area. Evaporators 9, 10, and 11 in ice cream storage had no guard against contact with product that are stacked at the same height. Forklifts can reach the same height of product storage and evaporators. Missing or peeling ammonia pipe labels on the roof. INSPECTION DOCUMENTS The following records were provided by the Crossroad representatives electronically prior to the inspection and are filed on a secure One Drive folder provided by EPA Inspector Danny Nguyen under the folder "Crossroad Farms Dairy Document Folder": 1 - Compliance Audit Report - Crossroad Farms Dairy_Aug. 17-18__2023.pdf 1B - Compliance Audit Sign-ins.pdf 2 - Compliance Audit Findings - Crossroad Farms Dairy_Aug. 17-18__2023.xlsx Page 5 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 3A - Compliance Audit Worksheets_Crossroad Farms Dairy_Aug. 2023.pdf 3B - IIAR9 Minimum System Requirements_Crossroad Farms Dairy_Aug. 2023.pdf 4 - CA interview questions_Crossroad Farms Dairy_Aug. 2023.pdf 5 - Auditor Resume.pdf Design Codes & Standards_rev 2023.pdf PHAs before 2005 memo_8-24-2023 SIGNED.pdf Contractor List.pdf CQ1 - CQ3 Sample - WMI 2023.pdf Tab 00 2023 MII Report Crossroads Index.pdf tab 01 letter crossroads.pdf Tab 02 Equipment list.pdf Tab 03 Detailed equipment listing.pdf Tab 04 Crossroads detailed report title pages.pdf tab 05 photos crossroads.pdf Tab-06 2023 MII Deficiency Log + Crossroads.pdf 2024 MOC Log.pdf MOC Sample - Cone HVAC 2024.pdf Prestartup Sample - Cone HVAC 2024.pdf 2023 RMP Date updates_.pdf Tab 0 Crossroad Farms - Indy RMP Index.pdf Tab 01 Crossroad Farms - Indy RMP Updates Log.pdf Tab 02 Crossroad Farms - Indy RMP Letter Describing WCS and ACS.pdf Tab 03 Crossroad Farms - Indy RMP Submittal.pdf Tab 04 Crossroad Farms - Indy WCS Aloha Heavy Gas Model Report.pdf Tab 05 Crossroad Farms - Indy WCS Aloha Heavy Gas Model Threat Zone Chart.pdf Tab 06 Crossroad Farms - Indy WCS Aloha Heavy Gas Model Map.pdf Tab 07 Crossroad Farms - Indy WCS Aloha Gaussian Model Report.pdf Tab 08 Crossroad Farms - Indy WCS Aloha Gaussian Model Threat Zone Chart.pdf Tab 09 Crossroad Farms - Indy WCS Aloha Gaussian Model Map.pdf Tab 10 Crossroad Farms - Indy ACS Aloha Heavy Gas Model Report.pdf Tab 11 Crossroad Farms - Indy ACS Aloha Heavy Gas Model Threat Zone Chart.pdf Tab 12 Crossroad Farms - Indy ACS Aloha Heavy Gas Model Map.pdf Tab 13 Crossroad Farms - Indy ACS Aloha Gaussian Model Report.pdf Tab 14 Crossroad Farms - Indy ACS Aloha Gaussian Model Threat Zone Chart.pdf Tab 15 Crossroad Farms - Indy ACS Aloha Gaussian Model Map.pdf Tab 16 Crossroad Farms - Indy RMP Executive Summary.pdf Tab 17 Crossroad Farms - Indy RMP Submittal-Redline.pdf Hazmat Certificates.pdf Bobby K - Operator 1 2023.pdf James G - Operator 2 2023.pdf Marcus S - Operator 1 2023.pdf Block Flow.pdf Consequences and Deviations 2020.doc Crossroad Farms Ventilation Study 4-26-18.pdf Page 6 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 Emergency Procedures 2023.pdf Employee Participation Sample - Full Notes in Binder 1.pdf Hot Work Sample.pdf Incident Investigation - Small Release Report Sample.pdf Intended Inventory Nh3 pdf Line Break Sample.pdf Mass Energy Balance Crossroad Farms 08212018 - L-B-.pdf Materials of Construction 2020.doc Closing Conference P&ID CROSSROADS SET.pdf PHA 11-2-21 and 12-14-21.pdf PSM team member.docx Relief Header V - Existing.pdf SDS NH3.PDF SOP - Overview with Safety Systems_NEW_ASM UPDATE 8-30-2022.doc SOP Sample - Condenser EC-1 - UPDATE 12-06-2022.docx Ammonia Sensor Calibration 2022.pdf Annual SPK 9-2023.pdf Compliance Audit Findings - Crossroad Farms Dairy Aug 24-25_2020_updated 11-2-2021.xlsx Compliance Audit Report 8-25-2020.pdf Compliance Audit Results - Crossroad Farms Dairy Aug 24-25_2020.pdf Crossroad Farms Dairy PHA Recommendations_11-2-21 and 12-14-21_updated 8-17-2023.xls NH3 Sensor Calibration 2024.pdf Relief Valves 5 yr Replacement.xlsx SOP Table of Contents (PRIORITIZED)_updated by ASM 2-24-2023 IN PROGRESS.xlsx Provided EPA point of contact to the facility Areas of Concern: All observations identified above in the `Records Review' section. North end blue egress door from the engine room into another part of engine room has a turn knob and not panic hardware. Based on evacuation map, the egress point is not primary egress point out of the engine room. The most northern egress door does include panic hardware but would require going through the non-panic hardware installed blue egress door. No portable or stationary eye wash station on the north end of engine room. The E-stop button is on the outside on the north end egress point of the facility but not immediately outside the engine room. South end entrance/egress point to engine room is open and not isolated with loading/unloading dock and glycol chillers. Corroded and non-insulated ammonia piping on ceiling next to referred to 1972 vessel. Missing pipe insulation and water leak from pipe to floor in engine room was observed. No system shutoff capability with ammonia pipes to ice cream freezer barrel in filler production area. Page 7 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 Evaporators 9, 10, and 11 in ice cream storage had no guard against contact with product that are stacked at the same height where forklifts can reach. Missing or peeling ammonia pipe labels on the roof. Based on statement from Crossroad representatives, there is not backup power in case of power loss. Ammonia sensors and emergency systems would not work. POST INSPECTON DOCUMENTS The following documents were provided by the Facility representatives electronically (uploaded to OneDrive folder) to EPA after the inspection: Example - Correctivefollow up work order on NH3 Comp6.pdf (5/23/2024 email from Mr. Gunawan) Example - ServicePM work order on NH3 compressor 6.pdf (5/23/2024 email from Mr. Gunawan) Example of welding job hot work.pdf (5/23/2024 email from Mr. Gunawan) NH3 Sensors Calibration 2023.pdf (5/23/2024 email from Mr. Gunawan) Relief Valves 5 yr Replacement.xlsx (5/23/2024 email from Mr. Gunawan) POST INSPECTON COMMUNICATION Communication Log (Post Inspection): 5-23-2024 Email: Mr. Gunawan provided documents requested during the inspection. DIGITAL SIGNATURES Digitally signed by DANNY DANNY NGUYEN NGUYEN Date: 2024.07.11 10:37:44 -04'00' Report Author: _________________________________ Digitally signed by BROOKE BROOKE FURIO FURIO Date: 2024.07.11 10:48:46 -04'00' Section Supervisor: __________________________________ Appendices and Attachments Appendix A: Participant List Appendix B: Digital Image Log Page 8 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 APPENDIX A: PARTICIPANT LIST Page 9 of 10 Facility Name: Crossroad Farms Dairy Inc. Facility Location: 400 South Shortridge Road, Indianapolis, Indiana 46219 Date of Inspection: May 15, 2024 APPENDIX B: DIGITAL IMAGE LOG 1. Inspector Name: Danny Nguyen 2. Archival Record Location: OneDrive/Desktop/Multimedia Section/112(r)/Inspections/Crossroad Farms Dairy Inc. 15 May 2024/Photos Image Number 1 2 File Name DSCN0757.jpg DSCN0758.jpg Date and Time (incl. Time zone and DST) 5/15/2024 / 1:50PM Eastern 5/15/2024 / 2:02PM Eastern Description of Image Exit door out of main engine room Corroded ammonia piping 3 DSCN0759.jpg 5/15/2024 / 2:03PM Eastern Water leak from piping in the ceiling 4 DSCN0760.jpg 5/15/2024 / 2:03PM Eastern Water leak to floor in the engine room 5 DSCN0761.jpg 5/15/2024 / Overview of water leak on the floor in the engine 2:05PM Eastern room 6 DSCN0762.jpg 5/15/2024 / 2:06PM Eastern South egress door from the engine room 7 DSCN0763.jpg 5/15/2024 / 2:17PM Eastern Vibrating water line near ammonia line 8 DSCN0764.jpg 5/15/2024 / 2:19PM Eastern South entrance to the engine room 9 DSCN0765.jpg 5/15/2024 / Pallets of material and equipment outside of south 2:19PM Eastern egress door 10 DSCN0766.jpg 5/15/2024 / 2:37PM Eastern Evaporators in ice cream storage room 11 DSCN0767.jpg 5/15/2024 / 2:38PM Eastern Evaporators 9-10-11 in ice cream storage room 12 DSCN0768.jpg 5/15/2024 / 2:38PM Eastern Evaporators in ice cream storage room 13 DSCN0769.jpg 5/15/2024 / 3:05PM Eastern North egress door from engine room 14 DSCN0770.jpg 5/15/2024 / 6:07PM Eastern Corroded pipe near ammonia vessel in engine room 15 DSCN0771.jpg 5/15/2024 / 6:08PM Eastern Corroded pipe near ammonia vessel in engine room Page 10 of 10