Document zQ1Q06VLYX43OBQvVByZdqmyR

UNITED STATES . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ENVIRONMENTA AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101ENFORCEMENT & PROTECTIONCOMPLIANCE ASSURADINVISICON E Clean Air Act - Section 112 (r) Risk Management Program and EPCRA 312-Tier II Facility Inspection Report FACILITY INFORMATION: Name:Washington Fruit and Produce Company - Union Gap Physical Address: 2116 N Rudkin Road, Union Gap, WA 98903 Phone Number:509-480-0820 Latitude / Longitude: 46.571444 / -120.474722 RMP Facility ID # 100000106244 FRS ID #:110000553909 EJ Concerns:Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name:Shane Tillett Phone Number:509-480-0820 E-mail:stillett@washfruit.com EMERGENCY CONTACT INFORMATION: Name:Kevin Heffington Phone (24-hr):509-930-1876 E-mail:kheffington@washfruit.com TRIP DETAILS: Inspection Date:4/29/2022 Inspection Time:0900 hours through 1015 hours (facility 1 of 2) Inspectors:Peter Phillips, US EPA Region 10 SEE Grantee, Lead RMP Inspector Edward Johannes, US EPA Region 10 SEE Grantee, EPCRA Inspector Bob Hales, US EPA Region 10 SEE Grantee, RMP Inspector Lisa Graves, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date:June 21, 1999 Date of Latest Update:July 21, 2021 Process (Program 1, 2, 3) as reported in RMP: Process IDDescription Process NAICS Program Chemical Name Quantity Chemical IDCodeLevelCAS Number(lbs) 1000117735 1S 000y 14s 720t 6 e 115m 11 4 3( R7 efr6 ig6 era4 ti- on4 Amm1 on- ia,7 A) nhy drous17,000 7/1/2022Page 1 of 4 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:NoYes The facility is High Risk:NoYes Joint EPCRA inspection:NoYes CAA Title V Air Permit: Does the facility have a CAA Title V Permit?NoYes RELEASE / ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years?NoYes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC?NoYes If Yes, Date the Tier II was submitted:2/17/2022 Did the facility submit a Tier II to the LEPC and local fire department? NoYes If Yes, Date the Tier II was submitted: 2/17/2022 to LEPC and 2/24/2022 to Yakima Fire Department INSPECTION ENTRY: Peter Phillips led the inspection entry. The inspection team met with Shane Tillett at the Washington Fruit and Produce Company Union Gap facility in Union Gap, Washington. The team arrived at the facility at 0900 hours and was joined by the following facility personnel: Name Title Shane TillettPSM Coordinator Rob WiekershamEngineering / PSM with CWR Central Meredith DennyCompliance Specialist with APSM Was a state / county / or local emergency representative present?NoYes The facility is a first responder:NoYes If No, Responding Agency: Yakima Fire Department Shane Tillett previously notified the inspection team that the Union Gap Facility had no conference room to convene in. Therefore, following the facility tour the inspection team would be escorted back to the Yakima Facility office to complete the document review portion of the inspection. Upon arrival to the facility, reintroductions were conducted with the inspectors, along with the purpose of their visit. EPA requested an explanation of the facility's operations and any additional safety measures that should be taken during the site tour. Shane Tillet 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 Page 2 of 4 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: No Yes An employee representative present during the facility visit: No Yes GENERAL INFORMATION: The Washington Fruit and Produce Company Union Gap Facility (the facility) is regulated under the Risk Management Program as a Program Level 3 facility and is owned and operated by the Washington Fruit and Produce Company. The facility is a produce storage and distribution center which utilizes an ammonia refrigeration system. One engine room houses the main components of the refrigeration system, which supports fifty - three controlled atmosphere rooms at the facility. There are no full - time employees on site, and four refrigeration operators from the Washington Fruit and Produce Yakima Facility rotate to provide oversight of refrigeration operations at the Union Gap Facility. The facility stores apples and cherries in refrigerated storerooms while the produce awaits shipment. Refrigeration operators check the ammonia refrigeration 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. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 0900 hours to 0930 hours. The EPA Inspection Team was escorted by facility representatives Shane Tillett and Rob Wiekersham. The EPA inspection team observed the facility engine room (Engine Room), Warehouse Areas 86 and 93 which house - controlled atmosphere rooms CA 29 and CA 37, and ammonia piping throughout the facility. The Engine Room at the facility houses the main equipment for the refrigeration system (Photos 1-8), which includes compressors, valves, intake vents, exhaust fans, high pressure vessel tanks, the ammonia sensor network panel, and an ammonia leak detection device. There are two controlled atmosphere rooms, designated as CA 29 in Warehouse Area 86 (Photos 10-13) and CA 37 in Warehouse Area 93 (Photos 14-15 and 17-18). The primary equipment observed in the controlled atmosphere rooms were the evaporators and ammonia sensor tubing intakes. Ammonia piping to the refrigeration system is located inside Warehouse Area 93 (Photo 16). Ammonia refrigeration equipment as clearly labeled and tagged, with appropriate safety features in place. Photographs of the facility, 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 Yakima facility to review RMP documentation in a conference room. Upon completion of the document review, the EPA inspection team provided a debriefing to Shane Tillett, Rob Wiekersham, and Meredith Denny. Page 3 of 4 INFORMATION COLLECTED FROM FACILITY: No documents were collected during the inspection. AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. Mechanical Integrity [68.73 (c)]: Washington Fruit Union Gap did not train each employee involved in maintaining the on - going integrity of process equipment. The facility could not provide documentation for employees involved in maintaining the ongoing integrity of process equipment. 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. No follow - up documentation was requested. 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: Digitally signed by Phillips, Peter Phillips, Peter E. E Date: 2022.07.26 13:15:45 -07'00 ' Inspector Signature Digitally signed by JAVIER JAVIER MORALES MORALES Date: 2022.07.26 13:52:47 -07'00 ' RMP Coordinator / Approval Digitally signed by ERIN WILLIAMS ERIN WILLIAMS Date: 2022.07.27 13:55:20 -07'00 ' EPCRA Coordinator / Approval Digitally signed by Jennifer A Jennifer A Sullivan Sullivan Date: 2022.07.27 15:34:05 -07'00 ' Land Enforcement Section Chief / Approval Page 4 of 4 City, Site ASCttiiactthmeyen ,t NA -aPShomttoea L:otgeDWS:CaN2s4U58h nDiSiCnNo2g4n5t7 oDSGnCNa2 4p5F6, rD SuCNWi24at55s DhSaCiNn24nd54g DtPSCroN2o4n53d DuSCcN2e45 2 CDSoCN2m45p1 aDSnCNy24 50U DSnCNi24o49n D SCGN24a48p D SCN2447 DSCN2446 DSCN2445 DSCN2444 DSCN2443 DSCN2442 DSCN2441 DSCN2440 DSCN2439 DSCN2438 AttachmentPhotographer: State: Name: Photographer:Lisa GravesPhoto Photo Lisa Union Log DSCN243814P/h2o9t/o20 2L2a y9:o0u11t AMI7 DE nDgaintGee RrTooimma e- vEDnetesrcyr s/i pE txiitoGnLaaWyoaupsth i,ng ton DSCN24394/29/2022 9:03 AM Engine Room - King ValveID Fruit DSCN24404/29/2022 9:03 AM Engine Room - King ValveWashiDnagtteo na nd DDDSSSCNCC24NN41223448744 432/29/442/0/2222 994///2922/20002222 224/ 2999/:2:0002275 9 :0AA4 MMAM 4EE/2nn9g/g2i0i2nn2 ee4/ 29RR/2oo02oo2 mmE n g-i-n e EARoxmomhm -ao Aunmmsiotnai a LSeaekn Dsetoecrto rN4/e29t/2w02o2r 4k/2 9/P20a22n elProduce 6524 Company DSCN24449:21 4/29/2022 9:07 AM Engine Room - Intake 9:07 9:07 9:07 9:05 9:04 9:03 9:03 9:01 DSCN2445AM 4/29/2022 9:07 AM AM Engine Room - High Pressure Receiver AM AM AM AM DDSCSN2C44N7 24464/29/2022 9:07 AM Engine Room - CompressorsUnion Facility 4/29/2022 9:09 AM Facility External Piing and Ducts Engine Engine Engine Engine Engine EngineGap DDSSCCNN2244449811104/42/92/92/02220 292: 192: 1A1M CAAM 2W9a-rEenhtroyu s/e E8x6i-tE Rnotormy R/o oEm xRiotom3 7R o3o7m RWoaorme hRoouoms eR o2o9m DReosomc rRiopotmi on DSCN2450124/29/202E2xt er9n:al1 E3nt rAy/MEx itC A93 923 9-Condenser HighKing King DDSSCNC24N52141352Pipi4n/g 2Co9rr/i2do0r242/2 9/92:0212 39 :1A3 MA M WCAa 2r9e Ahmmoounisa eS en9so3r- TCuboe raEnrdx hiaudsot rAmmVonaial vAmemo nViaaElntvrey/ Exit DSCN245314 and 4/29/2022 9:17 AM Warehouse 93-Entry / ExitLeak DSCN245416 Ducts 4/29/2022 9:18 AM Warehouse 93 Refrigeration System Piping DSCN2455174/29/2022 9:19 AM CA 37 Entry / Exit DSCN2456184/29/2022 9:19 AM CA 37 Condenser and Ammonia Sensor Tube DSCN2457154/29/2022 9:20 AM Warehouse 93-CorridorPanel DSCN245894/29/2022 9:21 AM Facility External Piping and Ducts