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
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Photographer:Lisa GravesPhoto
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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