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Recommendations Kruger Foods Kruger Foods Report Date: 12/12/2024 App Priority Responsible Person Due Date Complete Date 3 Jason Palarca 08/03/2024 07/26/2024 Recommendation #1 EP #00032 - San Joaquin County CUPA Inspection CalARP- OBSERVATION: The owner/operator failed to consult with the Unified Program Agency to decide which hazard review methodology is best suited to determine and evaluate the hazards of the process being analyzed. REGULATION GUIDANCE: (b) The owner or operator of a stationary source shall consult with the UPA to decide which hazard review methodology is best suited to determine and evaluate the hazards of the process being analyzed.(c) The owner or operator may use checklists, if acceptable to the UPA, developed by persons or organizations knowledgeable about the process and equipment as a guide to conducting the review. The hazard review shall be performed by a team familiar with process operations and shall include at least one employee who has experience and knowledge specific to the process being reviewed. For processes designed to meet industry standards or federal or state design rules, the hazard review shall, by inspecting all equipment, determine whether the process is designed, fabricated, and operated in accordance with the applicable standards or rules. CORRECTIVE ACTION(S): Submit statement to our department stating that the facility will Consult with our department to decide which hazard review methodology is best suited to determine and evaluate the hazards of the process being analyzed. Resolution Kruger Foods will consult with San Joaquin County EDH on the best methodology for conducting future Hazard Reviews. The next Hazard Review is due on 8/1/2028. 2 Jason Palarca 08/03/2024 12/12/2024 Recommendation #2 EP #00032 - San Joaquin County CUPA Inspection CalARP- OBSERVATION: The owner/operator failed to document initial and/or refresher trainings for each employee. Including (but not limited to): 1. Plant manager (person having responsibility over the CalARP program) 2. Technician performing daily inspections & pH testing of diffusion tank water 3. All employees involved in operating a process 4. Emergency Response Plan training for all employees (per ERP, all employees receive initial and annual refresher training) REGULATION GUIDANCE: The owner or operator shall ensure that each employee presently operating a process, and each employee newly assigned to a covered process has been trained or tested competent in the operating procedures that pertain to their duties. Refresher training shall be provided at least every three years, and more often if necessary, to each employee operating a process to ensure that the employee understands and adheres to the current operating procedures of the process. The owner or operator shall document initial and refresher training for each employee. CORRECTIVE ACTION(S): Submit copies of the training records for each employee operating the process to our department. Resolution All employees have received the necessary training. Refer to the linked google drive folder for copies of all training records. https://drive.google.com/open?id=19hOXL5_tO5xXWqVV_Wkh__v--cLg7pkx&usp=drive_fs Related Events Name Date Event Jason Palarca 10/04/2024 Marisol keeps track of all the trainings through alchemy. She will provide copies of the evacuation, emergency response, and ammonia awareness training. Resource Compliance will provide training to Patrick (plant manager) on an overview of the CalARP Program and will provide daily operations training to technicians.