Respondent is a power gas-fed generation facility, utilizing Anhydrous Ammonia in its SCR. It shares its ammonia with a neighbor who uses the NH3 in its refrigeration process. (Don’t ask me how I know)
ALLEGED VIOLATIONS
Following its February 5th, 2025, inspection, EPA alleges Respondent’s failure to:
- The Facility failed to maintain the National Fire Protection Association (NFPA) 704 placard on the anhydrous ammonia tank to be consistent with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(2). (Area of Concern 1 from the US EPA Inspection Report)
- The Facility failed to maintain ammonia piping consistent with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the Clean Air Act and 40 C.F.R § 68.65(d)(2). (Area of Concern 2 from the US EPA Inspection Report)
- The Facility failed to maintain piping supports consistent with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(2). (Area of Concern 3 from the US EPA Inspection Report)
- The Facility failed to maintain ammonia piping labels consistent with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(2). (Area of Concern 4 from the US EPA Inspection Report)
- The Facility failed to ensure the pressure relief valves discharged in a direction consistent with recognized and generally accepted good engineering practices, in violation of Section 112 (r)(7) of the Clean Air Act and 40 C.F.R. § 68.65 (d)(2). {Area of Concern 5 from the US EPA Inspection Report)
- The Facility failed to evaluate all possible engineering and administrative controls and consequences of failure in its 2024 PHA, in violation of Section 112 (r)(7) of the Clean Air Act and 40 C.F.R. § 68.67(c)(3) and (4). {Area of Concern 6 from the US EPA Inspection Report)
- The Facility failed to maintain operating procedures for the selective catalytic reactor (“SCR”) ammonia injection system, in violation of Section 112 (r)(7) of the Clean Air Act and 40 C.F.R. § 68.69(c). (Area of Concern 7 from the US EPA Inspection Report)
- The Facility failed to ensure operating procedures were current and accurate for the years 2020 and 2023, in violation of Section 112 (r)(7) of the Clean Air Act and 40 C.F.R. § 68.69 (c). (Area of Concern 8 from the US EPA Inspection Report)
- The Facility failed to conduct ammonia storage tank inspections consistent with manufacturers’ recommendations and good engineering practices, in violation of Section 112 (r)(7) of the Clean Air Act and 40 C.F.R.§ 68.73{d)(3). (Area of Concern 9 from the US EPA Inspection Report).
- The Facility failed to conduct ammonia piping metal thickness testing consistent with applicable manufacturers’ recommendations and good engineering practices, in violation of Section 112 (r)(7) of the Clean Air Act and 40 C.F.R. § 68.73(d)(3). (Area of Concern 10 from the US EPA Inspection Report)
- The Facility failed to ensure appropriate mechanisms to notify the National Reporting Center (“NRC”) in its Emergency Response Plan and Emergency Action Plan in the event of a release, in violation of Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.90(b)(3). (Area of Concern 11 from the US EPA Inspection Report)
SETTLEMENT
The parties enter into this ESA in order to settle the violations described above for the total penalty amount of $8.280.