Respondent owns and operates a poultry processing facility which handles and stores approximately 49,000 pounds of anhydrous ammonia in its ammonia refrigeration system. EPA conducted an inspection of the Facility on March 31, 2014 to determine Respondent’s compliance with CAA Section 112(r)(7) and the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68.
The Chemical Accident Prevention Provisions require an owner or operator to comply with process safety information requirements at 40 C.F.R. § 68.65(d)(l)(vi) and (d)(2), i.e., to compile process safety information pertaining to design codes and standards relevant to the equipment and to document that the equipment in the process complies with recognized and generally accepted good engineering practices. Recognized and generally accepted good engineering practices for mechanical refrigeration systems using anhydrous ammonia include those of the American National Standards Institute (“ANSI”), the American Society of Heating, refrigerating, and AirConditioning Engineers (“ASHRAE”), and the International Institute of Ammonia Refrigeration (“IIAR”), EPA CEPP Alert #550-F-01-009 (Hazards of Ammonia Releases at Ammonia Refrigeration Facilities) and manufacturers’ recommendations, including the following:
- ANSI/IIAR 2-2008B, Equipment, Design, and Installation of Closed Circuit Ammonia Mechanical Refrigerating Systems (“IIAR 2″)
- ANSI/ ASHRAE Standard 15-2007, Safety Standard for refrigeration Systems (“ASHRAE 15”)
FINDINGS OF FACT RELATED TO THE VIOLATIONS OF SECTION 112(r)(7) OF THE CLEAN AIR ACT
Respondent has handled and/or stored at the Facility more than 10,000 pounds of anhydrous ammonia, the threshold quantity of a regulated substance in a process since 2005.
Based on available information, including the Inspection, EPA has determined that Respondent did not follow recognized and generally accepted good engineering practices in designing and maintaining the Facility’s anhydrous ammonia refrigeration processes by failing to follow Section 13 of IIAR 2 requirements in the following:
- Section 13.3.7.1 of IIAR 2 requires that all exhaust fans discharge vertically with a minimum velocity of 2500 feet per minute. During the Inspection, EPA determined that the exhaust fans located in Machinery Rooms #2 and #3 discharged horizontally, rather than vertically.
- Section 13.3.4 of IIAR 2 requires that discharge to air be to the outdoors “in a manner that will not cause a nuisance or danger” and exhaust from mechanical ventilation systems shall be discharged “no less than 20 feet from a property line.” EPA determined during the Inspection that the discharge from a horizontal exhaust fan occurred less than 20 feet from the Facility property line adjacent to Business Route 50 (Maryland Highway).
- Section 13 .2 of IIAR 2 requires that each refrigeration machinery room contain at least two refrigerant detectors that activate a visual and audible alarm and mechanical ventilation. The alarms notify employees that ammonia has been detected at certain concentrations. The detector also activates mechanical ventilation to remove ammonia from the machinery room. EPA determined during the Inspection that the Facility did not have visual and audible alarms inside all refrigeration machinery rooms and outside each entrance to each refrigeration machinery room.
- Section 13.1.4 of IIAR 2 and Section 8.11.2 of ASHRAE 15 require that no opening be present that would allow the passage of escaping refrigerant to other parts of the building. During the Inspection, EPA observed two large openings between Machinery Room # 1 and the boiler room.
PAYMENT TERMS
Respondent consents to the assessment of a civil penalty for the violation of Section 112(r)(7) of the CAA, 42 U.S.C. § 7412(r)(7), in the amount of $56,226.
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