There appears to have been no monetary fine issued with this agreement; instead, it looks as if the facility has agreed to correct all the deficiencies by June 2018. Respondent uses, handles, and/or stores more than a threshold quantity of a flammable mixture and anhydrous ammonia, both regulated substances. The EPA conducted an inspection on April 27, 2016, to assess compliance with 40 C.F.R. part 68. During the inspection, the EPA representative observed alleged violations as described in paragraphs below:
- Respondent did not include regulated substances within process piping in the maximum intended inventory. This is a violation of 40 C.F.R. § 68.65(c)(1)(iii).
- Respondent did not provide relief system design and design basis. This is a violation of 40 C.F.R. § 68.65(d)(1)(iv).
- The process safety information did not contain applicable design codes and standards employed for the ammonia system. This is a violation of 40 C.F.R. § 68.65(d)(1)(vi).
- Respondent did not document that ammonia system equipment complies with RAGAGEP. This is a violation of 40 C.F.R. § 68.65(d)(2).
- Ammonia pressure-relief-valve extensions above machine-room roof did not meet the height and direction of termination of discharge requirements in accordance with Section 3 15.5.1.3 and Section 15.5.1.5 of IIAR 2 2014, American National Standard for Safe Design of Closed Circuit Ammonia Refrigeration Systems. This is a violation of 40 C.F.R. § 68.65(d)(2).
- Ammonia piping was not labeled in accordance with Section 5.14.5 of IIAR-2 2014 or per Section 4.0 of Bulletin 114-Guidelines for Identification of Ammonia Refrigeration Piping and System Components (Date: 2014). This is a violation of 40 C.F.R. § 68.65(d)(2).
- Safety showers and eyewash stations within the ammonia machine room did not have a continuous water supply and there were no safety showers and eyewash stations outside of the ammonia machine room in accordance with Section 6.7 of IIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
- During the EPA inspection, it was observed that the entry/exit doors in the ammonia machine room were propped open impeding the ability of the doors to be self-closing and tight fitting in accordance with Section 6.10.2 of IIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
- Ammonia signage at entry/exit doors did not have the required National Fire Protection Association 704 placards and restricted access signage in accordance with Section 6.15 of IIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
- Respondent did not provide written operating procedures that address the safety and health considerations specified in 40 C.F.R. § 68.69(a)(3). This is a violation of 40 C.F.R. § 68.69(a)(3).
- Ammonia loading procedures were not readily accessible for the ammonia storage tank. This is a violation of 40 C.F.R. § 68.69(b).
- For 2015, Respondent did not certify that the operating procedures were current and accurate. This is a violation of 40 C.F.R. § 68.69(c).
- According to the Facility’s training spreadsheet (entitled “Online Training Record, XXXXXXX, 2014 & 2015”): Maintenance Foreman did not complete “NORM Awareness Training for Upstream Oil and Gas Operations” by the due date of October 7, 2015; Maintenance Foreman did not complete “Personal Protective Equipment Training for Oil and Gas Personnel” by the due date of October 7, 2015; Operations Manager did not complete “Fire Safety Training” by the due date of February 29, 2016; Lease Operator did not complete “Fire Safety Training” by the due date of February 29, 2016; Lease Operator did not complete “Hazard Communication Training for the Oil and Gas Industry” by the due date of February 29, 2016; Senior Maintenance Mechanic did not complete “Fire Safety Training” by the due date of February 29, 2016; Plant Operator did not complete “Fire Safety Training” by the due date of February 29, 2016; and Foreman did not complete “Fire Safety Training” by the due date of March 31, 2016. This is a violation of 40 C.F.R. § 68.71(b).
- External inspections, including corrosion under insulation (CUI) inspections, had not been performed on the process piping at the Facility according to Section 6.4 of API 570, Piping Inspection Code: Inspection, Repair, Alteration, and Rerating of in-service Piping Systems. This is a violation of 40 C.F.R. § 68.73(d)(1).
- Internal inspections had not been performed at least every 10 years on the fractional distillation tower, the propane pressure vessels, the Natural Gas Liquids (NGL) pressure vessels, the amine unit, and the scrubbers. Inspections on these pressure vessels had not been performed in accordance with Section 6.4 and Section 6.5 of API 510, Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair, and Alteration. This is a violation of 40 C.F.R. § 68.73(d)(3).
- Respondent did not document hose inspections and replacement dates for the NGL loadout stations. This is a violation of 40 C.F.R. § 68.73(d)(3).
- A management of change (MOC) was not completed before the Facility increased capacity in October of 2015 (Compressor #6 was changed from standby status to full-time status in order to realize the increased capacity). This is a violation of 40 C.F.R. § 68.75(a).
- Respondent did not provide electrical classification documentation which accurately reflected the current state of the Facility. This is a violation of 40 C.F.R. § 68.75(d).
- Respondent completed compliance audits on November 13, 2009, and on October 29, 2013. This exceeds the three-year requirement. This is a violation of 40 C.F.R. § 68.79(a).
- Inspections had not been performed on the Facility’s Type A suits per RAGAGEP. This is a violation of 40 C.F.R. § 68.95(a)(2).
- The online RMP at the time of the EPA inspection was not updated and contained incorrect information including owner/operator, parent company, points of contact, and potentially offsite consequence analysis information. This is a violation of 40 C.F.R. § 68.190(b)(5).
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