Respondent operates a chemical manufacturing which has 2,400,000 pounds of ammonia in onsite storage. Respondent has one RMProgram level 3 covered process. On August 16, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices for its covered process at its stationary source.
At the time of the inspection…
- the process safety information did not contain an evaluation of the consequences of deviation. 40 CFR § 68.65(c)(1)(v)
- a relief valve header positioned so that it would discharge downward. The ANSI/Compressed Gas Association, Inc., CGA 2.1-2014, Safety Requirements for the Storage and Handling of Anhydrous Ammonia (5.8.3), requires the discharge from pressure relieve valves be vented away from the container, upward and unobstructed to the atmosphere. The facility could not provide documentation that the discharge design for the relief valve complies with recognized and generally accepted good engineering practices. 40 CFR § 68.65(d)(2)
- there was no documentation that the recommendations from the May or October 2015 process hazard analyses (PHAs) were addressed, or a schedule indicating when they were to be completed. One hundred ten (110) recommendations resulted from the Ammonia Plant PHA. Seven (7) recommendations resulted from the Ammonia Storage and Loading HAZOP. 40 CFR § 68.67(e)
- the written operating procedures did not contain procedures that addressed consequences of deviation. 40 CFR § 68.69(a)(2)(i)
- the written operating procedures did not contain steps to correct or avoid the deviation. 40 CFR § 68.69(a)(2)(ii)
- the prestart up safety review did not confirm that the PHA was performed and that the PHA recommendations had been completed since unresolved recommendations were still outstanding items at the time of the inspection. 40 CFR § 68.77(b)(3)
Respondent agrees to pay the civil penalty of TWENTY THOUSAND THREE HUNDRED SEVENTY-SEVEN DOLLARS ($20,377)
Supplemental Environmental Project
Respondent shall undertake and complete the following Emergency Planning and Preparedness Supplemental Environmental Project (SEP) within 45 days of the effective date of this CAFO. Respondent shall expend no less than SEVENTY-SIX THOUSAND FOUR HUNDRED FIFTEEN DOLLARS, ($76,415) for the purchase of five (5) years of Emergency Services Marketing Corp. Inc.’s, “I Am Responding System”, forty-six (46) Motorola radios, and fifty (50) Motorola pagers for sixteen (16) local Fire Departments.
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