Using “bailing wire” to hold open your deadman valves on oil-pots is a really bad idea… leaving the bailing-wire (e.g. evidence) on the valve after each use is just stupid and shows an auditor/inspector that this is an accepted and continual practice! Another tell-tale indication of cheating a deadman valve is the indentions left in the rubberized coating on the handle.
As discussed below, the CAFO resolves the following CAA violations that Complainant alleges occurred in connection with Respondent’s storage and handling of anhydrous ammonia at its cold storage and distribution facility:
- failure to design and maintain a safe facility, takin g such steps as are necessary to prevent such releases, in violation of the General Duty Clause, Section 112(r)(1) of the CAA, and
- failure to minimize the consequences of accidental releases, should they occur, in violation of the General Duty Clause, Section 112(r)(1)
Respondent operates a cold storage and distribution facility. The Facility is located less than 1,000 feet from a residential neighborhood, a church, and a post office, and less than three-quarters of a mile from other residential neighborhoods, restaurants, and businesses. At the time of the violations alleged herein, the Facility had a refrigeration system, which cycled approximately 6,600 pounds of anhydrous ammonia through various physical states to cool Respondent’s products (the “System”). Accordingly, Respondent “stored” and “handled” anhydrous ammonia. As the operator of a stationary source that processes, handles or stores extremely hazardous substances, Respondent was, at all times relevant to the allegations herein, subject to the General Duty Clause found in Section 112(r)(1) of the CAA. Due to the dangers associated with anhydrous ammonia, the ammonia refrigeration industry has developed industry standards to control the risks associated with the use of ammonia. In collaboration with the American National Standards Institute (“ANSI”), the International Institute of Ammonia Refrigeration (“IIAR”) has issued (and updates)…