This inspection was for the purpose of determining compliance with Section 112(r)(7) accidental release prevention requirements of the Clean Air Act, as amended in 1990. The scope of this Inspection may include, but is not limited to:
- reviewing and obtaining copies of documents and records
- Interviews and taking of statements
- reviewing of chemical storage, handling, processing. and use
- taking samples and photographs; and
- any other inspection activities necessary to determine compliance with the Act.
In consideration of the penalty assessment factors and upon consideration of the entire record, the parties enter into the ESA in order to settle the violations described in the enclosed Summary for the total penalty amount of $10,600.
NOTE: I normally do not post ESA’s as they are usually smaller $ and few findings, but this ESA has numerous findings and passed the $10K threshold. One finding, in particular, was a blast from the past… bathroom inside engine room and access. This was also identified in the PHA as an issue.
INSPECTION FINDINGS
Anhydrous Ammonia; 18,000 pounds
Three EPA representatives and an EPA contractor inspected the facility on September 17, 2019. Based upon this inspection the facility is in violation of the following risk management program elements:
1. Process Safety Information: process safety information did not have current piping and Instrumentation diagrams (P&IDs) as required by 40 C.F.R. § 68.65(d)(1)(ii). The facility did not update their P&IDs to include the additional condenser was added to their anhydrous ammonia refrigeration system in 2015.
2. Process Hazard Analysis: The facility’s PHA was not performed by a team with expertise in engineering and process operations and the team did not include appropriate personnel as required by 40 C.F.R. § 68.67(d). During the inspection, The Facility was unable to produce documentation to identify the PHA team members for a PHA dated February 24, 2016.
3. Process Hazard Analysis: The PHA has not been updated and revalidated by a team every five years after the completion of the initial PHA to assure that the PHA Is consistent with the current process as required in 40 C.F.R. § 88.67(f). During the inspection, The Facility had one PHA dated February 24, 2016, on file that was a revalidation of a prior PHA. There were no lists of participants and no documentation of findings. The facility did not have the prior PHA available for review.
4. Operating Procedures: The facility’s operating procedures do not address startup following a turnaround, or after emergency shutdown as required in 40 C.F.R.§ 68.69(a)(1)(vii).During the inspection, the facility was unable to produce operating procedures to address the startup following a shutdown for the ammonia refrigeration system.
5. Operating Procedures: The Facility did not certify annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary as required in 40 C.F.R. § 68.69(c). During the inspection they facility as unable to produce documentation for the annual certification of the operating procedures for the ammonia refrigeration system.
6. Mechanical Integrity: The facility has not followed recognized and generally accepted good engineering practices (RAGAGEP) as required In 40 C.F .R. § 68.73(d)(2). During the inspection. The facility was unable to produce inspection and testing documentation for the pressure relief valves (PRVs) located in the engine room. The facility is not following RAGAGEP in their written procedures for the replacement of PRVs every five years (Reference IIAR Bulletin 110, Rev 6/07, Section 6.6.3. Pressure Relief Devices)
7. Mechanical Integrity: The facility has not ensured the frequency of inspections and tests of process equipment is consistent with applicable manufacturers’ recommendations, good engineering practices, and prior operating experience as required in 40 C.F.R. § 68.73(d)(3). During the inspection. the pressure relief valves (PRVs) located in the engine room with a replacement date of August 2018 were approximately thirteen months overdue (Reference IIAR Bulletin 110, Rev 6/07, Section_ 6.6.3 Pressure Relief Devices).
8. Mechanical Integrity: The facility has not documented each inspection and test that had been performed on process equipment, which identifies the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed description of the inspection or test performed, and the results of the inspection or test as required in 40 C.F.R. § 68.73(d)(4). During the inspection, the facility was unable to produce inspection and testing documentation for the replacement of pressure relief valves (PRVs), calibration of ammonia detectors, annual testing of the compressor safety cutouts for shutdown, and the replacement of air intake filters.
9. Incident Investigation: The facility has not investigated each incident that resulted in, or could reasonably have resulted in a catastrophic release of a regulated substance as required in 40 C.F.R. § 68.81(a). The facility provided an agency notification form confirming the release of 103 pounds of anhydrous ammonia on August 26, 2015, at approximately 4:25 P.M. which prompted an evacuation of the facility personnel and of an adjacent facility (Stemilt Olds Station). The facility was unable to produce a formal incident investigation report as required by 40 C.F.R. § 68.81(d).
Employment Participation: The facility has not developed a written plan of action regarding the implementation of an employee participation plan as required in 40 C.F.R.§ 68.83(a). During the inspection, the facility was unable to produce a written employee participation plan.
EPA Inspectors observed the following issues that must be addressed:
1. The engine room doors are not equipped with panic-type hardware to meet IIAR 2-2008 with Addendum B, Section 13.1.10.
2. Unauthorized personnel can access the restroom in the engine room with the possibility of getting exposed to ammonia during an ammonia release. This hazard was Identified in the PHA.
3. The engine room air intake and exhaust opening are co-located on the same side. This ventilation design may allow ammonia to be recirculated back Into the engine room during a release.
CLICK HERE for the ESA