Many years ago I had an open debate with a “grandfather of refrigeration” on his turf in front of about 30 other refrigeration professionals and the debate was about “flange connections”, ASME B16, and TORQUE and how it all applied to covered processes regardless of what the HHC/EHS was, including anhydrous ammonia in a refrigeration process. “Torque” is a nasty word in the presence of many refrigeration professionals; so much that a trade group was lobbied to remove any mention of the requirement from their codes and standards (e.g. Recognized and Generally Accepted Good Engineering Practice). The debate got rather heat with neither of us giving ground and the word remains a dirty word in the industry today – although some of my clients have decided B16 applies to their process. Not to say “I told you so” but here is EPA’s Region VI (Dallas, TX Office) take on torque and flanged connections…
Respondent is the owner or operator of the refrigerated warehousing and storage area. Respondent’s refrigerated distribution center includes a Program Level 3 covered process, as provided by 40 C.F.R. § 68.10(d). Respondent uses 74,000 pounds of ammonia (anhydrous), a regulated substance in an amount that exceeds the threshold quantity as part of its covered process at its distribution center. On March 29, 2019, at approximately 6:30 a.m. the gasket flange to Pump #1 on the Low Side Accumulator at the Distribution Center Engine Room failed causing a release of liquid anhydrous ammonia.
The incident investigation identified the failure of the gasket was due to the bolts used to tighten the flange were not torqued to proper specifications leading to vibration and failure.
The incident investigation also identified the failure of the gasket was due to the use of a gasket not specifically designed for the use of anhydrous ammonia.
VIOLATIONS
Violation 1: Mechanical Integrity – Written Procedures
40 C.F.R. § 68. 73(b) requires an owner or operator to establish and implement written procedures to maintain the ongoing integrity of process equipment.
- At the time of the March 29, 2019 incident, Respondent did not have written procedures to ensure the flange bolts were tightened to the manufacturer’s specifications.
- At the time of the March 29, 2019 incident, Respondent did not include ensuring adequate torque specifications in its inspection frequencies.
Following the March 29, 2019 incident, Respondent developed and implemented a preventative maintenance program to tighten flange bolts on all ammonia pump flanges using a torque wrench to adequate specifications on a bi-annual basis.
At the time of the March 29, 2019 incident, EPA finds Respondent did not establish or implement procedures to maintain the ongoing integrity of its process equipment in violation of 40 C.F.R. § 68.73(b).
CIVIL PENALTY AND TERMS OF SETTLEMENT
Taking into consideration the size of the Respondent’s business, the economic impact of the penalty on the Respondent’s business, the Respondent’s full compliance history and good faith efforts to comply, the duration of the violation, payment by Respondent of penalties previously assessed· for the same violation, the economic benefit of noncompliance, the seriousness of the violation, and Respondent’s cooperation, as well as other factors which justice may require, EPA and Respondent agree that an appropriate penalty to settle this matter is $37,900 (thirty-Seven Thousand and Nine-Hundred dollars).
CLICK HERE for the CAFO
Members should also take a peek at these: