NOTE: I have posted this inspection because of the level of detail the inspectors went. There has been a significant shift in the quality of findings from BOTH OSHA and EPA in their process safety inspections. This EPA inspection team was well aware that the IIAR Bulletins are being phased out and replaced with ANSI/IIAR standards. The amount was low, but things could have been much more painful. When you install/construct a “bypass line” around your “King Valve” and your operators could not tell the inspection team if the bypass was open or closed, things could have gone much worse…
On April 25, 2018, EPA conducted a compliance inspection of the Distribution Center, which uses 15,000 pounds of ammonia as a refrigerant, to determine its compliance with the Risk Management Program(“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations as noted on the attached “Risk Management Program Inspection Findings, Alleged Violations and Proposed Penalty Form” (“Form”), which is hereby incorporated by reference. Here are the specific issues noted: