I usually do not post such small cases, but this 540-megawatt electrical generation facility is sort of unique as it uses 87,840 pounds of anhydrous ammonia in a closed refrigeration system used to cool gas turbine inlet air and increase power output. It also uses 44,840 pounds of aqueous ammonia to reduce NOx emissions by injecting ammonia vapor into an SCR. These two (2) processes also have a DIFFERENT program level. The 44,840 pounds of aqueous ammonia is a Program Level 2 process and the 87,840 pounds of anhydrous ammonia is a Program Level 3 process. So EPA used many different RAGAGEPs in this inspection as the two (2) processes are very different and have their own specific RAGAGEPs from IIAR and CGA.
This inspection also had a few very strange citations that are absolutely hogwash, so I am not sure how this agreement was reached! For example:
- Two wrenches of different sizes within the vicinity of the king valve were not labeled
- Nor were there instructions about the direction the king valve should be turned (on/off)