Respondent operates an ammonia refrigeration plant with 50,629 pounds of anhydrous ammonia which is an RMProgram level 3 covered process. On March 27, 2019, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its stationary source. During the inspection, EPA conducted a walkthrough of the Facility and found the following occurrences where the Respondent failed to document that equipment complies with RAGAGEP:
a. The high-pressure receiver (HPR) and associated equipment were located outside and were not secured. There was no fencing with a locking gate to secure the outside equipment.
i. American National Standards Institute / International Institute of Ammonia Refrigeration (ANSI/IIAR) 2-2014 Section 7.2.4 states, “Equipment shall be protected where a risk of physical damage exists. Where equipment containing ammonia is located in an area with heavy vehicular traffic during normal operations and a risk of impact exists, vehicle barriers or alternative protection shall be provided in accordance with the Fire Code.”
ii. ANSI/IIAR 2-2014 Section 5.12.2 states, “Refrigeration system charging connections shall be plugged or capped. When located outdoors, they shall be locked or otherwise restricted to access by only authorized personnel.”
iii. ANSI/IIAR 2-2014 Section 7.2.2 states, “Access to the refrigeration equipment shall be restricted to authorized personnel.”
b. The ammonia leak detection alarms were not identified with signage of their function.
i. ANSI/IIAR 2-2014 Section 17.6 states, “Ammonia leak detection alarms shall be identified by signage adjacent to visual and audible alarm devices.”
c. There was no National Fire Protection Association (NFPA) diamond on the HPR.
i. ANSI/IIAR 2-2014 Section 5.14.2 NFPA 704 Placards states, “Buildings and facilities with refrigeration systems shall be provided with placards in accordance with NFPA 704. For equipment located outdoors, the placard shall display the following degrees of hazard: Health-3, Flammability-1, Instability-0. For equipment located indoors, the placard shall display the following degrees of hazard: Health-3, Flammability-3, Instability-0.”
d. Cardboard, wood pallets, and other combustible materials were found in the machinery room.
IIAR Bulletin 112, Section 4.2.1(a) states, “Lubricants or other combustible materials shall not be stored in the machinery room.”
e. The ammonia piping connected to evaporators was not labeled with contents, physical state, and direction of flow.
ANSI/IIAR 2-5.14.5 states, “Ammonia piping mains, headers, and branches shall be identified with the following information:
1.“AMMONIA.”
2. Physical state of the ammonia.
3. Relative pressure level of ammonia, being low or high as applicable.
4. Pipe service, which shall be permitted to be abbreviated.
5. Direction of flow.”
“The marking system shall either be one established by a recognized model code or standard or one described and documented by the facility owner.”
f. One of the high-pressure compressor nameplates was illegible.
ANSI/IIAR 2-2014 Section 8.4.1 states, “The following data shall be provided on nameplates or labels affixed to compressors:
1. Manufacturer’s name.
2. Manufacturer’s serial number.
3. Manufacturer’s model number.
4. Year manufactured (encoded with serial number is permissible).
5. Maximum allowable working pressure (MAWP).
6. Maximum rotation speed in rpm.
7. Direction of rotation; comply with Section 5.17.2, if applicable”.
ALLEGED VIOLATIONS
Respondent failed to document that equipment complies with RAGAGEP, as required by 40 C.F.R. § 68.65(d)(2).
Respondent consents to the payment of a civil penalty in the amount of $31,151.
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