Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so I am not sure. Each GDC citation below had a $16,550 tacked onto it, but was negotiated down to $9,103. The GDCs focused on
- SOPs,
- Piping Insulation issues leading to premature degradation, and
- having never inspected vessel HTR01
(emphasis by me)