This is from a recently posted Consent Decree for a fish processing facility. From all I have seen this facility did NOT have RMP Covered processes using Anhydrous Ammonia, Chlorine or Butane and all of these actions stem from a General Duty Clause agreement, which is by far the most significant GDC agreement I can remember. The facility used the Ammonia as a refrigerant, Chlorine to treat their water, and Butane to power their forklifts. Following a May 2016 inspection of the Facility by EPA and identification of the Clean Air Act Section 112(r) violations alleged in the Complaint, Defendant and EPA entered into an Administrative Compliance Order on Consent (“AOC”) pursuant to Section 113(a) of the Clean Air Act and pursuant to that AOC, Defendant carried out a number of assessments related to its ammonia refrigeration, chlorine, and butane systems.
EPA required actions on all three chemicals:
Ammonia, Chlorine, and Butane System Requirements
Evaluation of Ammonia Losses
Defendants completed the following work to evaluate potential areas of ammonia loss from the Ammonia Refrigeration System:
- Pressure test the shell and tube heat exchangers and the condenser coils;
- Internally inspect condensers 1 and 2, the injector heat exchangers, and connected piping to confirm the equipment’s integrity; and
- Perform baseline thickness tests on pipes and vessels to determine the remaining life of equipment.
Ammonia Refrigeration System Maintenance
Defendants shall implement an Ammonia Refrigeration System inspection and maintenance schedule.
Pressure Relief Valve Piping Upgrade
Defendants completed the following modifications to the pressure relief valve piping design in the Ammonia Refrigeration System:
- Combined the discharge of all pressure relief valve into fourteen (14) relief terminations;
- Terminated the pressure relief device discharge piping relieving to the atmosphere to be no less than 15 feet above grade;
- Terminated the pressure relief devices relieving to the atmosphere to be no less than 7.25 feet above a roof that is occupied solely during service and inspection. Where a higher adjacent roof level is within 20 feet horizontal distance from the relief discharge, the discharge termination shall not be less than 7.25 feet above the height of the higher adjacent roof;
- Directed the termination of the discharge upward and positioned the termination of the discharge to avoid spraying ammonia on persons in the vicinity;
- Installed drainage for moisture accumulation; and
- Installed discharge piping from pressure relief devices and fusible plugs that are steel pipe minimum Schedule 40 for pipe sizes up to 6 inches and minimum Schedule 20 for pipe sized 8 inches and larger or stainless steel pipe minimum Schedule 40 for pipe sizes 1-1/2 inches and small and minimum Schedule 10 for pipe sizes 2 inches and larger.
At all times, Defendants shall maintain, and have available for inspection at the Facility, an updated Process & Instrument Diagram for the Ammonia Refrigeration System.
Implementation of Ammonia Hazard Assessment Recommendations
Defendants implemented the following recommendations from the ammonia hazard assessment for the Facility:
- Replacement of the Facility’s high pressure receiver;
- Replacement of the Facility’s liquid transfer vessel (“LTV”);
- Installation of Level Alarms on the LTV;
- Replacement of the Facility’s accumulator oil pot, including necessary pressure relief valves and piping; and
- Installation of an emergency stop for remote control of the Facility’s machinery room.
Implementation of Safer Designs for Chlorine System
Defendants discontinued the use of chlorine gas for the disinfection of fish thaw water at the Facility. Defendants have installed equipment and make any upgrades necessary to switch from using chlorine gas to liquid sodium hypochlorite in retort water. As of the Effective Date, Defendants shall use liquid sodium hypochlorite in retort water to disinfect fish thaw water. Defendants may seek approval from EPA to use an alternate method of disinfecting thaw water that is safer than chlorine gas.
Community Notification System
Defendants shall notify the 24/7 Emergency Watch Center or Emergency Operations Center at 699-3800 operated by the American Samoa Government Territorial Emergency Management Coordination Office (“TEMCO”) if any of the following situations arise:
- A fixed ammonia detection of 220 parts per million or greater within a monitored production space or the refrigeration machinery room;
- A visible ammonia cloud is observed; or
- The Facility is evacuated as a result of the release of a chemical listed pursuant to CAA § 112(r)(3).
Defendants shall revise their Emergency Action Response Plan to include the requirements above.
Defendants shall develop, establish, and implement a program to educate the community on what to do in the event of a TEMCO-activated alarm in response to a chemical release.
Butane
Defendants discontinued filling butane cylinders for use in forklifts at the Facility. Defendants shall implement written procedures for receiving butane and for installing cylinders to forklifts at the Facility.
CLICK HERE to see Consent Decree