Respondent is the owner and/or operator of a stationary source that uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia, a regulated substance, as specified at 40 C.F.R. §§ 68.115 and 68.130. EPA conducted an inspection of the Facility on December 12, 2016 and EPA observed alleged violations of 40 C.F.R. part 68. The alleged violations involve:
- maximum intended inventory
- relief system design and design basis
- manual king valve on the Controlled Pressure Receiver was not labelled in accordance with Section 5.14.3 of IIAR 2 2014
- Ammonia piping mains, headers, and branches, were not adequately identified and marked in accordance with Section 5.14.5 of IIAR 2 2014
- machinery room doors not marked with a sign indicating that only authorized personnel ONLY accordance with Section 6.3.4 of IIAR 2 2014
- two doors to the machinery room were not equipped with panic-type hardware in accordance with Section 6.10.2 ofIIAR 2 2014
- vessel nameplate was not visible above the insulation and could not be inspected in accordance with Section 12.5.2 of IIAR 2 2014
- failed to address the ammonia incident that occurred on January 5, 2009 when updating and revalidating the PHA in 2014
- failed to develop and implement written operating procedures for emergency shutdown
- insulated piping was breached in the outer jacket and vapor retarder, and piping had ice formation on the surface; inspections on the insulated ammonia piping has not been performed in accordance with Section 6. 7.2 of IIAR Bulletin 110
- failed to provide documentation regarding the frequency of inspections and tests performed on the ammonia refrigeration process equipment
- failed to implement a MOC for the installation of a valve on a roof-top vent for the venting system connected to the four pressure vessels
- failed to update the P&IDs related to the removal of evaporators