EPA RMP citations @ cold storage facility (NH3 & $95K)

By /

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:

  1. maximum intended inventory
  2. relief system design and design basis
  3. manual king valve on the Controlled Pressure Receiver was not labelled in accordance with Section 5.14.3 of IIAR 2 2014
  4. Ammonia piping mains, headers, and branches, were not adequately identified and marked in accordance with Section 5.14.5 of IIAR 2 2014
  5. machinery room doors not marked with a sign indicating that only authorized personnel ONLY accordance with Section 6.3.4 of IIAR 2 2014
  6. two doors to the machinery room were not equipped with panic-type hardware in accordance with Section 6.10.2 ofIIAR 2 2014
  7. vessel nameplate was not visible above the insulation and could not be inspected in accordance with Section 12.5.2 of IIAR 2 2014
  8. failed to address the ammonia incident that occurred on January 5, 2009 when updating and revalidating the PHA in 2014
  9. failed to develop and implement written operating procedures for emergency shutdown
  10. 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
  11. failed to provide documentation regarding the frequency of inspections and tests performed on the ammonia refrigeration process equipment
  12. 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
  13. failed to update the P&IDs related to the removal of evaporators

  1. 40 C.F.R. § 68.65(c)(l) provides that the process safety information shall include information pertaining to the technology of the process. Respondent failed to have maximum intended inventory concerning the technology of the ammonia refrigeration process. This is a violation of 40 C.F.R. § 68.65(c)(1).
  2. 40 C.F.R. § 68.65(d)(l)(iv) provides that the process safety information shall include information pertaining to the equipment in the process including relief system design and design basis. Respondent failed to have specific information pertaining to the relief system design and design basis. This is a violation of 40 C.F.R. § 68.65(d)(1)(iv).
  3. 40 C.F.R. § 68.65(d)(2) provides that the owner or operator shall document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP). The manual king valve on the Controlled Pressure Receiver was not labelled in accordance with Section 5.14.3 of IIAR 2 2014, Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems. This is a violation of 40 C.F.R. § 68.65(d)(2).
  4. 40 C.F.R. § 68.65(d)(2) provides that the owner or operator shall document that equipment complies with RAGAGEP. Ammonia piping mains, headers, and branches, including piping connected to compressors C-5 and C-6 and piping in the warehouse cooler, were not adequately identified and marked in accordance with Section 5.14.5 of IIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
  5. 40 C.F.R. § 68.65(d)(2) provides that the owner or operator shall document that equipment complies with RAGAGEP. All machinery room entrance doors were not marked with a sign indicating that only authorized personnel are permitted to enter in accordance with Section 6.3.4 of IIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
  6. 40 C.F.R. § 68.65(d)(2) provides that the owner or operator shall document that equipment complies with RAGAGEP. The two doors to the machinery room were not equipped with panic-type hardware in accordance with Section 6.10.2 ofIIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
  7. 40 C.F.R. § 68.65(d)(2) provides that the owner or operator shall document that equipment complies with RAGAGEP. The Low Pressure Accumulator nameplate was not visible above the insulation and could not be inspected in accordance with Section 12.5.2 of IIAR 2 2014. This is a violation of 40 C.F.R. § 68.65(d)(2).
  8. 40 C.F.R. § 68.67(c)(2) provides that the process hazard analysis (PHA) shall address the identification of any previous incident which had a likely potential for catastrophic consequences. Respondent failed to address the ammonia incident that occurred on January 5, 2009 when updating and revalidating the PHA in 2014. This is a violation of 40 C.F.R. § 68.67(c)(2).
  9. 40 C.F.R. § 68.69(a)(1)(iv) provides that the owner or operator shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements: Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner. Respondent failed to develop and implement written operating procedures for emergency shutdown. This is a violation of 40 C.F.R. § 68.69(a)(1)(iv).
  10. 40 C.F.R. § 68.73(d)(2) provides that inspection and testing procedures shall follow RAGAGEP. Respondent failed to follow RAGAGEP for the inspection and maintenance of the insulated ammonia piping in the warehouse cooler. One section of insulated piping was breached in the outer jacket and vapor retarder, and two sections of insulated 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, Guidelines for Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems. This is a violation of 40 C.F.R. § 68.73(d)(2).
  11. 40 C.F.R. § 68 .73(d)(3) provides that the frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices. Respondent failed to provide documentation regarding the frequency of inspections and tests performed on the ammonia refrigeration process equipment. This is a violation of 40 C.F.R. § 68.73(d)(3).
  12. 40 C.F.R. § 68.75(a) provides that the owner or operator shall establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process. Respondent failed to implement a management of change procedure for the installation of a valve on a roof-top vent for the venting system connected to the four pressure vessels located in the machinery room. The purpose of this venting system is to allow for the isolation of a vessel as needed for maintenance. The installation of this valve is discussed in the Near Miss Report dated 11/23/2014. This is a violation of 40 C.F.R. § 68.75(a).
  13. 40 C.F.R. § 68.75(d) provides that if a change covered by this paragraph results in a change in the process safety information required by 40 C.F.R. § 68.65, such information shall be updated accordingly. The owner/operator failed to update the P&IDs related to the removal of evaporators E-503 and E-504 from the Bacon Room. This is a violation of 40 C.F.R. § 68.75(d).

CLICK HERE for the CAFO

Related Posts

Scroll to Top