EPA RMP Citations @ Cold Storage facility (NH3 and $8K)

On March 7, 2013, EPA conducted a compliance inspection of Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the Respondent had violated regulations 

implementing section 112(r)(7) of the Act by failing to comply with the specific requirements outlined in the attached RMP Program Level 3 Process Checklist-Alleged Violations & Penalty Assessment (Checklist and Penalty Assessment)…

Does the process safety information include materials of construction pertaining to the equipment in the process? [68.65(d)(1)(i)]  $600

• The materials of construction were unknown for two process vessels identified as V-4 and V-6. 

Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices? [68.65(d)(2)]  $1500

• Ammonia Pressure Vessels V-4 and V-6 were missing nameplates.  
• IIAR Bulletin No. 109 Minimum Safety Criteria for a safe Ammonia Refrigeration System 4.3.1.2 states: 
  • All pressure vessels shall have a name plate with the following minimum data: 
    • Manufacturer’s name 
    • Serial number 
    • Model number 
    • Year of manufacture 
    • Maximum allowable pressure 
    • Test pressure applied 
    • National Board Number (where applicable) 
    • Manufacturer’s ASME stamp (where applicable) 

Has the owner or operator established a system to promptly address the team’s findings and recommendations; assured that the recommendations arc resolved in a timely manner and documented; documented what actions are to be taken; completed actions as soon as possible; developed a written schedule of when these actions are to be completed; and communicated the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations? [68.67(e)] $1500

• Numerous recommendations were not resolved for the 2004 and 2009 Process Hazard Analyses (PHAs). For example: 
  • Action Item #7 on the 4/1/2004 PHA Deficiency Action Log states “Consider extending all PRV headers to 15 feet above the roof and point to a safe location.” 
  • Item 2.515 on the 3/17/2009 PHA states, “Replace outdated PRVs. Update headers to 15 feet and to a safe location.”
• During the 3/7/2013 inspection, a PRV header was observed to be less than 15 feet above the roof. A facility reprentative confirmed that it still needed to be fixed. 

Has each employee involved in operating a process, and each employee before being involved in operating a newly assigned process, been initially trained in an overview of the process and in the operating procedures? [68.71(a)(1)]  $1500

• A worker started working at the facility in November 2009. The facility was unable to provide documentation of his initial training. The facility was unable to provide any training records prior to 2012. 

Has the owner or operator followed recognized and generally accepted good engineering practices for inspections and testing procedures? [68.73(d)(2)]  $900

• Extensive insulation damage on V -4 and piping was documented on the 2009 Mechanical Integrity (5-year independent) inspection and the 2012 annual inspection. Extensive insulation damage on V-4 and the LTR Liquid line were observed during this inspection. 
• IIAR Bulletin 110 (Revised 3/02) Guidelines for Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems Section 6.4.3.1(Revised Feb. 4, 2004) Pressure Vessels: “Where a section of insulation is materially damaged, it should be repaired or replaced. Underlying areas affected by surface corrosion should be cleaned off, inspected and appropriately treated before reinstatement of the protective finish, insulation and vapor barrier.” 
• Section 6.7.2 Insulated Piping: “Any mechanical damage to insulation should be repaired immediately… Sections of insulation which are obviously in poor condition shall be removed and the integrity of the exposed piping with the aid of non-destructive testing techniques, as appropriate.” 

Has the owner or operator documented each inspection and test that has been performed on process, which identifies the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the of the inspection or test? [68.73(d)(4)]  $900

• The facility used IIAR Bulletin 109 Safety Inspection Checklists to document the 2012 annual inspections. The facility was unable to produce documentation for annual inspections prior to 2012. 

Has the owner or operator corrected deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe or timely manner when necessary means were taken to assure safe operation? [68.73(e)]  $900

• There are numerous deficiencies from the 2009 Mechanical Integrity Inspection Issues Tracking Report that do not have a documented response. In particular, Findings # 245, 246, 248, 251, 252 and 253 refer to damaged insulation.
• Safety relief valves identified as V-2 and V-3 expired in 2009 and were in service in at the time of EPA’s inspection. Note: a PO from 2/28/2013 (this date is after the facility received our NOI) indicated that the facility is in the process of replacing all the expired PRVs. 
• Safety relief valves identified as #9, #10 and #11 had no valve tags and no date of installation information. These valves were on compressor CP-8.

Has the owner or operator promptly determined and documented an appropriate response to each of the findings of the audit and documented that deficiencies had been corrected? [68.79(d)] $300

• The facility did not document that all deficiencies were corrected from the 7/26/2011 Compliance Audit.

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