EPA inspected a food distribution warehouse in October 2012 that contained an ammonia refrigeration process. The inspection found the following issues:
1) Assume the release rate for the worst case release scenario (WCS) analysis to be the total quantity divided by 10, if there are no passive mitigation systems in place as required by Section 112(r)(7) of the Clean Air Act (the Act). and 40 CFR. §68.25(c)(1). For the WCS the Facility used a release quantity of 21,480 pounds and a release rate of 1180 pounds/min with a resulting distance to endpoint of 1.2 miles. However, 21,480 pounds released over 10 minutes (per requirements) would yield a release rate of 2,148 pounds/minute. When RMP Comp was run using the revised release rate, a distance to endpoint of 1.7 miles was the result. In the January 18, 2013 response to EPA’s Notice of Inspection Findings and Request for Information, the Facility stated that the RMP reviewed by Mr. XXXXXX during the October 26, 2012 inspection contained an apparent typo that indicated a release rate of 1180 pounds/min with a resulting distance to endpoint of 1.2 miles. On January 11, 2013, the Facility performed a WCS using RMP Comp software based on a release of 21,480 pounds from the largest vessel over a 10 minute period. The results indicated a release rate of 2,150 pounds/min and an estimated distance to toxic endpoint of 1.7 miles. The Facility corrected the information in RMP eSubmit on January 15, 2012.
2) Certify annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary as required by Section 112(r)(7) of the Act, and 40 C.FR §68. 69(c). All of the Standard Operating Procedures (SOPs) reviewed during EPA’s inspection appear not to have been certified annually since 2009. In their January 18, 2013 response to EPA the Facility submitted a copy of their annual certification of operating procedures, dated April 23, 2012. They have also initiated a recurring internally generated work order to schedule and complete future annual certifications. Their 2013 certification is scheduled to begin on April 01, 2013.
3) Provide refresher training at least every three years, or more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process as required by Section 112(r)(7) of the Act. and 40 CFR. §68.71(b). The last operator refresher training was conducted in January 2011. Although the training syllabus indicated that it was provided over 32 hours, it appeared to be general in nature and there was no indication that training was offered on the current operating procedures of the process. The Facility submitted documentation of the required training, conducted January 14-16, 2013, in their January 18, 2013 response to EPA.
4) Ensure the frequency of inspections and tests of process equipment is consistent with applicable manufacturers’ recommendations, good engineering practices, and prior operating experience as required by Section 112(r)(7) of the Act, and 40 C. FR. §68.73(d)(3). An annual inspection per International Institute of Ammonia Refrigeration (lIAR) Bulletin 109 was completed in August 2011; thus, the subsequent annual inspection was due no later than August 2012. However, as of the date of the inspection this subsequent annual inspection had not been completed. In their January 18, 2013 response to EPA the Facility stated that they have begun reviewing previously completed inspections for content and frequency to ensure that they are consistent with manufacturer recommendations and good engineering practices. The annual inspection of the ammonia refrigeration system was conducted by XXXXXXX between August 21 and November 5, 2012, and included a visual inspection of each piece of equipment. The Facility stated that future inspections will utilize the Bulletin 109 form to document consistency with manufacturer recommendations and good engineering practices.
5) Correct deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation as required by Section 112(r)(7) of the Act, and 40 C.F.R. §68. 73(e). The Facility was not able to provide any documentation indicating that deficiencies documented during the annual and 5 year inspections were corrected before further use or in a timely and safe manner. In their January 18, 2013 response to EPA, the Facility stated that remaining action items from the Mechanical Integrity Inspection completed in 2009 have been prioritized and scheduled for completion. A summary of the costs associated with action items from the 2009 Mechanical Integrity Inspection and the 2010 Compliance Audit were included.
Other Observations/Recommendations-
1) The Facility has a large number of open action items/recommendations from its Process Hazard Analysis (PHA), mechanical integrity inspections and compliance audits. These numerous items were tracked across several different word processing and spreadsheet applications with no relative priorities or risk rankings assigned to the various items. EPA later recommended that the Facility consider assigning priorities or risk rankings to the various items and institute a single, global tracking system. EPA also recommended that the Facility ensure that all such items are promptly addressed, documented and resolved in accordance with the identified schedule(s).
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