Respondent is the owner and/or operator of the Facility, which is a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:
(a) Respondent operates an ammonia refrigeration plant.
(b) At all times relevant to the violations alleged, Respondent had on-site for use 15,000 pounds of anhydrous ammonia.
(c) Respondent has one (1) RMProgram level 3 covered process
On July 16, 2024, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its Facility. At the time of the inspection, EPA observed the following:
(a) The process safety information did not accurately document the safe upper limits for compressors.
(b) With respect to whether the Respondent had ensured and documented that its process is designed and maintained in compliance with RAGAGEP:
i. The entry/egress doors between the ammonia machinery room (AMR) and the loading dock were not tight-fitting, such that there were visible gaps present. Section 6.2.1 of American National Standards Institute/International Institute of Ammonia Refrigeration {ANSI/IIAR)-2 {2021) and Section 7.3.9.2 of ANSI/IIAR-9 Addendum-A {2024) state, “Machinery room doors shall be self-closing and tight fitting…JI
ii. The King Valve was not labeled in the AMR. Section 5.14.4 of ANSI/IIAR-2 (2021) states, “Valves required for system emergency shutdown procedures shall be readily accessible and identified in accordance with Sections 5.14.3 and 6.3.3.1.” and Section 7.2.9.3 of ANSI/IIAR-9 Addendum-A (2024) states, “Valves required for emergency shutdown of the system shall be clearly and uniquely identified at the valve itself and in the system schematic drawings.
iii. A safety shower was not provided outside the AMR, only an eyewash station. Section 6.7.2 of ANSI/IIAR-2 (2021) states, “A minimum of one eyewash/safety shower unit shall be located outside the machinery room and shall be no further than 55 ft. from the outside of the machinery room door” and Section 7.3.7.1 of ANSI/IIAR-9 Addendum-A {2024) states, “Each Machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room…”
iv. Ammonia audible/visual alarms throughout the facility were not adequately labeled. Section 17.6 of ANSI/IIAR-2 (2021) states, 11Ammonia leak detection alarms shall be identified by signage adjacent to visual and audible alarm devices” and Section 7.2.9.1(2) of ANSI/IIAR-9 Addendum-A (2024) states, 11Machinery Room Signage. Signage shall be provided in accordance with this section … 2) Alarm Signage. The meaning of each alarm shall be clearly marked by signage near the visual and audible alarms.”
v. Ice build-up was observed on an oil pot and associated piping and valves in the AMR, preventing the use of a valve on the oil pot. Section 5.10.1 of ANSI/IIAR-2 (2021) states, “Piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate effects of condensation and excessive frost buildup to a level that interferes with valve operation or creates damage to piping, equipment or supports” and Section 5.6.8 of ANSI/IIAR-6 (2019) states, “Equipment and piping shall be kept free from excessive ice buildup. Ice buildup shall not interfere with the operation of emergency shut-off valves. Ice accumulation shall not be permitted to deflect or bend pipes, displace components, or negatively impact the system’s structural integrity” and Section 7.2.6.1 of ANSI/IIAR-9 Addendum-A (2024) states, “Piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system.”
vi. Some ammonia pipes on the roof had missing labels or labels that were faded and/or peeling off. Section 5.14.6 of ANSI/IIAR-2 (2021) and Section 7.2.9.4 of ANSI/IIAR-9 Addendum-A (2024) states, “Ammonia piping mains, headers, and branches shall be identified with the following information: I. “AMMONIA”; 2. Physical state of the ammonia; 3. Relative pressure level of ammonia, being low or high as applicable; 4. Pipe service, which shall be permitted to be abbreviated; and 5. Direction of flow.”
(c) The 2021 process hazard analysis did not address an incident that occurred in April 2020 and which had a likely potential for catastrophic consequences.
(d) A total of 12 items ranked C and D were closed after 2023, more than two years after the process hazard analysis was completed in 2021. According to the Respondent’s 2021 process hazard analysis, items ranked C and D should be closed within 1 and 2 years after the process hazard analysis is completed, respectively.
(e) The operation procedures did not accurately document the safe upper limits for compressors.
(f) The Respondent had last conducted a visual inspection of the condensers in August 2021 and its condenser inspection checklist did not specifically address examining the condenser coils for corrosion. Table 8.1 of ANSI/IIAR-6 (2019) requires annual inspections of condensers and specifies that owners/operators “visually inspect condenser coils for degradation of coating and that there is not excessive accumulation of scale or algae growth.”
(g) Respondent had made a change to its process technology, which resulted in a change to the safe upper limits (pressure) for its compressor, but Respondent had not updated its process safety information documentation, required by 40 C.F.R. § 68.65, or its written operating procedures, required by 40 C.F.R. § 68.69, to reflect this new safe upper limit.
Respondent agrees to a civil penalty in the amount of $33,424 (Assessed Penalty)