EPA RMP Citations @ frozen poultry storage facility (NH3 & $159K)

EPA-Alleged Condition:

Examples of RAGAGEP:

The main shutoff value (“king valve”) located behind the high-pressure receiver was not clearly labeled.

It is standard industry practice for the emergency shut-off valve be clearly and uniquely identified at the valve itself and in schematic drawings. See e.g.,

IIAR 9-2020, § 7.2.9.3;_and HAR Bull. 109, § 4.10.3

Ammonia alarms were not present in some required areas, including, but not limited to, outside the ammonia machinery room entry door leading to the refrigerated loading dock.

It is standard industry practice to have ammonia leak

detection, with audible and visible alarms located both inside the ammonia machinery room and outside of each entrance to the machinery room. See e.g., IIAR2-2014 § 6.13, HAR 9-2020, § 7.3.12.1,

ASHRAE 15-2019. § 8.13.10.l; andNFPA 12012,

§ 53.2.3.1.2. It is also industry practice to have Level 1 detection and alarm in areas outside the machinery room where an ammonia refrigeration

equipment is installed. IIAR 2-2014 § 6.13

Ammonia piping on the roof the Facility had damaged labels or lacked appropriate labeling.

The standard industry practice is for piping mains, headers, and branches to be identified as containing ammonia and as to the physical state of the refrigerant (that is, vapor or liquid, etc.), the relative pressure level of the refrigerant, and the direction of flow. See e.g., IIAR 9-2020 § 7.2.9.4; IIAR 2-2014,

§ 5.14.5, HAR Bull. 109, § 4.7.6, HAR Bull. 114,

§ 4.2.1.

The Facility’s ammonia machinery room did not have unobstructed eyewash stations or safety showers located outside the room.

Specifically, (1) the exit from the ammonia machinery room to the interior warehouse lacked an eyewash station outside the exit door in the warehouse, and (2) outside the second exit from the ammonia machinery room which leads to the exterior, the eyewash station was not located on the same level as the ammonia machinery room and was instead located down a set of stairs which would obstruct immediate access to the eyewash station for a person suffering from ammonia exposure.

The standard industry practice is to maintain a minimum of two eyewash stations/shower units, one located inside the machinery room and one located outside of the machinery room. Additional eyewash/safety shower units shall be installed such that the path of travel in the machinery room is no more than 55 feet to an eyewash/safety shower. See e.g., IIAR 9-2020, § 7.3.7.l; IIAR2-2014, § 6.7;

IIAR Bull. 109, § 4.10.10. The emergency eyewash/safety shower unit installations are to comply with ANSI/ISEA 2358.1 standards, which specify that eyewash stations must be installed in accessible locations that require no more than 10 seconds to reach and must be located on the same level as the hazard and the path of travel shall be free of obstructions that may inhibit immediate use. See e.g., ANSI/ISEA 23581.1-2014, §§ 4.5.2, 5.4.2, and BS.

The ammonia machinery room at the Facility lacked required signage to display important information about the Process.

It is standard industry practice for the person in charge of a facility with an ammonia refrigeration system to provide directions for emergency shutdown of the system in a location that is readily accessible to trained refrigeration system staff and trained emergency responders. The schematic drawings or signage shall include several types of information including: (1) Instructions with details and steps for shutting down the system in an emergency; (2) The name and telephone numbers of the refrigeration operating, maintenance, and

management staff, emergency responders, and safety personnel; (3) The names and telephone numbers of all corporate, local, state, and federal agencies to be contacted as required in the event of a reportable incident; (4) Quantity of ammonia in the system; (5) Type and quantity of refrigerant oil in the system; and, (6) Field test pressures applied. See e.g., IIAR 2-2014, § 5.15; ASHRAE 15-2013, § 11.2.1; and

HAR 9-2020, § 7.2.10.

The drainage system for the Facility’s ammonia machinery room lacked a means to limit the spread of liquid ammonia into the drainage system, such as a cover for floor drains.

It is standard industry practice to provide a means for limiting the spread of a liquid ammonia spill into the machinery room drainage system. See, e.g., IIAR 9-2020, §§ 7.3.8.2 and 7.3.8.3; IIAR2-2014 § 6.9.3.

There were problems with the insulation of ammonia piping at the Facility, including insulation that was missing, frosted or corroded, indicating that the insulation was failing.

The standard industry practice is for piping and equipment surfaces not intended for heat exchange to 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. See, e.g., HAR 9-2020, § 7.2.6.1; IIAR 2-2014, § 5.10.1. In addition, the standard industry practice is to check piping for signs of corrosion and to treat corroded piping with rust-preventative paint, and to replace the badly corroded pipe. See e.,g., IIAR Bull. 109, && 4.7.4 and 4.7.5.

During the Inspection, ammonia sensors and alarms in the ammonia machinery room were not functioning properly.

It is standard industry practice to test ammonia detectors in accordance with the manufacturers’ specifications. See e.g., ASHRAE 15-2013, § 11.6.3, and IIAR 2-2014, § 5.12.3. The minimum machinery room alarm response is further described in HAR 9-2020, § 7.3.12.2.