Respondent owns an ice production operation and two refrigerated warehousing storage operations which consist of two separate ammonia closed-loop refrigeration system processes. Both processes have refrigerated and frozen storage space using industry standard mechanical refrigeration designs including multiple cooling coils (evaporators), heat rejection towers (condensers), rotary screw compressors, and ammonia service pressure vessels. At the single Stationary Source, Respondent has two RMProgram level 3 covered processes which store or otherwise use anhydrous ammonia in amounts exceeding its applicable threshold of 10,000 pounds. During calendar year 2013, EPA opened an RMProgram compliance monitoring investigation to determine Respondent’s compliance with 40 C.F.R. Part 68. As part of this investigation, EPA conducted an onsite inspection of RMProgram related records and equipment on April 30th and May 1st of 2013. The focus of the onsite inspection was to assess Respondent’s compliance with RMProgram requirements for its covered processes operating at its Stationary Source.
At the time of the inspection,
- Respondent did not produce documentation supporting that it had updated and revalidated its process hazard analysis (PHA) for one of the covered processes at least every five years after the initial PHA. The initial PHA was dated as completed on October 30, 2001. Subsequent PHA updates were dated as complete on November 30, 2006, and November 26, 2012. The November 26, 2012, PHA update was 12 months past due.
- Respondent failed to retain PHA documented resolution of recommendations for the life of the process. Recommendations from the November 2012 Distribution Center PHA had not been documented as resolved at the time of the inspection. At the time of inspection, Respondent did not produce documentation of the means it used to verify that each employee operating the processes understood the required training covering an overview of the processes and the associated operating procedures.
- Respondent did not produce complete records for the equipment vacuum and pressure tests.
- Respondent failed to produce evidence indicating that it performed appropriate checks and inspections to assure that Ice Maker #2 equipment was installed properly and consistent with design specifications and the manufacturer’s instructions.
- Respondent failed to document that it had implemented appropriate responses to each of the findings from its Stationary Source RMProgram compliance audits.
- Respondent failed to update its RMPlan emergency contact information within thirty days of a change in such information.
Respondent agrees to pay the civil penalty of FORTY-NINE THOUSAND DOLLARS ($49,000).
CLICK HERE for the CAFO