EPA inspected a meat plant that has an ammonia refrigeration process that qualified as a Program 3. This inspection should garner additional attention as this inspection took place VERY SOON after the facility was sold/bought. The new owner took over on August 29, 2011 and the inspection took place on May 16th and 17th, 2012. The new owner was cited for issues that resulted from the previous owners lack of attention to detail to process safety. Lesson’s learned… for a couple of dollars a due diligence would have saved $ and embarrassment for the new owner. The citations could not even be considered “low hanging fruit” as these were so easy; the EPA inspectors were tripping over them as these had already fallen off the tree!! Here is a break down of the citations and a copy of the settlement agreement… (BTW… I am very disappointed in what EPA accepted as “closure” for these issues as NONE of the closure plans actually improved or ensured “process safety”. Everything was “from this point forward XXXXX will do….”. When you see some of the citations you will ask yourself, what about the last 12 years??)
Prevention Program – Safety Information [§ 68.65(d)(2)] $1,500
The owner or operator fail to document that equipment complies with recognized and generally accepted good engineering practices.
Prevention Program – Process Hazard Analysis [68.67(e)] $1,500
The owner or operator failed to establish a system to:
- promptly address the team’s findings and recommendations
- assured that the recommendations are resolved in a timely manner and documented
- document what actions are to be taken
- complete actions as soon as possible
- develop a written schedule of when these actions are to be completed; and
- communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions
Prevention Program – Process Hazard Analysis [68.67(t)] $2,500
The owner or operator failed to insure that the PHA has been updated and revalidated by a team every five years after the completion of the initial PHA to assure that the PHA is consistent with the current process.
Operating procedures [68.69(c)] $1,200
The owner or operator failed to certify annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary.
Emergency response program § 68.180 No Penalty Assessed
The owner or operator failed to include a written emergency response plan that included specific actions to be taken in response to an accidental release of a regulated substance in the RMP.
CLICK HERE (pdf) to see the agreement