Respondent operates an ammonia refrigeration system which uses 30,345 pounds anhydrous ammonia (ammonia). Respondent has one RMProgram level 3 covered process, which stores or otherwise uses an extremely hazardous substance in an amount exceeding its applicable threshold of 10,000 pounds. On December 21, 2017, the EPA conducted an onsite 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 ammonia refrigeration process at its stationary source.
During a walk-through of the Facility, the EPA inspectors made the following observations:
1) Yellow natural gas piping on the roof was not properly labeled to identify its contents. The American National Standards Institute/American Society of Mechanical Engineers (ANSI/ASME) A13.1-2007 indicates, “Positive identification of the contents of a piping system shall be by lettered legend, giving the name of the contents in full or abbreviated form. Arrows shall be used to indicate the direction of flow.” The Facility did not provide documentation that the natural gas labeling complied with RAGAGEP.
2) Electrical safety issues were noted in numerous locations throughout the facility as follows:
- On the roof, the electrical conduit was connected using tape;
- In ammonia machine room (AMR) 1B, inspectors observed an open electrical junction box;
- In AMR 1A, the eyewash and safety shower were adjacent to a wall-mounted electrical box that did not have a ground fault circuit interrupter (GFCI) receptacle;
- In the caged area adjacent to the high-pressure receiver (HPR), open electrical wires were hanging from the side of the building; and
- In the ingredients cooler, open electrical wires were hanging from an ammonia evaporator where the fan had been removed.
The National Fire Protection Association (NFPA) 70-2014, Section 110.12(B) states,
“there shall be no damaged parts that adversely affect safe operation or mechanical strength of the equipment such as parts that are broken, bent, cut, or deteriorated by corrosion, chemical action, or overheating.”
The Facility did not provide documentation that its electrical safety complied with RAGAGEP.
3) Inspectors observed unsupported piping on the roof and beneath the HPR. The American National Standards Institute/International Institute of Ammonia Refrigeration (ANSI/IIAR) 2-2014, Section 13.4.2. requires “refrigerant piping be isolated and supported to prevent damage from vibration, stress, corrosion, and physical impact,” and the ANSI/American Society of Heating, Air-Conditioning Engineers (ASHRAE) 15-2016, Section 8.10.4 states “refrigerant piping shall be properly isolated and supported to prevent damaging vibration, stress, or corrosion.” The Facility did not provide documentation that its unsupported piping complied with RAGAGEP.
4) The vapor retarder was missing, and insulation was damaged on ammonia piping outside of the spiral freezer. The ANSI/IIAR 2-2014, Section 5.10.1 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.” The IIAR Bulletin 109, Sections 4.7.5 states “insulated piping showing signs of vapor barrier failure should have the insulation removed and the pipe inspected.” The Facility did not provide documentation that its missing vapor retarder and damaged insulation complied with RAGAGEP.
5) The audible and visual ammonia detection alarms outside the entrance to AMR 1B and above the interior entry door to AMR 1A did not contain signage. The ANSI/IIAR 2-2014, Section 17.6 states, “Ammonia leak detection alarms shall be identified by signage adjacent to visual and audible alarm devices.” The ASHRAE 15-2016, Section 8.11.2.1 states, “The meaning of each alarm shall be clearly marked by signage near the annunciators.” The Facility did not provide documentation that the signage for ammonia leak detection alarms complied with RAGAGEP.
6) Inspectors observed unsealed wall penetrations in both machine rooms that would allow ammonia to escape if a release occurred. In AMR 1B, the wall opening for the electrical conduit to pass into the electrical room was not sealed and in AMR 1A, ammonia piping passing through the wall was not sealed. The ANSI/IIAR 2-2014, Section 6.6.2 states that “pipes penetrating the machinery room separation shall be sealed to the walls, ceiling, or floor through which they pass” and Section 6.2.1 of the ANSI/IIAR 2-2014 states that “the machinery room shall be separated from the remainder of the building by tight-fitting construction with a one-hour fire-resistance rating.” The ASHRAE 15-2016, Section 8.12(c) states “walls, floor, and ceiling shall be tight and of construction.” The Facility did not provide documentation that the unsealed wall penetrations complied with RAGAGEP.
7) One exit door from AMR 1A did not contain panic-type hardware and was not hinged to swing in the direction of egress. The ANSI/IIAR 2-2014 Section 6.10.2 states, “Doors that are part of the means of egress shall be equipped with panic hardware and shall be side-hinged to swing in the direction of egress for occupants leaving the machinery room.” The Facility did not provide documentation that the exit door for the AMR complied with RAGAGEP.
8) A portion of the valves on piping and equipment in AMR 1B did not contain valve identification tags indicating the refrigerant flow direction. The ANSI/ASHRAE 15-2013, Section 11.2.2 states “systems containing more than 110 pounds (50 kg) of refrigerant shall be provided with durable signs having letters not less than 0.5 inches (12.7 mm) in height designating valves or switches for controlling the refrigerant flow.” The NFPA 1-2012, Section 53.3.4.2 states “systems containing more than 110 lb. (50 kg) of refrigerant shall be provided with signs having letters not less than 1⁄2 in. (12.7 mm) high, designating the following: (1) main shutoff valves to each vessel.” The Facility did not provide documentation that the identification tags on the valves controlling the refrigerant flow complied with RAGAGEP.
9) The HPR located inside the caged area did not contain NFPA diamonds to indicate the presence or hazards of ammonia. The NFPA 1-2012, Section 53.2.4.1 and ANSI/IIAR 2-2014, Section 6.15.1 require buildings and facilities with refrigeration systems be provided with placards accordance with NFPA 704 and the Mechanical Code. The Facility did not provide documentation that its NFPA placards conformed with RAGAGEP.
10) The King Valve on the HPR was located approximately eight feet off the ground and above the vessel. There was no permanent ladder or work platform to access the valves in the event of an emergency. In addition, no chain-operated valve was installed on the King Valve to allow for easy closure. The ANSI/IIAR 2-2014, Section 6.3.3.2 states “manually operated isolation valves identified as being part of the system emergency shutdown procedure shall be directly operable from the floor or chain operated from a permanent work surface.” The Facility did not provide documentation that the King Valve complied with RAGAGEP.
11) The sign on the King Valve was broken and weathered making it difficult to identify. The ANSI/IIAR 2-2014, Section 5.14.3 requires “valves required for emergency shutdown of the system shall be clearly and uniquely identified at the valve itself and in the system schematic drawings.” The Facility did not provide documentation that the signage for the King Valve complied with RAGAGEP.
12) Corrosion and blistered paint on ammonia piping entering the HPR was observed by inspectors in two locations. The ANSI/IIAR 2-2014, Section 13.4.2 states “refrigerant piping shall be isolated and supported to prevent damage from vibration, stress, corrosion, and physical impact.” The NFPA 1-2012 requires “refrigeration systems be operated and maintained in a safe and operable condition, free from accumulations of oil, dirt, waste, excessive corrosion, other debris, or leaks, and in accordance with the ASHRAE 15 and the mechanical code. The IIAR Bulletin 109, Sections 4.7.4 states “uninsulated refrigerant piping should be examined for signs of corrosion, and if corrosion exists, the pipe should be cleaned down to bare metal and painted with a rust preventive paint and badly corroded pipe should be replaced.” The Facility did not provide documentation that the piping corrosion and blistered piping painting complied with RAGAGEP.
13) Ammonia piping associated with evaporators in the coolers and freezer was unlabeled. In addition, piping from the condensers to the HPR did not contain labeling. This is inconsistent with the ANSI/IIAR 2-2014, Section 5.14.5; the IIAR Bulletin 109, Section 4.7.6; the IIAR Bulletin 114, Sections 4.1.1 through 4.1.8; and the ANSI/ASME 13.1-2007 that state ammonia piping mains, headers, and branches shall be identified with the contents (“AMMONIA”), including the physical state of the ammonia, the pressure level of ammonia being low or high, pipe service, and direction of flow. The Facility did not provide documentation that the ammonia piping labeling complied with RAGAGEP.
14) Ammonia evaporators in the ingredient’s cooler were unprotected from physical damage by lift trucks stacking loaded pallets. The ANSI/IIAR 2-2014, Section 7.2.4 requires “equipment be protected where a risk of physical damage exists. Where equipment containing ammonia is in an area with heavy vehicular traffic during normal operations and a risk of impact exists, vehicle barriers or alternative protection shall be provided in accordance with the Fire Code.” The ANSI/ASHRAE 15-2013, Section 11.1 states “means shall be taken to adequately safeguard piping, controls, and other refrigerating equipment to minimize possible accidental damage or rupture by external sources.” The Facility did not provide documentation that its unprotected ammonia evaporators complied with RAGAGEP.
15) Extension cords were being used in the freezer, the ingredient’s cooler and raw cooler to power heating tapes that prevent freezing of condensate water lines. The NFPA 1-2012, Section 11.1.7.6 states that “extension cords shall not be used as a substitute for permanent wiring.” The Facility did not provide documentation that its use of extension cords complied with RAGAGEP; and
The EPA inspection team reviewed the Facility’s procedures for managing changes and observed that the procedures indicated the method of informing staff of changes was “word of mouth.” Using “word of mouth” provides no documentation to verify employees are trained in the change prior to start-up of the process and does not ensure all employees whose job tasks will be affected are informed of the change.
ALLEGED VIOLATIONS
Based on the EPA’s compliance monitoring investigation, the EPA alleges that the Respondent violated 40 C.F.R. Part 68, the codified rules governing the Act’s Chemical Accident Prevention Provisions and Section 112(r) of the Act, 42 U.S.C. § 7412(r), when it:
a) Failed to document that equipment complies with RAGAGEP as required by 40 CFR § 68.65(d)(2); and
b) Failed to inform employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process of, and trained in, the change prior to start-up of the process or affected part of the process as required by 40 CFR § 68.75(c).
Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of ONE HUNDRED FOUR THOUSAND FIVE HUNDRED TWO DOLLARS ($104,502)
CLICK HERE for the CAFO