I usually do not post such small cases, but this 540-megawatt electrical generation facility is sort of unique as it uses 87,840 pounds of anhydrous ammonia in a closed refrigeration system used to cool gas turbine inlet air and increase power output. It also uses 44,840 pounds of aqueous ammonia to reduce NOx emissions by injecting ammonia vapor into an SCR. These two (2) processes also have a DIFFERENT program level. The 44,840 pounds of aqueous ammonia is a Program Level 2 process and the 87,840 pounds of anhydrous ammonia is a Program Level 3 process. So EPA used many different RAGAGEPs in this inspection as the two (2) processes are very different and have their own specific RAGAGEPs from IIAR and CGA.
This inspection also had a few very strange citations that are absolutely hogwash, so I am not sure how this agreement was reached! For example:
- Two wrenches of different sizes within the vicinity of the king valve were not labeled
- Nor were there instructions about the direction the king valve should be turned (on/off)
Program Level 3 Alleged Violations and Unadjusted Penalties
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
Labeling Issues:
At the time of the inspection, the receiver tank, certain doors, and emergency equipment lacked adequate signs and labels, including the following:
Inadequate NFPA signs –
The anhydrous ammonia receiver tank did not have viewable NFPA hazards diamonds visible from any direction of approach, and the size NFPA hazards diamond does not meet NFPA 704 size requirements.
The NFPA signs on the exterior doors at the Chiller Room do not have meet NFPA 704 size requirements.
Inadequate electrical equipment labeling -The emergency ventilation fan switch located next to the exterior door at the southeast corner of the Chiller Room was not clearly labeled (“on” or “off”) and the emergency electrical switches failed to specify what equipment were controlled by each switches
See, e.g.,
NFPA 55-2016 § 7.1.7.3;
NFPA § 704-2012, Figure 9.1(b);
ANSI/ASHRAE 2-2014 § 6.12;
ANSI/ASHRAE 15-2013 § 8.12(i)
Section C – Prevention Program – Safety Information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
Labeling Issues:
At the time of the inspection, certain piping and the sign for the ammonia system lacked critical information, including the following:
Inadequate ammonia piping signage
Piping by the receiver tank lacked enough labels to distinguish flow direction, contents, and physical state
Inadequate ammonia system signage
The sign describing parameters of the ammonia system did not include the field test pressure applied.
See, e.g.,
ANSI/IIAR2-2014 §5.14.5; 5.15
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
Piping Issues:
At the time of the inspection, ammonia piping showed corrosion at locations where the piping meets a support.
Piping maintenance had not been adequately performed.
See, e.g., IIAR Bulletin 110 (3/93) -§ 6.7.1.
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
Piping Issues:
At the time of the inspection, piping containing anhydrous ammonia was not adequately equipped with protection from accidental bumps and resulting damage, including piping under the anhydrous ammonia receiver tank
See, e.g.,
ANSI/IIAR 2-2014 §7.2.4;
ANSI/ASHRAE15-2013§ 11.1
NFPA55-2016 § 4.11.1.1
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
Emergency Procedure issues:
At the time of the inspection emergency shutdown procedures with emergency contact information were not posted outside the exterior doors at the southeast corner and southwest corner of the Chiller Room.
See, e.g.,
ANSI/ASHRAE 15-2013 §11.7;
IIAR Bulletin 109 §4.10.5;
ANSI/IIAR 2-2014 §5.15 and Appendix J
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
King Valve issues:
At the time of the inspection the following problems with the king valve were identified including:
A wrench is required to manually close/open the king valve for the anhydrous ammonia receiver tank.
Two wrenches of different sizes within the vicinity of the king valve were not labeled.
Nor were there instructions about the direction the king valve should be turned (on/off)
See, e.g.,
ANSI/ASHRAE 15-2013 §11.7;
IIAR 2-2014 §13.3.7
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
Emergency Equipment issues:
At the time of the inspection the following problems with the emergency equipment were identified including:
The inspectors observed there was one emergency eyewash station located at the far west end of the Chiller Room.
Process equipment and piping containing anhydrous ammonia that is located toward the east end of the Chiller Room is greater than 55 feet from the closest emergency eyewash station.
An eyewash was also not present within 55 feet of the anhydrous ammonia receiver tank.
Stations must be located within the work area for immediate emergency use (i.e., less than 10 seconds or within 55 feet).
See, e.g.,ANSI/IIAR2-2014 § 6.7
Section C – Prevention Program – Safety information [68.65]
Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)]?
General Hazardous Conditions issues:
At the time of the inspection the following hazardous conditions were identified including:
Combustible materials (e.g., cardboard boxes) were located in the Chiller Room;
The operator computer station is located against the wall in front of an electrical cabinet.
The clearance in front of the electrical cabinet is less than 36-inches;
The inspectors observed a used oil drum next to an ammonia system oil pot.
A transfer hose was connected from the oil pot to the bung hole of the oil drum.
The bung was open that allowed vapors to escape.
The valve on the transfer hose was in the open position.
See, e.g.,
ANSI/IIAR2-2014 §§ 6.4, 5.9
NFPA 70-2017 § 110.26
Program Level 2 Alleged Violations and Unadjusted Penalties
Section C – Prevention Program – Safety information [68.48]
Has the owner or operator owner or operator ensured that the process is designed in compliance with recognized and generally accepted good engineering practices?[68.48(b)]
General Safety Issues:
At the time of the inspection, several aspects of the Facility lacked adequate signs and labels, including the following:
The aqueous ammonia storage tank did not have sufficient NFPA hazards diamonds to be viewable from all normal approaches. The NFPA hazards diamond did not meet NFPA 704 requirements for size.
Piping containing aqueous ammonia at the aqueous ammonia tank and near the SCR was not adequately equipped with protection from accidental bumps that could result in damage.
See e.g.,
ANSI/ASME 13.1-2007
ASME B31.3-2006
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