NOTE: I have posted this inspection because of the level of detail the inspectors went. There has been a significant shift in the quality of findings from BOTH OSHA and EPA in their process safety inspections. This EPA inspection team was well aware that the IIAR Bulletins are being phased out and replaced with ANSI/IIAR standards. The amount was low, but things could have been much more painful. When you install/construct a “bypass line” around your “King Valve” and your operators could not tell the inspection team if the bypass was open or closed, things could have gone much worse…
On April 25, 2018, EPA conducted a compliance inspection of the Distribution Center, which uses 15,000 pounds of ammonia as a refrigerant, to determine its compliance with the Risk Management Program(“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations as noted on the attached “Risk Management Program Inspection Findings, Alleged Violations and Proposed Penalty Form” (“Form”), which is hereby incorporated by reference. Here are the specific issues noted:
Has the owner or operator documented either that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)] or, for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, documented that it is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]?
At the time of the inspection, the Facility LACKED ADEQUATE SIGNS AND LABELS in several places.
- Alarm light signs were vague and confusing (two alarm color schemes and inadequate signage explaining the difference such that someone would understand what actions to take when lit);
- some ammonia piping in warehouse refrigerated rooms was not labeled;
- the ammonia machinery room (AMR) Roof Door lacked required ammonia warning signs, and the glycol chiller room door and
- unit lacked NFPA diamond for ammonia (though had one for other substances)
See, e.g., ANSI/IIAR 2-2014 §6.15; NFPA 1-2012§ 60.5.1.8.2.1; NFPA 704-2012; ASME A13.1-2007 § 3.
See alsoANSI/IIAR 9-2020 §§7.2.9.1,7.2.9.4, 7.3.12.6
Has the owner or operator documented either that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)] or, for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, documented that it is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]?
At the time of the inspection, the liquid discharge line on the medium pressure recirculator contained A BYPASS LINE AROUND THE KING VALVE that could interfere with the functioning of the King Valve as designed and defeat its ability to stop the flow of ammonia in the event of an emergency.
The OPERATORS DID NOT KNOW IF THE MANUAL BYPASS VALVE WAS OPEN OR CLOSED.
Signage indicating the status of the valve would eliminate confusion posed by this configuration.
Additionally, the valve on the bypass line was not accessible from the ground or a permanent work surface.
See, e.g., ANSI/IIAR 2-2014 §§6.3.3.2 &13.3.7; IIAR Bulletin 109 § 4.10.3.
See also ANSI/IIAR 9-2020 §§7.2.9.3,7.3.3.3.
Has the owner or operator documented either that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)] or, for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, documented that it is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]?
At the time of the inspection, facility components essential for quick emergency response were locked, slowing their use.
REMOTE SHUTOFF CONTROLS AT THE PRINCIPAL ENTRANCE TO THE AMR WERE LOCKED and the key needed for operation was NOT READILY ACCESSIBLE.
The fence around the parking lot from the loading dock area lacked a pedestrian gate and the vehicle gate was locked closed with a chain and padlock, which could trap people in the area of a release.
See, e.g., ANSI/IIAR 2-2014§6.12.1; ANSI/ASHRAE 15-2013 §8.12(i); NFPA 1-2012§53.2.3.4.5; NFPA 101-2015 §7.11.
See also ANSI/IIAR 9-2020 §7.3.11.1.
Has the owner or operator documented either that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)] or, for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, documented that it is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]?
At the time of the inspection, the facility lacked audio/visual alarms at the AMR Roof Door and lacked detectors and alarms in the glycol chiller room.
See, e.g., ANSI/IIAR 2-2014§§6.13.1, 17.7; ANSI/ASHRAE 15-2013 § 8.11.2.1; NFPA1-2012, §53.2.3.1.2.
See also ANSI/IIAR 9-2020 §7.3.12.4.
Has the owner or operator documented either that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)] or, for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, documented that it is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]?
At the time of the inspection, the condenser piping contained four PRVs at each end of the condenser that discharged to the atmosphere below the level of the working platform on top of the condenser, rather than the required 7.25feet above.
See, e.g., ANSI/IIAR 2-2014§15.5.1.3; ANSI/ASHRAE 15-2013 §9.7.8.
See also ANSI/IIAR 9-2020 §7.4.2.
Has the owner or operator documented either that equipment complies with recognized and generally accepted good engineering practices [68.65(d)(2)] or, for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, documented that it is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]?
At the time of the inspection, the electrical junction box for a pressure sensing switch on the glycol chiller was missing, exposing its wiring and posing a potential ignition hazard.
See, e.g., NFPA 70-2014, § 110.12(B).
Has refresher training been provided at least every three years, or more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process [68.71(b)]?
At the time of the inspection, Respondent’s refresher training documentation for one employee indicated that training had not been completed within the past three years.
Has the owner or operator corrected deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation [68.73(e)]?
At the time of the inspection, there was rusting on condenser supports, a section of overhead piping insulation was damaged, and one section of ammonia piping had damaged insulation at a support saddle that could lead to moisture entrapment and corrosion under insulation, each indicating that equipment deficiencies were not being corrected in a safe and timely manner.
See, e.g., IIAR Bull. 109, §§ 4.7.4 and 4.7.5; IIAR Bull. 110, §§6.4.3, 6.7.2.
NOTE: Bulletins 109 and 110 were in effect at the time of inspection and have since been withdrawn and replaced by ANSI/IIAR 6-2019.
CLICK HERE for the Process Checklist (Findings) and Alleged Violations and Proposed Penalty Form