Respondent owns and operates a carbonated beverage bottling plant. At the facility, respondent produces, processes, handles, or stores substances listed in, or pursuant to, CAA 112(r)(3) or other extremely hazardous substances identified as such due to toxicity, reactivity, flammability, volatility. or corrosivity, including anhydrous ammonia. On March 29, 2015, there was a 3,750 pound release of anhydrous ammonia from the facility due to a closed compressor discharge valve and a failed high pressure compressor shutdown interlock.
On March 29, 2015 at 4:00 pm, the respondent discovered a leaking valve for the #7 ammonia compressor. When the leak was detected, the #7 ammonia compressor was isolated and taken out of service. Subsequent investigation determined that the cause of the leak was the closure of the discharge valve on the #7 ammonia compressor during maintenance. After maintenance had been completed the discharge valve was not reopened. The closed discharge valve on the #7 ammonia compressor resulted in a buildup of pressure above the 250 psi set point on the associated valve causing the valve to release ammonia. Investigation by the respondent also discovered that a high pressure limit switch which should have shut down the #7 ammonia compressor failed to operate. Respondent reported that 3,750 pounds of ammonia was released to the atmosphere during the on-going release which took place over the period of February 28, 2015 to March 29, 2015.
The original action of closing the discharge valve on the #7 ammonia compressor during maintenance and not following up to ensure that the discharge valve was re-opened, and failure to insure that the high pressure limit switch was operating, were either contrary to operating procedures at the facility, or were not addressed in operating procedures for the facility.
Respondent failed to design and maintain a safe facility and did not take such necessary steps to minimize the consequences of accidental releases by not fully utilizing commonly available and accepted practices to ensure safety, by failing to insure that a discharge valve was open after maintenance and by failing to insure the operation of a high pressure limit switch which would have shut down the compressor if the discharge valve was closed.
Respondent’s failure constitutes a violation of the general duty clause in section 112(r)(1).
CIVIL PENALTY
Respondent agrees that an appropriate penalty to settle this matter is $37,500. Complainant has also considered Respondent’s willingness to undertake an audit of safety practices at the facility in determining this penalty.
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