EPA RMP GDC @ cold storage and distribution facility (NH3 & $40K)

Using “bailing wire” to hold open your deadman valves on oil-pots is a really bad idea… leaving the bailing-wire (e.g. evidence) on the valve after each use is just stupid and shows an auditor/inspector that this is an accepted and continual practice! Another tell-tale indication of cheating a deadman valve is the indentions left in the rubberized coating on the handle.

As discussed below, the CAFO resolves the following CAA violations that Complainant alleges occurred in connection with Respondent’s storage and handling of anhydrous ammonia at its cold storage and distribution facility:

failure to design and maintain a safe facility, takin g such steps as are necessary to prevent such releases, in violation of the General Duty Clause, Section 112(r)(1) of the CAA, and
failure to minimize the consequences of accidental releases, should they occur, in violation of the General Duty Clause, Section 112(r)(1)

Respondent operates a cold storage and distribution facility. The Facility is located less than 1,000 feet from a residential neighborhood, a church, and a post office, and less than three-quarters of a mile from other residential neighborhoods, restaurants, and businesses. At the time of the violations alleged herein, the Facility had a refrigeration system, which cycled approximately 6,600 pounds of anhydrous ammonia through various physical states to cool Respondent’s products (the “System”). Accordingly, Respondent “stored” and “handled” anhydrous ammonia. As the operator of a stationary source that processes, handles or stores extremely hazardous substances, Respondent was, at all times relevant to the allegations herein, subject to the General Duty Clause found in Section 112(r)(1) of the CAA. Due to the dangers associated with anhydrous ammonia, the ammonia refrigeration industry has developed industry standards to control the risks associated with the use of ammonia. In collaboration with the American National Standards Institute (“ANSI”), the International Institute of Ammonia Refrigeration (“IIAR”) has issued (and updates)…

Standard 2: American National Standard for Safe Design of Closed-Circuit Ammonia Mechanical Refrigeration Systems (“ANSI/IIAR 2”),
Standard 4: Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems (“ANSI/IIAR 4”), and
Standard 7: Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems (“ANSI/ IIAR 7”), inter alia, along with other applicable standards and guidance. Bulletins and guidance include, without limitation,
- IIAR Bulletin No. 109, Guidelines for IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System ( 1997) (“IIAR Bull. 109”);
- IIAR Bulletin No. 110, Guidelines/ or Start-Up, Inspection, and Maintenance of Ammonia Mechanical Refrigerating Systems (1993, most recently updated in 2007) (“IIAR Bull. 110”);
- IIAR Bulletin No. 114, Guidelines for Identification a/Ammonia Refrigeration Piping and Components (1991, most recently updated in 2018) (“IIAR Bull. 114”);
- IIAR Bulletin No. 116, Guidelines for Avoiding Component Failure in Industrial Refrigeration Systems Caused by Abnormal Pressure or Shock (1992) (“IIAR Bull. 116”); and
the Ammonia Refrigeration Management Program (2005, most recently updated in 2019) (“IIAR ARM Program”), which is intended to provide streamlined guidance to facilities like Respondent’s that have less than 10,000 pounds of ammonia.

Also in collaboration with ANSI, the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (“ASHRAE”) has issued (and updates) Standard 15: Safety Standard/or Refrigeration Systems (“ANSI/AS HRAE 15”). These standards are consistently relied upon by refrigeration experts and are sometimes incorporated by reference into state building and mechanical codes, including Connecticut’s codes.

On August 9, 2017, EPA visited the Facility to determine whether Respondent was complying with Section 112(r) of the CAA and Section 312 of EPCRA. The EPA inspectors toured the Facility’s perimeter, ammonia machinery room (“AMR”), roof, refrigerated loading dock, and medium-temperature rooms and freezers. During the Inspection, the EPA inspector observed several potentially dangerous conditions relating to the System, including the following:

Problems with the AMR door. The exit door in the AMR did not have panic hardware installed to allow for quick egress in the event of an emergency. In addition, the AMR door was not tight-fitting at the bottom and would not prevent ammonia from escaping should a release occur;
Failure to It ave a legible, permanent sign securely attached and easily accessible in any location on the ammonia refrigeration system displaying the following information:
1. name and address of the installer;
2. the refrigerant number and the amount of refrigerant in the system;
3. the lubricant identity and amount; and iv) the field test pressure(s) applied. This type of sign provides critical information to those maintaining the System (thereby helping to prevent releases) and to those responding to an emergency (thereby minimizing the consequences of releases that do occur);
Fire Hazards in the AMR. For example, a propane torch, gasoline, oil drums, and an organic peroxide solution were being stored in the AMR. In addition, EPA Inspectors observed exposed electrical wiring and an open electrical box in the AMR, and the water treatment system in the room was powered by linked electrical extension cords rather than a fixed electrical receptacle;
King valve 1101 accessible. The main shut-off valve (“king valve”) for the high-pressure receiver was not accessible from the floor level, nor was it accessible via a chain or permanent work surface, and there was no hand-wheel on the valve stem for easy operation in the event of an emergency.
Unlabeled piping and equipment. Several sections of ammonia piping in the AMR, on the roof, and in the loading dock areas either had worn, difficult-to-read labels or lacked labels indicating the contents and direction of flow. In addition, the high-pressure receiver was not labeled with a National Fire Protection Association (“NFPA”) diamond signifying the presence and hazards of ammonia. The failure to label ammonia-containing piping and equipment makes it more difficult to properly maintain the System, operate correct valves, warn workers and emergency responders about hazards posed by System, reduce the risk of human error in operating the System, and respond quickly in the event of a release.
Deadman valves on oil pots were compromised. Wire wrapped around the self-closing “deadman” valves on oil pots in the AMR indicated that service technicians were using the wire to hold the valves in an open position during oil removal, overriding the valves’ protective function in the event of an emergency.
Corroded piping and equipment. Signs of corrosion were observed on the low-pressure accumulator and piping and valves on the roof, including the purge valve assembly.
Missing/compromised insulation and vapor barriers on piping and equipment. Compromised insulation was observed on the low-pressure accumulator, various sect ions of piping on the roof, and the evaporator in the freezer. In addition, EPA Inspectors observed areas of ammonia piping and equipment frosted over with ice in the AMR, indicating a breach in the vapor barrier/insulation.
Piping and equipment not adequately protected. Piping and valves extend ing from near the base of the high-pressure receiver were not adequately protected from accidental damage or rupture by external forces.
Inadequate ventilation. The emergency exhaust fan in the AMR was undersized to properly ventilate the space. In addition, the air intake point was installed in the ceiling (as was the exhaust fan), potentially lead ing to short-circuit ing of the make-up air directly to the exhaust, rather than a location that would bring incoming fresh air down to ground level.
Small ammonia leak. EPA Inspectors discovered a small ammonia leak in a valve assembly pipe fitting on the roof.
Failure to adequately support ammonia piping. EPA Inspectors observed two spots where piping supports were either missing or improperly placed, causing ammonia piping to sag.
The pressure relief vent header does not discharge upward. The pressure relief vent header discharges in a downward direct ion toward the evaporative condenser. This orientation could result in ammonia being sprayed onto people work ing on the roof, and/or ammonia absorbing into coo ling water in the condenser, which is recycled to an open tank inside the machinery room.

On January 26, 2018, EPA issued a Notice of Potential Violation and inspection report to Respondent, providing notice of potential General Duty Clause violations.
32. Respondent was responsive to the letter and began taking steps to address deficiencies at the Facility. According to Respondent, Respondent has completed the following actions:

Installed a new exhaust fan to supplement the existing ventilation system ;
Damaged insulation was repaired and re labeled;
A chain was added to the king valve on the high-pressure receiver that allows an operator to close the valve from ground level;
A wire holding open a self-closing “deadman” valves on an oil pot was removed, and Respondent has started doing spot checks to ensure this practice does not continue;
Duct work was installed on the air intake to allow adequate circulation of fresh air in the event the ventilation system is activated;
Supports were added to support sagging ammonia pipes, and electrical conduit suspended from ammonia piping was repositioned;
Corroded piping was rep laced, treated with moisture-proof grease, and reinsulated;
Respondent hosted its service contractors and the local fire chief for a tour of the Facility and review of its emergency response plan;
Panic hardware and a door sweep were installed on the AMR door;
A sign identifying the installer of the System and the type and amount of refrigerant was installed at the Facility;
Flammable chemicals were removed from the AMR, and a flammable storage cabinet placed outside of the AMR was purchased to store these materials;
Labeling was added to piping and equipment;
A refrigeration contractor evaluated corrosion on the low-temperature intercooler, cleaned the equipment, applied a moisture-resistant grease, and repaired the breached insulation on it;
Guarding was installed to protect piping near the base of the high-pressure receiver from accidental rupture;
Waste oil and unused chemicals were shipped off-site;
Abandoned electrical conduit and exposed electrical wiring were removed, and open electrical junction boxes were covered;
The ammonia leak discovered on the roof during the Inspection was repaired the same day; and
The pressure relief vent header has been repaired so that discharge sprays upward rather than downward.

As a result of EPA’s inspections and review of information provided by Respondent, EPA alleges the following violations:

COUNT I: FAILURE TO DESIGN AND MAINTAIN A SAFE FACILITY IN VIOLATION OF THE CAA’S GENERAL DUTY CLAUSE

Pursuant to the General Duty Clause, Sect ion 112(r)(1) of the CAA, owners and operators of stationary sources producing, processing, handling, or storing extremely hazardous substances have a general duty, in the same manner, and to the same extent as Section 654 of Title 29, to, among other things, design and maintain a safe facility, taking such steps as are necessary to prevent releases.

Respondent operates a stationary source that handled and stored anhydrous ammonia, an extremely hazardous substance. Accordingly, at the time of the violations alleged herein, Respondent was subject to the General Duty Clause.

The recommended industry practice and standard of care for designing and maintaining a safe facility with an ammonia refrigeration system of the same size and type as Respondent’ s System is to base design considerations upon applicable design codes, federal and state regulations, and industry guidelines to prevent releases or minimize their impacts as well as to develop and implement standard opera ting procedures, maintenance program s, personnel training programs, management of change practices, incident investigation procedures, self-audits, and preventative maintenance programs. IIAR, ASHRAE, and others have developed standards and guidelines for this purpose, such as the IIAR Bulletins, ANSI/HAR Standard 2, the IIAR ARM Program, and ANSI/ASHRAE Standard 15. See also EPA’s GDC Guidance, Section 2.3.2, and NFPA 1: Fire Code, Section 53.

i) name and address of the installer;
ii) the refrigerant number and the amount of refrigerant in the system;
iii) the lubricant identity and amount; and
iv) the field test pressure(s) applied.

See, e.g., IIAR Bull. 109, Section 4.10.4 and Section 7, General Safety Inspection Checklist item (i); ANSI/IIAR 2-20 14, Section 5.15 (among other emergency shutdown schematic drawings or signage, must have information on quantity of ammonia in system, type and quantity of refrigerant oil in the system, and field test pressures applied).

There were several fire hazards in the AMR. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to refrain from storing combustible materials and address electrical hazards in the AMR. See, e.g., ANSI/IIAR 2-2014 , Section 6.4 (combustible mate rials shall not be stored in machinery rooms outside of approved fire-rat ed storage containers) ; NFPA 1 (2012 ed.), Sections 53.3 .1.3.1 (flammable and combustible materials shall not be stored in the refrigeration machinery rooms except for incidental materials necessary for the safe and proper operation and maintenance of the system.), 53.2 .3.4 and I I.I (electrical equipment and electrical installations in refrigeration machinery room shall comply with Sect ion 11.1 ); IIAR Bull. 109, Section 7, General Safety Inspection Check list item (x) (covers should be fasten ed to all electrical panels and junction boxes.).

Respondent failed to adequately label all ammonia piping and equipment. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to identify all refrigeration machinery with labels and provide key equipment- specific information on nameplates, and to label all piping with the identity, physical state, and relative pressure of the con tents, as well as direct ion of flow. See, e.g., ANSI/IIAR 2-20 14, Sections 5. I 4.2 (refrigeration machinery shall be labeled), 5.14.4 (requiring nameplates on all equipment that includes certain information regarding the manufacturer, design limits, and purpose, as specified by type of equipment in Chapters 8 through 16 of the Standard), and 5.14.5 (pip ing shall be labeled with the identity, physical state, and relative pressure of the contents, along with the pipe service and direction of flow); IIAR Bull. 109, Sect ion 4.7.6 (All ammonia piping should have appropriate pipe markers attached to indicate the use of the pipe and arrows to indicate the direct ion of flow, such as in IIAR Bull. 114 … ); IIAR Bull. 114, Sections 4.1 (Piping Markers: Piping markers shall be designed to identify the refrigerant, the physical state of the refrigerant, the relative pressure level of the refrigerant and the direction of flow) and 4.2 (Component Markers: Component marker s will bear the name of the equipment they identify, e.g., RECEIVER , ACCUMULATOR, RECIRCULATOR and provide a pressure level designation.); IIAR ARM Program, Section 4.2 (Recommends labeling in accordance with Bulletin 114 as part of the facility’s Standard Operating Procedure program); and ASME 13. 1-2007 (specifying conventions for labeling piping).

Wire had been wrapped around the self-closing “deadman” valves on oil pots in the AMR, thereby overriding the valves’ protective function in the event of an emergency. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to have a shut-off valve in series with a working self-closing valve at all oil removal points in the System. See, e.g., ANSI/IIAR 2-2014, Section 5.9.3 (at minimum, a shut-off valve in series with a self-closing valve is required); IIAR Bull. 109, Section 7, General Safety Inspection Checklist item (g).

Several pieces of equipment and sections of piping were corroded. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to implement a preventive maintenance program, under which piping and equipment are regularly evaluated for signs of corrosion, and corroded piping and equipment is c leaned down to bare metal and painted to prevent future corrosion. See, e.g., IIAR Bull. 109, Sections 4.2.4, 4.3.5, 4.4.5 (calling for regular inspection of condensers, heat exchangers, pressure vessels, and evaporators for signs of corrosion), 4. 7.4 (Uninsulated refrigerant piping should be exa mined for signs of corrosion. If corrosion exists, the pipe should be cleaned down to bare meta l and painted with a rust prevention paint. Badly corroded pipe should be replaced.) , and inspection checklists (calling for regular evaluation of piping, valves, and equipment for signs of corrosion); NFPA 1 (20 12 ed.), Section 53.3.1.1 (Refrigeration systems shall be operated and maintained in a safe and operable condition, free from accumulations of oil, dirt, waste, excessive corrosion, other debris or leak s.); and IMC 2012, Sect ion 1101. 7 (Mechanical refrigeration systems shall be maintained in proper ope rating condition, free from accumulations of oil, dirt, waste, excessive corrosion, other debris and leaks.).

There were several sections of compromised and/or missing insulation on ammonia piping and equipment. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to regularly inspect the condition of insulation and vapor barrier and to remove and replace any sections that are in poor condition. See, e.g., IIAR Bull. 110, Sect ions 6.7.2 (Any mechanical damage to insulation on piping should be repaired immediately and the vapor seal reinstated to prevent access of water or water vapor which will lead to the breakdown of insulation and corrosion of the pipework. At least as part of the annual piping inspect ion, but preferably more frequently, the external condition of the insulation and supports shall be inspected. Condensation and frosting on the surface of insulated finishes indicate a deterioration or breakdown of the insulation or vapor barrier. Sections of insulation which are obviously in poor condition shall be removed and the integrity of the exposed piping determined with the aid of non-destructive testing techniques, as appropriate. Piping shall be replaced as necessary, and protective coatings, insulation, and vapor seal reapplied. ), 6.4.2.1 (insulation applied to pressure vessels and head exchangers should be regularly checked ed by operators for deterioration, and any deterioration found should be recorded and repairs arranged), 6.4.3.1 (Where a section of insulation is materially damaged, it should be repaired or replaced. Underlying areas affected by surface corrosion should be cleaned off, inspected, and appropriately treated before reinstatement of the protective finish, insulation, and vapor barrier.); ANSI/IIAR 2-2014 , Section 5.10.1 (piping and equipment surfaces not intended for heat exchange shall be insulated, treated, or otherwise protected to mitigate condensation and excessive frost buildup); ANSI/IIAR 4-2015 , Section 12.1 (Refrigeration piping or components, whose surface temperature is expected to be at or below the dew point tempera ture at any time, shall be insulated and conditioned to prevent or mitigate condensation.).

Ammonia piping and equipment was not adequately protected from potential damage by external sources of physical impact. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to install guarding or barricading to prevent ammonia piping and equipment from being subject to physical impact. See, e.g., ANSI/IIAR 2-2014, Section s 5.17.1 (Guarding or barricading shall be provided for ammonia-containing equipment installed in a location subject to physical damage.), 7.2.4 (Equipment shall be protected where a risk of physical damage exists. Where equipment containing ammonia is located 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.), and 13.4.2 (Refrigerant piping shall be isolated and supported to prevent damage from vibration, stress, corrosion, and physical impact.); IIAR Bull. 109, Sect ion 4.7.3 (ammonia piping should be inspected throughout a facility to determine that no refrigerant piping is exposed to possible physical damage through traffic hazards, for example, forklifts) and Section 7 Evaporators Inspection Check list item (g) (adequate protect ion against traffic hazards?), item (b) (piping); IIAR ARM Program , Appendix I 0.1 , item 8.10 (” Is all piping protected from traffic hazards such as fork lifts?”).

The ventilation system in the AMR was not adequate in size or installation to properly ventilate the space. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is for emergency ventilation systems to provide not less than 30 air changes per hour based on the gross machinery room volume, and make-up air supply locations should be positioned to prevent short-circuiting of the make-up air directly to the exhaust. See, e.g., ANSI/ IIAR 2-20 14, Sections 6. 14.5.2 (requiring proper positioning or air intakes to avoid short-circuiting make-up air to the exhaust) and 6. 14.7 .1 (emergency ventilation systems shall provide not less than 30 air changes per hour); IIAR Bull. 109, Section 7 Ventilation Inspection Checklist item (b) (actual emergency ventilation exhaust or greater than or equal to the minimum required?) and item (k) (intake louvers and exhaust fans are positioned to promote mixing and to avoid short-circuiting of machinery room air?).

Ammonia piping was not adequately supported and was sagging in multiple locations. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to provide sufficient support for piping to prevent damage from stress or movement. See, e.g., ANSI/IIAR 2-2014 , Sections 5.11.5 (supports and foundations shall be designed to prevent excessive vibration or movement of piping, tubing, and equipment), 13.4.1 (piping hangers and supports shall carry the weight of the piping and any additional expected loads), and 13.4.2 (piping shall be isolated and supported to prevent damage from vibration, stress, corrosion, and physical impact); IIAR Bull. 109, Section 7 Piping Inspection Checklist item (a) (piping system adequately supported and anchored?).

The termination of the discharge from the pressure relief vent header was not directed upward, and any discharge absorbed into the nearby condenser was not via a proper water diffusion system. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to direct discharge from pressure relief devices upward to avoid spraying people, or into the bottom of a water diffusion tank that has been appropriately sized to handle the amount of ammonia that might be released from the pressure relief devices. See, e.g., ANSI/IIAR 2-20 14, Sections 15.5.1 (pressure relief devices shall discharge vapor directly to the atmosphere outdoors, except discharge through a water diffusion system in accordance with Section 15.5.3, among other methods, is permitted where approved by the authority having jurisdiction) , 15.5.1.5 (the termination of atmospheric discharges from pressure relief devices shall be directed upward and arranged to avoid spraying ammonia on persons in the vicinity), 15.5.3 (where pressure relief devices discharge to a water tank, the discharge pipe shall distribute the ammonia to the bottom of the tank, the tank shall be sized to contain 1 gallon of water for each pound of ammonia that would be released in 1 hour from the largest device connected to the discharge pipe and large enough to contain both water and ammonia without overflowing, and the effect of back pressure shall be considered in the relief vent piping design).

Accordingly, by failing to install a permanent sign showing key information about the System at the Facility, remove fire hazards in the AMR, adequately label all ammonia piping and equipment, ensure the self-closing “deadman ” valves on oil pots in the AMR were capable of working as designed, address corrosion and compromised and/or missing insulation on several pieces on ammonia piping and equipment, adequately protect ammonia piping and equipment from potential damage by external sources of physical impact , provide adequate ventilation in the AMR, promptly correct a small ammonia leak on the roof, provide adequate supports for ammonia piping , and ensure a safe point and means of discharge from the pressure relief vent header, Respondent failed to design and maintain a safe facility, in violation of the General Duty Clause, Section 112(r)(1) of the CAA,.

COUNT II: FAILURE TO MINIMIZE THE CONSEQUENCES OF ACCIDENTAL RELEASES THAT MIGHT OCCUR IN VIOLATION OF THE CAA’S GENERAL DUTY CLAUSE

Pursuant to the General Duty Clause, Section 112(r)(1) of the CAA, owners and operators of stationary sources producing, processing, handling, or storing extremely hazardous substances (including anhydrous ammonia ) have a general duty, in the same manner, and to the same extent as Section 654 of Title 29, to, among other things, minimize the consequences of any accidental releases that do occur.

The exit door in the AMR did not have panic hardware, nor was it tight-fitting at the bottom. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to install panic hardware onto AMR exit doors and ensure that the AMR is provided with tight-fitting, self-closing doors. See,
e.g., ANSI/IIAR 2-2014, Section 6.10.2 (Machinery doors shall be self-closing and tight fitting. 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.); IIAR ARM Program, Appendix 10, item 11.14 at AI 0-42 (Asks whether machinery room doors are tight-fitting, open outward, and are fitted with panic-type hardware).

Respondent failed to install a permanent sign showing key information about the System at the Facility. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to install a legible, permanent sign displaying the follow ing information: i) name and address of the installer; ii) the refrigerant number and the amount of refrigerant in the system; iii) the lubricant identity and amount; and iv) the field test pressure(s) applied. See, e.g., IIAR Bull. 109, Section 4. 10.4 and Section 7 Gen); ANSI/IIAR 2-2014, Section 5.15 (among other emergency shutdown schematic drawings or signage, must have information on the quantity of ammonia in system, type and quantity of refrigerant oil in the system, and field test pressures applied).

There were many fire hazards in the AMR. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to refrain from storing combustible materials and to address electrical hazards in the AMR. See, e.g., ANSI/IIAR 2-2014 , Section 6.4 (combustible materials shall not be stored in machinery rooms outside of approved fire-rated storage containers); NFPA 1 (20 12 ed.), Sections 53.3.1.3.1 (flammable and combustible materials shall not be stored in the refrigeration machinery rooms except for incidental material s necessary for the safe and proper operation and maintenance of the system.), 53.2.3.4 and 1.1 (electrical equipment and electrical installations in refrigeration machinery room shall comply with Section I); IIAR Bull. 109, Section 7 General Safety Inspection Checklist item (x) (covers should be fastened to all electrical panels and junction boxes.).

Respondent failed to ensure that the high-pressure receiver king valve was accessible for easy use in the event of an emergency shutdown. The recommended industry practice and standard of care for ammonia refrigeration systems of this size are to ensure that main shut-off valves are directly operable from the floor level or chain operated. See, e.g., ANSI/IIAR 2-20 14, Sections 6.3.3 .1 (manually operated valves inaccessible from floor level shall be operable from portable platform s, ladders, or shall be chain operated) and 6.3 .3.2 (manually operated isolation valves that are part of system emergency shutdown procedure shall be directly operable from floor or chain operated from a permanent work surface); IIAR Bull. 109, Section 4.10.3 (main shut-off valve(s) should be readily accessible) and Section 7, General Safety Inspection Checklist item (e); IIAR ARM Program, Appendix 10.1, items 7.6 (accessibility of main valves), 11.5 (availability of platforms, ladders or chain s for inaccessible valves).

Respondent failed to adequately label all ammonia piping and equipment. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to identify all refrigeration machinery with labels and pro vide key equipment-specific information on nameplate s, and to label all piping with the identity, physical state, and relative pressure of the contents, as well as direction of flow. See, e.g., ANSI/ HAR 2-2 014 , Section s 5.14.2 (refrigeration machinery shall be labeled), 5.14.4 (requiring nameplates on all equipment that includes certain information regarding the manufacturer , design limits, and purpose, as specified by type of equipment in Chapters 8 through 16 of the Standard), and 5. 14.5 (pip ing shall be labeled with the identity, physical state, and relative pressure of the contents, along with the pipe service and direction of flow) ; IIAR Bull. 109, Section 4.7.6 (All ammonia piping should have appropriate pipe markers attached to indicate the use of the pipe and arrows to indicate the direction of flow, such as in IIAR Bull. 114 … ); IIAR Bull. 114, Sections 4.1 (Piping Markers: Piping markers shall be designed to identify the refrigerant, the physical state of the refrigerant, the relative pressure level of the refrigerant and the direction of flow) and 4.2 (Component Markers: Component markers will bear the name of the equipment they identify, e.g., RECEIVER , ACCUMULATOR, RECIRCULATOR and provide a pressure level designation.); IIAR ARM Program , Section 4.2 (Recommends labeling in accordance with Bulletin 114 as part of the facility’s Stan dard Operating Procedure program) ; and ASME 13. 1-2007 (specify ing conventions for labeling piping).

Wire had been wrapped around the self-closing “deadman ” valves on oil pots in the AMR, thereby overriding the valves’ protective function in the event of an emergency. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to have a shut-off valve in series with a working self-closing valve at all oil removal points in the System. See, e.g., ANSI/ IIAR 2-2014, Section 5.9.3 (at minimum, a shut-off valve in series with a self-closing valve is required); UAR Bull. 109, Section 7 General Safety Inspection Checklist item (g).

The ventilation system in the AMR was not adequate in size or installation to properly ventilate the space. The recommend ed industry practice and standard of care for ammonia refrigeration systems of this size is for emergency ventilation systems to provide not less than 30 air changes per hour based on the gross machinery room value, and make-up air supply locations should be positioned to prevent short-circuiting of the make-up air directly to the exhaust. See, e.g., ANSI/IIAR 2-2014, Sections 6. 14.5.2 (requiring proper positioning or air intakes to avoid short-circuiting make-up air to the exhaust) and 6.14.7. 1 (emergency ventilation systems shall provide not less than 30 air changes per hour); IIAR Bull. 109, Section 7 Ventilation Inspection Checklist item (b) (actual emergency ventilation exhaust or greater than or equal to the minimum required?) and item (k) (intake louvers and exhaust fans are positioned to promote mixing and to avoid short-circuiting of machinery room air?).

EPA Inspectors discovered a small ammonia leak in a valve assembly pipe fitting on the roof. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to immediately investigate and repair any ammonia leaks discovered. See, e.g., IIAR Bull. 109, Section 4.10.8 (If an ammonia leak is observed, the source of the leak should be investigated and the leak repaired.); IMC 2012, Section 110 1.7 (Mechanical refrigeration systems shall be maintained in proper opera ting condition, free from accumulations of oil, dirt, waste, excessive corrosion, other debris, and leaks.); NFP A I (20 12 ed.), Section 53.3.1.1 (Refrigeration systems shall be operated and maintained in a safe and operable condition, free from accumulations of oil, dirt, waste, excessive corrosion, other debris or leaks.). 60. As described in paragraph 30.m and in Count I (paragraph 48) above, the termination of the discharge from the pressure relief vent header was not directed upward, and any discharge absorbed into the nearby condenser was not via a proper water diffusion system. The recommended industry practice and standard of care for ammonia refrigeration systems of this size is to direct discharge from pressure relief devices upward to avoid spraying people, or into the bottom of a water diffusion tank that has been appropriately sized to handle the amount of ammonia that might be released from the pressure relief devices. See, e.g., ANSI/IIAR 2-2014, Sections 15.5.1 (pressure relief devices shall discharge vapor directly to the atmosphere outdoors, except discharge through a water diffusion system in accordance with Section 15.5.3, among other methods, is permitted where approved by the authority having jurisdiction), 15.5.1.5 (the termination of atmospheric discharges from pressure relief devices shall be directed upward and arranged to avoid spraying ammonia on persons in the vicinity), 15.5.3 (where pressure relief devices discharge to a water tank, the discharge pipe shall distribute the ammonia to the bottom of the tank, the tank shall be sized to contain 1 gallon of water for each pound of ammonia that would be released in I hour from the largest device connected to the discharge pipe and large enough to contain both water and ammonia without over flowing, and the effect of back pressure shall be considered in the relief vent piping design).

Respondent certifies that it has corrected the violations alleged in this CAFO and, upon completion of the process hazard review update, will continue to operate the Facility in compliance with Section 112(r) of the CAA.

Taking into account the relevant statutory penalty criteria, the applicable penalty policy, the facts alleged in this CAFO, Respondent ‘s cooperation in agree ing to perform the non-penalty obligations in this CAFO, and such other circumstances as justice may require , EPA has determined that it is fair and proper to assess a civil penalty of forty thousand six hundred dollars ($40,600) for the violations alleged in this matter.

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