In 2015 EPA released a new enforcement alert “Ammonia Refrigeration Facilities under Scrutiny by US EPA“. Several example in the document talked about these key inspection considerations and lessons from past incidents and violations. The following was the key points to the enforcement alert
- Lessons Learned from recent inspections of ammonia refrigeration systems:
- Identifying the hazards that a facility’s refrigeration systems present is crucial. Guidance on how to conduct a proper hazard analysis is available from the International Institute of Ammonia Refrigeration or in EPA’s General Duty Clause Guidance, found at http://www.epa.gov/osweroe1/docs/chem/ gdcregionalguidance.pdf. Part of this analysis should include understanding the gap between the safety requirements of new industry codes and standards and the standards to which the facility was built and developing a plan to address safety deficiencies. In some cases, that plan must include making facility upgrades.
- Preventive maintenance is the standard for the industry. The maintenance program, including inspections, should be documented. • Gathering sufficient information about the piping and equipment is crucial so that facilities understand the hazards associated with their refrigeration system and can develop a proper maintenance program.
- Refrigeration systems that are missing key controls, such as emergency shutoff valves, because they were not built to industry codes and standards in effect at the time of construction need to be upgraded.
- Halting corrosion of pipes and equipment should be a priority.
- Hammering and shaking of equipment and pipes risks breakage and ammonia releases.
- Defrosting is important. Ice buildup can impede access to important equipment and dangerously weigh down piping.
- Adequate ventilation in a safe location is required for machinery rooms.
- Ability to shut down the system without entering the machinery room is necessary.
- Ammonia pressure relief devices should not be located where they could spray ammonia onto people.
- A trained operator is critical to running an ammonia refrigeration system.
- A well-maintained closed loop system should limit accidents occurring during startup.
Earlier this year we started to see the results of the enforcement alert and posted few of then violations and CAFOs. To view these violations click here.
The most recent CAFOs for 2017 are below. It is worth you time to view these and look at the key point to them all. EPA is not just inspecting paperwork, they are verifying is program documented correctly, do the employees understand the program, and is the program being implemented at the ground level.
- Lack of Implemented Program & $270,000
- Failed to Submit RMP & $80,470
- Form R and Tier 2 & $19,810
- Prevention Program and Incorrect Filing
- Ammonia Detectors did not activate Visual/Audible Alarms
- 4 Phone Calls & $20,000
- Ammonia Leak and Improper Identification of Shut off Valves $36,000
- IIAR RAGAGEP Violations $56,000
- 9,995 Pound Charge & $184,717
