Does RAGAGEP apply to General Duty Facilities?
At the time of the EPA inspection, approximately 14,600 pounds in total of ammonia were present at the facility. The facility has two separate refrigeration systems, each of which cycled approximately 7,300 pounds of ammonia through various physical states to cool the companies products. On February 15, 2018, EPA inspectors visited the facility to inspect and assess compliance with Section 112(r) of the CAA. The EPA inspectors toured the following areas of the facility: building perimeter and loading dock, refrigeration systems in the two ammonia machinery rooms, rooftop, and the “#2 Room.” Here is a link to the EPA CAFO.
- EPA’s inspection of the Facility and review of submitted information revealed some potentially dangerous or deficient conditions relating to the Facility at the time of the inspection in 2018, including the following:
- Inadequate emergency ventilation system in machinery room
- Inadequate visual/audible alarms
- Combustible materials in ammonia machinery rooms
- Inadequate signage and labeling on System
- Machinery room door and walls not sealed tight
- Lack of safety showers
- Improperly placed discharge relief
- Rusted valves and piping
- Missing/illegible ASME nameplates
For you that know IIAR 2 standard, all of this and more is covered in that RAGAGEP. GCAP has a two day class called Machinery Room Best Practices that covers all this information plus more.