2022 RETA Breeze March-April

EPA GENERAL DUTY CLAUSE INSPECTIONS 51 POUNDS OF VAPOR RELEASED

This small company uses NH3 to produce and store ice. The NH3 process runs continually, but employees are not in the plant outside of normal business hours. One evening in 2016, at 10:53 PM, the city fire department was notified about a strong ammonia smell near the facility. Following their protocols, the fire department donned their HAZMAT suits and entered the facility and shut down the compressor. Firefighters remained on the scene until 5:57 AM that morning. Following a root cause analysis, they found that a housing seal on their reciprocating

compressor had failed and allowed the release. They calculated a loss of 51 pounds of vapor over a period of 196 minutes. By failing to identify and replace the seal prior to failure and allowing the process to continue to run while it was releasing NH3, the company violated the requirement of CAA 113(r)(1) for owners and operators to design and maintain a safe facility, taking such steps as necessary to prevent releases. This release did not result in any exposure injuries nor require an evacuation of the area. Someone noticed an odor and call the fire department. The exact start time of the

release was not known, but they were able to estimate the 196-minute release duration. This company was cited and paid a penalty of $40,000, which is considerable for a small company and also in 2016. How could this event been prevented? What options could this company have to notify appropriate personnel if there is a release? Do they need to have someone on premises who is qualified to shut down the system at all times? What would you have done?

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