JANUARY 21, 2025 - EXPEDITED SETTLEMENT AGREEMENT
EPA alleges that the Respondent violated the Act's Section 112(r)(7) Chemical Accident Prevention Provisions, 42 U.S.C. ? 7412(r)(7), when at the time of inspection, Respondent did not provide evidence that: It documented that equipment complies with recognized and generally accepted good engineering practices as required by 40 C.F.R. ? 68.65(d)(2), because:
i. The emergency shutoff valve (King Valve) on top of the high-pressure receiver just outside of the engine room was not labeled. Valves listed as emergency shut off valves in the system emergency shutdown procedure shall be clearly and uniquely identified at the valves themselves and in the system schematic drawings, Some insulation on ammonia pipes associated with the outdoor equipment was torn or gaping at the seams, exposing the pipes underneath to moisture
iii. Corrosion, rust, and pitting were observed on piping and valve groups associated with the outdoor ammonia equipment.
iv. Excessive ice buildup was found on some of the pipes and valve groups associated with the outdoor ammonia equipment. Excessive ice buildup may interfere with turning valves and can add weight, compromising the structural integrity of the pipes. There was also ice underneath some of the insulation. Moisture trapped under insulation may accelerate corrosion of pipes.
EPA and the United States Department of Justice jointly determined that this matter, although it involves al