MAY 19, 2025 - CONSENT AGREEMENT
On August 10, 2023, EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent's compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its Facility.
(a) EPA inspection team observed that the pipes around the two 30,000-gallon ammonia tanks and the sulfur dioxide tank were not consistently labeled. Some pipes were labeled with direction of flow, but many lacked labels identifying their contents. The ammonia piping should be labeled/colored in accordance with the Pipe Marking Guide, American National Standard Institute/American Society of Mechanical Engineers (ANSI/ASME) Al3.1- 2007 Standard for the Identification of Pipes. The standard requires labels of a certain color, depending on the type of material in the pipes, and that the labels identify the contents and direction of flow of said contents.
(b) Facility representatives provided EPA inspection team with inspection reports for Ammonia Tanks AA-1 and AA-2. The reports were generated from external inspections and ultrasonic (UT) testing that were conducted on the two 30,000-gallon ammonia tanks on November 02, 2021, by a third-party company, Applied Technical Services. The results from the tests indicate the thickness is below the minimum allowable value on three components for each ammonia tank.
Multiple shell