As part of a new focus on operations with at least 10,000 pounds of ammonia on hand, the U.S. Environmental Protection Agency inspected Penobscot McCrum's potato processing plant last year and recently issued a complaint alleging the company is unprepared for an emergency involving an ammonia leak.

An EPA enforcement alert issued in February states that recent ammonia-related Clean Air Act violations at nine refrigeration facilities nationwide have resulted in property damage, injuries, hospitalizations and several deaths and reminded the industry that companies must take responsibility to prevent accidental releases of ammonia.

Ammonia presents a significant health hazard, the alert states, because it is corrosive to the skin, eyes and lungs; exposure to 300 parts per million is "immediately dangerous to life and health"; it is flammable at concentrations of 15-28 percent by volume in air; and it can explode if released in an enclosed space with an ignition source present or if a vessel containing ammonia is exposed to fire.

According to City Planner Wayne Marshall, in response to the EPA alert, and because Waldo County Emergency Management Agency Director Dale Rowley identified Penobscot McCrum's ammonia operation as one of the larger public safety risks in the county, the city of Belfast has begun coordinating site visits to local facilities that use large quantities of ammonia, and plans to conduct field drills simulating a response to an ammonia release.

"Ammonia is currently the greatest toxic chemical airborne hazard in Waldo County," Rowley wrote in an email to City Manager Joe Slocum and Fire Chief Jim Richards.

Marshall said that in the "extremely unlikely" event of a catastrophic emergency at the Penobscot McCrum facility, "the catchment area is quite large, between 1.3 and 1.6 miles for a release into the atmosphere. That would be a release of somewhere in the range of 7,500 to 8,500 pounds of ammonia."

On Sept. 24, representatives of the city; local, county and state emergency agencies and responders; and the Department of Environmental Protection met with Penobscot McCrum staff for a tour of the Pierce Street facility to learn about the facility's ammonia refrigeration process and each others' roles in the event of an emergency.

Slocum, Marshall, Code Enforcement Officer Todd Rosenberg, Belfast Police Chief Michael McFadden, Fire Chief Jim Richards, fire department representatives Bob Richards and Keith Pooler, Waldo County Emergency Management Agency Director Dale Rowley, State Emergency Management Agency Technical Hazards Coordinator Robert Gardiner and Department of Environmental Protection Agency representatives Jon Selleck and John Woodward met with Penobscot McCrum staff, including CEO Jay McCrum, new Compliance Manager Dillon Cyr, Refrigeration Operator Ron Clark and Safety Specialist Wanda Rowe.

Penobscot McCrum staff gave the group a tour of the refrigeration process area, pointing out improvements that have been made at the facility, and the location of the “king valve,” which shuts off the whole system.

“Everyone should know where that is, in case someone has to go through an ammonia cloud in a white suit in low visibility,” Marshall said.

Penobscot McCrum will be submitting an updated emergency response plan to the county emergency management agency Oct. 15, and will present the plan at a meeting of the Local Emergency Planning Committee that day. The company has already submitted a draft to the city for review and comment. Marshall said the city is looking for specific things like the names and numbers of people who should be contacted in case of an emergency, and who is calling whom.

“We want it to be as good a tool as possible for how to do a response, not a pro-forma cookie-cutter plan.” Marshall said.

He said Penobscot McCrum has been putting in a concerted effort in the past eight months to address concerns that were raised from the October 2014 EPA inspection of the facility, and there was nothing about the operation that anyone thought was a major problem. Marshall said that from both code enforcement and public safety perspectives, the facility looked to be in good shape.

EPA's allegations

However, the Sept. 30 EPA administrative complaint against Penobscot McCrum, based on last year's site inspection, lists numerous allegations ranging from “minor” to “major,” including under-representing the worst-case release quantity of ammonia from the facility as 7,800 pounds rather than 14,500 pounds and characterizing the area around the facility as urban rather than rural (urban areas have obstructions that would block the spread of airborne ammonia in the event of a spill), thereby underestimating the extent of the area that would be affected by an ammonia release.

It alleges the company's required Process Hazard Analysis failed to establish appropriate emergency responses to ammonia leaks because it stated that the facility staff would not respond to a leak if it meant entering an ammonia atmosphere; nor would the local fire department, and it did not have mechanisms in place to notify emergency responders or the public. In addition, the complaint alleges the company's “Extremely Hazardous Material Facility Plan” did not identify evacuation routes.

The complaint states, “The emergency response plan was not suitable for the facility because the geographic region lacks a hazardous material response team and a release of ammonia could have substantial adverse impacts on the general public and the environment before a hazardous material response team could arrive from another region.”

In addition to emergency preparedness issues, the complaint lists problems with the physical plant.

The refrigeration system machinery room is alleged to be in poor condition, with broken wall sections and a door that was not self-closing and lacked a tight-fitting seal.

“Broken walls in a machinery room are inconsistent with the industry standards for machinery room structural integrity,” the complaint states.

The complaint notes inspectors found numerous instances of exposed wiring in the ammonia machinery room, pipe hangers supporting ammonia piping secured to other parts of ammonia piping, insulation and lagging in poor condition, and compressor bypass relief valves in use past their five-year replacement dates. Pressure and condenser relief devices were allegedly not the proper distance from the building's roof, windows and vents. The standard distance from those points is established “to prevent recirculation of contaminated air and to protect people from being sprayed with ammonia,” according to the complaint.

The complaint also alleges ammonia areas were not properly identified, labeling and tagging of components of the ammonia refrigeration process was sporadic and missing in some areas, the equipment's compliance with safety standards was not properly documented, and some required documentation was missing for high pressure vessels.

Employee training was alleged to be lacking or not documented, and EPA alleged that not all contractors who perform work on or adjacent to the refrigeration process were identified as required.

“Normal day-to-day maintenance and inspection was substantially lacking,” the complaint states. It also alleges standard operating procedures were not being re-certified on an annual basis.

The complaint states it will be proposing a monetary penalty for the alleged violations.

Penobscot McCrum's response

Penobscot McCrum CEO Jay McCrum said in a meeting with The Republican Journal Oct. 5 that the company has been working on a response since December 2014, when it received the report from the EPA's inspection. That inspection, he said, spurred an effort by the company to improve communication with the city and the state to address things the company had “slighted” in the past.

The company created a new compliance specialist position and hired Dillon Cyr about a month ago to fill that role. Cyr is working on developing relationships with the appropriate people who would be instrumental in an emergency.

"We have a great partnership with our local hospital, we're moving forward with police and fire, we have Clean Harbors [a Waterville hazardous materials and emergency response company] on board, and they've been classified to deal with any exterior ammonia spills,” he said.

The company has installed protective barriers around the ammonia tanks and posted required signs.

McCrum said some of the things in the complaint have merit and others do not. He disagrees with allegations about the integrity of their piping system, and said the integrity of the system is tested with a method that sonically measures the piping membrane. However, the company did not provide EPA with documentation of the tests.

“An awful lot of the allegations — I'm sorry to say — weren't about actions or lack of action but a lack of documenting,” McCrum said. “We have invested hundreds of thousands of dollars into our process safety management program, which has a documentation component, but as a company we didn't keep up with it."

“The important thing is you need to show your work," Cyr said. "If you do your homework, you have to pass it in.

"When implemented correctly, the PSM program is a great tool to give us a look at our preventative maintenance program and show all the proof and work we get done on a day-to-day basis," he said. "For example, if we have a new hire they can go on a particular piece of equipment that's been documented and it shows its services records, shows the track record, and work history.

"A lot of questions came down to cosmetics," Cyr said, pointing out a portion of the building where a new outer wall had recently been built. "The building is cosmetically old but structurally sound."

McCrum said, "We feel very strongly we have got everything in place, there's been a breakdown in communication and so forth, and we really feel besides benefiting our company and the community, it's going to benefit everybody as a whole because there are other companies that are maybe under the radar."

Other Belfast operations that the city and emergency responders plan to visit include the refrigeration system at McCrum's Front Street location, the freezer plant at the former Coastal Farms building on Northport Avenue, and the Curling Club on Belmont Avenue.