Inside EPA’s Safety Case Against Citrosuco’s 111,000-Pound Ammonia System

The emergency controls were not where workers would expect them

On the roof, EPA said a pressure-relief pipe was angled to discharge ammonia downward rather than upward. Inside the plant, an emergency shutoff for one machinery room was roughly the length of a football field from the room it controlled. At the front of the property, the primary vehicle exit gate was locked.

Those were three of 27 observations listed in the settlement after EPA inspected Citrosuco North America’s Lake Wales facility on March 7, 2024. The facility operates an ammonia refrigeration plant serving citrus processing operations.

The quantity matters. Citrosuco had 111,000 pounds of anhydrous ammonia on site at the times relevant to EPA’s allegations. Its covered process had a regulatory threshold of 10,000 pounds. That placed the system under the Clean Air Act’s Risk Management Program, which is intended to prevent accidental releases of regulated substances and limit the consequences when releases occur.

This was not one isolated paperwork failure

EPA evaluated whether Citrosuco could document that its ammonia process followed recognized and generally accepted good engineering practices, often shortened to RAGAGEP. In plain language, that means the company needed to show that critical equipment was designed, operated, inspected and maintained according to accepted safety standards.

The observations stretched across the physical plant, emergency systems and compliance records.

The corrosion record shows how warnings can remain unresolved

Among the most consequential observations was localized corrosion and pitting on ammonia piping, valves and refrigeration equipment across several areas of the facility. The order says Citrosuco’s last documented evaluation concluding that corroded piping remained safe was a visual inspection performed in 2019.

A later compliance audit in 2022 found that corrosion inspections and testing were not being conducted according to good engineering practices and manufacturer recommendations. The audit recommended adding corrosion inspections to the annual mechanical-integrity program.

By the 2024 inspection, EPA said Citrosuco had no documentation demonstrating that the affected lines remained safe to operate.

“Respondent had no documentation demonstrating these lines were safe to operate.” EPA consent agreement, description of corrosion and pitting observations

The same gap appeared at the audit level. Citrosuco completed a facility compliance audit in 2022, but EPA said the company had no documentation showing that it determined an appropriate response to every finding or that the identified deficiencies had been corrected.

A decade-old procedure overstated available ventilation

The facility’s written procedures and its equipment records did not match. One standard operating procedure said ammonia sensors would activate at 150 parts per million and provide at least 20,000 cubic feet per minute of outside air. The ventilation documentation showed that System 1 could provide only 8,000 cubic feet per minute.

The procedure’s footer said it was last reviewed on May 8, 2014. EPA alleged that Citrosuco failed to review procedures as often as necessary and failed to certify annually that they remained current and accurate.

EPA also said documentation available during the inspection did not demonstrate past annual testing of emergency stops and emergency ventilation systems. Citrosuco later supplied records showing that annual testing was conducted on March 28, 2024, later in the same month as the inspection.

EPA condensed the record into seven alleged violations

The 27 observations were not presented as 27 separate legal violations. EPA grouped its case into seven alleged failures under the Clean Air Act’s chemical accident prevention regulations.

Years passed between the oldest records and the final order

The human stakes are real, but the record does not document an injury

The order does not say that ammonia was released, that a worker was exposed or that anyone was injured. It also does not identify how many people worked near the covered process.

What it does establish is why the alleged deficiencies mattered to prevention and response. Workers and emergency personnel may rely on alarms to recognize a problem, labels to understand where ammonia is moving, ventilation to remove contaminated air, controls to shut equipment down, and unobstructed exits to leave the area.

Several observations concerned what would happen after something went wrong. The eyewash and shower inside Machinery Room 2 lacked adequate flow. No second unit was outside the room. One roof platform lacked a guardrail, roof grating was unstable, and a locked gate could impede the property’s primary means of emergency egress.

These facts support a finding of potential risk, not a claim that the worst outcome occurred. The supplied record documents alleged weaknesses in layers of protection, not a casualty event.

Citrosuco settled without admitting the factual allegations

Citrosuco agreed to the $179,634 penalty, consented to the order’s conditions, waived its right to contest EPA’s seven allegations and waived an appeal. The company also acknowledged that the order counts as an enforcement action when EPA considers its compliance history in any future case.

At the same time, the agreement states that Citrosuco neither admitted nor denied the factual allegations. A consent order resolves a case without the fact-finding process of a contested hearing, so the distinction matters.

Citrosuco certified, to the best of its knowledge, that it was currently complying with relevant Clean Air Act requirements and that all alleged violations had been corrected. The agreement contains no separate narrative explanation from the company and no item-by-item account of the corrective work.

The company certified that “all violations alleged herein, which are neither admitted nor denied, have been corrected.” Consent Agreement and Final Order, paragraph 21(d)

The settlement resolves federal civil-penalty liability only for the violations and facts specified in the order. It does not relieve Citrosuco of ongoing compliance duties or prevent EPA from pursuing other relief authorized by law.

What the settlement resolves, and what it leaves unanswered

The order provides a financial penalty, a binding compliance commitment and a record that can be considered in future enforcement. Those are concrete consequences.

The public document is less specific about the physical transformation of the facility. It does not provide repair invoices, updated engineering drawings, photographs, testing results for each condition or a follow-up inspection confirming every correction.

The penalty closes the administrative case. The more important preventive question is whether every safeguard now works as a system: the pipes, alarms, ventilation, controls, procedures and escape routes. Citrosuco certified that the alleged violations were corrected. The consent order itself does not supply the itemized evidence that would allow the public to test that claim.