The U.S. Environmental Protection Agency’s (EPA) Region 1, which covers the Northeastern U.S., is implementing a General Duty Clause pilot program impacting facilities with less than 10,000 lbs of ammonia.
These facilities are not subject to the EPA’s RMP (Risk Management Plan) rule, which comprises the EPA’s requirements for facilities with more than 10,000 lbs of ammonia. But they do fall under the federal government’s General Duty Clause, which requires operators to identify hazards and maintain a safe facility.
“The goal is to improve compliance at non-RMP ammonia facilities,” said Lowell Randel, director of government affairs for the International Institute of Ammonia Refrigeration (IIAR),during his annual government affair update at IIAR’s Natural Refrigeration Conference and Expo, held March 4-6 in Phoenix, Ariz.
The goal is to improve compliance at non-RMP ammonia facilities.– Lowell Randel, IIAR
Under the pilot, companies with ammonia systems are queried on whether they have performed a process hazard review, followed by spot checks of facilities. Companies that have failed to perform the review could accept an “expedited settlement agreement,” which would include a $5,000 penalty and the completion of the review with assistance from a third-party, among other measures.
Last November, IIAR released its first guidelines – called Low Charge Ammonia Refrigeration Management (ARM-LC) – for users of low-charge ammonia systems that have a charge of 500 lbs. or less.