EPA has launched and been implementing the Compliance Assurance and Enforcement Focus to improve safety at facilities with smaller ammonia refrigeration systems (over 1000 pounds and less than 10,000 pounds). After a public notice period informing the regulated community about the program, EPA plans to send brief, targeted Information Requests to selected facilities that it has reason to believe may be out of compliance. Facilities will be required to respond to EPA answering four questions about their ammonia refrigeration systems, including whether a process hazard review has been performed. If a facility has not performed the required hazard review, EPA will inform the facility that it has violated the first duty of the General Duty Clause, and offer a one-count settlement with a requirement to perform a hazard review, meet with emergency responders, and pay a small penalty.
EPA New England’s Chemical Accident Prevention Program helps facilities that use hazardous chemicals comply with environmental and storage safety rules. There are many more facilities that must comply with these rules than EPA resources can inspect, so EPA has been using a strategic approach of enforcement and assistance to promote safe practices for storing and using hazardous chemicals. The Region has focused work on ammonia refrigeration facilities in support of the National Enforcement Initiative: Reducing Risks of Accidental Releases at Industrial and Chemical Facilities. In 2017, there were 8 reported ammonia releases at New England ammonia refrigeration facilities. As of July 2018, there have been 5 reported ammonia releases at refrigeration facilities. Ammonia refrigeration work done by EPA Region 1 includes: state ammonia safety trainings, ammonia table-top exercises, ammonia presentations, a chemical accident prevention video, ammonia group email blasts; analysis of EPCRA tier 2 data for ammonia refrigeration facilities; EPCRA in-person workshops and an EPCRA webinar; launch of the Compliance Assurance and Enforcement Focus to improve safety at facilities with smaller ammonia refrigeration systems; and focused assistance to New England ice rinks.
As part of the Chemical Accident Risk Reduction national enforcement initiative, EPA developed the following key safety measures in coordination with the International Institute of Ammonia Refrigeration. They are measures that EPA and IIAR agreed should be in place, regardless of an ammonia refrigeration system’s age or size, for the system to meet the requirements of 40 C.F.R. Part 68 or the General Duty Clause. This is not intended to be a complete list of important safety measures but rather a subset of easily verifiable items that could help facilities prevent ammonia releases and prepare for any releases that do occur. These safety measures should be reviewed during inspections and included as injunctive relief/compliance measures in all settlements where applicable. The second list contains other important safety measures that should be reviewed during inspections and incorporated into settlements if at all possible. This second list also was developed with IIAR’s input. Below is a video from EPA.
[youtube]https://www.youtube.com/watch?v=hLA6EYa7tMg[/youtube]
