For ammonia, any release to the atmosphere over 100 pounds by weight within 24hrs is considered a reportable release under the Emergency Planning Community Right to Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). What does this mean, immediately upon awareness of this size of leak or greater notifications have to be made to the following: Failure to do so can lead to substantive fines outside the dilemma of having a leak.
- NRC: National Response Center
- LEPC: Local Emergency Planning Community
- SERC: State Environmental Response Commission
Two recent fines from EPA to two different food manufactures/distributors. One fine was close to $200,000 and the other settlement was over $600,000! DOES YOUR COMPANY HAVE A PLAN for Notifications and reporting and after reporting does the procedure include any follow up that may be needed? The facility must provide a detailed written follow-up as soon as practicable after the release. SERCs and LEPCs are required to make these reports available to the public.
Remember, after a reportable release, an RMP facility has up to 6 months to update their RMP submit acknowledging the leak as well.
