In an effort to improve the safety at Facilities in New England, EPA Region 1 has launched a General Duty Clause enforcement initiative and is targeting facilities with smaller ammonia refrigeration systems (between 1,000 and 10,000 pounds of anhydrous ammonia).
EPA has already begun sending brief, targeted information requests to a list of selected ammonia refrigeration facilities in New England that it believes may be out of compliance.
Facilities will be required to respond to EPA by answering four questions about their ammonia refrigeration systems, including whether a process hazard analysis has been performed. If you have not conducted one recently, then EPA plans to issue a fine and require the facility to utilize a third-party expert to conduct a hazard assessment and coordinate with local emergency response officials.
Why is this important?
You may not realize you are out of compliance and could receive a significant fine. According to EPA, “Some of the most dangerous facilities that EPA inspected were not aware of the hazards that their refrigeration systems posed to the public, emergency responders, and employees.”
Being aware of, and effectively managing your process hazards ensures a safe workplace for your workers and has wide-reaching benefits for all key stakeholders, including your customers, contractors, and the community. Risk management also ensures your organization can continue to function with as little disruption as possible, drives a positive safety culture, and ensures business continuity which translates into overall value for your organization and its stakeholders.
What actions should you take?
To stay ahead of the EPA initiative, it is important to determine whether or not your facility is in compliance. Conducting a hazard and operability study (HAZOP) is an approved and recommended methodology for evaluating your system. If you have not had one performed recently, having one performed as soon as possible will ensure your facility is prepared to answer the information request EPA will be sending out and if the EPA should visit your facility.
If you have performed a recent HAZOP, it is important to determine whether any process changes have been made to the ammonia system since then and make sure you have documentation and are actively tracking the action items resulting from the assessment.
CAPACCIO can facilitate a HAZOP to determine compliance and address any findings stemming from the assessment. If you have already conducted a HAZOP, CAPACCIO can do a technical review of the assessment to ensure compliance with the requirement.
For more information
If you have any questions or require assistance, please contact Christine Silverman, PE.