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Additional Concerns

Ammonia refrigeration systems containing less than the threshold quantity are still required to comply with specific mandated requirements. These are intended to address any refrigeration system containing a listed compound.

Operation of an ammonia refrigeration system with a system charge less than 10,000 pounds does not imply safety and environmental controls are not required. The facility owners also need to recognize the following as additional requirements pertaining to the use of ammonia as a refrigerant.

EPCRA - (Emergency Planning and Community Right-to-Know Act, 1986)

  1. Facilities required to publicly disclose information on chemicals used, or potentially released, by on-site processes.
  2. For ammonia refrigeration systems, the threshold planning quantity is 500 pounds.
  3. Any release of ammonia greater than 100 pounds must be reported immediately.

Intended to inform community of hazardous chemicals used within facility.

General Duty Clause of Clean Air Act

  1. The General Duty Clause states: “The owners and operators of stationary sources producing, processing, handling or storing [a chemical in 40 CFR Part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the general duty clause in the Occupational Safety and Health Act (OSHA)], to identify hazards which may result from... releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.”
  2. Knowing the hazards posed by chemicals and evaluation of the impacts of possible releases.
  3. Following codes, standards and other business practices to ensure the facility is properly constructed and maintained – and the chemical is managed safely.
  4. Have a contingency plan involving community responders, if necessary to aid in adequate control of the incident.

Intended to cover any stationary process that uses a hazardous chemical in any quantity.

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