What the EPA Actually Expects of the General Duty Clause Ammonia Refrigeration Facility | Blog No.100

Ammonia refrigeration facilities under 10,000 lbs often assume they’re “not regulated.”

because they fall below the formal PSM/RMP thresholds. But under the General Duty

Clause (GDC), the EPA still expects these facilities to identify hazards, maintain a safe

system, and prevent accidental releases.

While GDC sites are less likely to receive random “lottery” inspections, they will be

thoroughly inspected if a release occurs. If you have onsite or offsite consequences,

your facility should fully expect an EPA inspection.

Recently, an ammonia facility in EPA Region IV received a Request for Information

(RFI) following an incident. This provides a real-world look at the actual documentation

the EPA expects GDC facilities to maintain.

Below is the anonymized, verbatim request (with dates redacted):

EPA Request for Information

1. Provide a map of the facility. On this map, identify the area where the incident

occurred.

2. Provide piping and instrumentation diagrams (P& ID) for the ammonia refrigerant

system. Identify on this diagram the area where the incident occurred.

3. Provide a copy of the facility’s hazard assessment for the ammonia refrigerant

system.

4. Provide a copy of all standard operating procedures used by the facility

for the ammonia refrigerant system.

5. Provide a copy of all documents used by the facility for hazard communication

about ammonia and the ammonia refrigerant system.

6. Provide a narrative description of the facility’s mechanical integrity and

preventative

maintenance programs for the ammonia refrigerant system.

7. Provide a copy of any maintenance work orders or inspection reports for the

ammonia refrigerant system from [REDACTED] to present.

8. Provide a copy of the facility’s emergency response plan.

9. Provide the following information regarding the ammonia refrigerant system:

a. The date the system was commissioned [REDACTED];

b. The initial ammonia charge size in pounds;

c. Any records of replacement ammonia added to the system; and

d. Description of any modifications, improvements, changes, replacements,

and/or upgrades made to the system since [REDACTED].

10. For each ammonia sensor/detector at the facility, provide the make, model,

detection concentration range, location, and records of the most recent

calibration.

11. Provide a list of all pressure relief valves (PRV) installed on the ammonia

refrigeration system. For each PRV, provide the date of the most recent

replacement or recertification.

12. Provide a copy of any communications between the facility and any government

agency about the incident.

13. Provide a narrative description of the incident, including the root cause.

14. Explain what steps the facility has taken or will take to prevent similar incidents.

15. Provide a written description of the company’s business structure, including

ownership, corporate form, parent/subsidiary companies, and affiliated

organizations.

What This Tells Us

The EPA expects GDC ammonia facilities to have real programs, not informal practices.

Based on this RFI, a compliant facility should already have:

 Accurate documentation: facility map, P& IDs, ammonia inventory, modification

history (an argument can be made that management of changes would satisfy

this requirement).

 Written programs: hazard assessment, SOPs, hazard communication,and

emergency response plan.

 Mechanical integrity: a defined PM program and maintenance records that go

back years.

 Safety devices managed: detector calibration records and PRV

replacement/recertification history.

 Incident investigation: documentation of root cause and corrective actions.

 Organized records: everything easily retrievable on short notice.

In short:

General Duty Clause = PSM/RMP fundamentals, just without the 14-element

labels.

If you can’t quickly produce these items, the EPA will treat that as noncompliance.

Need Help Getting Into Full GDC Compliance?

Macha PSM helps sub-10,000-lb ammonia facilities build complete, inspection-ready

GDC programs—SOPs, hazard assessments, MI programs, P& IDs, emergency plans,

detector/PRV tracking, and more.

If you want a modern, organized, inspector-ready ammonia program, we can help you

get into compliance. Please reach out to learn how we can prepare you for EPA

inspections.

Thanks for reading!

Stay tuned for more!

Previous blog: Meeting the January 1 Federal MSSE Deadline: What Facilities Need to Know | Blog No. 99

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