Shelter-In-Place means a RMP Update is due in 6-months

Recently a facility had an NH3 release via an RV and in the spirit of “doing it right” made all the necessary calls, including notifying their local FD.  The FD arrived, although it was not required as the facility response team had matters under control before their arrival, the FD felt it was necessary to issue a SIP alert for those within 1,000′ of the facility.  This was done out of an abundance of caution because a housing development was in close proximity of the plant and the weather that day was of the type people would have their windows open.

None the less, a relief valve on the refrigeration system lifted and discharged an unknown amount of NH3 (still unknown/reported at the time of this writing); however, regardless of the amount released, the fact that the FD issued a SIP, this facility now has a “5-year accident history,” and thus they have 6-months to “update their RMP” to reflect this change.

I was not involved in this incident and have no “official record” of the events, but these types of incidents can often result in a SIP alert being issued and that folks is all it takes to create a 5-year accident history for your facility.  40 CFR Part 68.42 states:

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