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:
Five-year accident history.
(a) The owner or operator shall include in the five-year accident history all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
So as we can see, an event where a SIP alert is issued, even with an “abundance of caution,” that action turns your release into a 5-year accident history incident. And for each accidental release that qualifies as a “5-year accident history” event, the owner or operator shall report the following information:
- Date, time, and approximate duration of the release;
- Chemical(s) released;
- Estimated quantity released in pounds and, for mixtures containing regulated toxic substances, percentage concentration by weight of the released regulated toxic substance in the liquid mixture;
- Five- or six-digit NAICS code that most closely corresponds to the process;
- The type of release event and its source;
- Weather conditions, if known;
- On-site impacts;
- Known offsite impacts;
- Initiating event and contributing factors if known;
- Whether offsite responders were notified if known; and
- Operational or process changes that resulted from an investigation of the release and that have been made by the time this information is submitted by § 68.168.