This is an interesting case! From all evidence I have seen, this ice rink was ordered by the local Fire Department to comply with CalARP regulations back in 1999-2000 time frame. This ice rink was stated as having only 2,056 pounds at the time the business was ordered to shut down (CalARP TQ is 500# for NH3 – Thanks, Brian Chapin for correcting me!). This makes it appear as if the Local FD, acting as the “Administrating Agency” (AA) made positive determinations that the facility contained anhydrous ammonia in quantities rendering it subject to CalARP (quote from the investigative report). The business was contacted several times and appeared to make an attempt to address the FD’s request, but in the end, the owner decided to shut down and file a “closure plan” to demo the refrigeration process. Keep in mind this was a business OPEN to the general public and was in a densely populated area of CA, but still had only 2,056 pounds of NH3. The investigative report by the 3rd party expert (NOT SAFTENG) is quite troubling, but again… this was a process well under the CalARP TQ for NH3 of 10,000 pounds. Here is the case file… CLICK HERE.