The EPA alleged that the Army Corps did not comply with Risk Management Plan regulations contained in the federal Clean Air Act in its handling of anhydrous ammonia at its Cold Regions Research and Engineering Laboratory in Hanover, New Hampshire. This facility contains about 6,350kg of anhydrous ammonia in a closed-loop refrigeration process.
EPA’s Risk Management Plan programme requires companies that use or store certain amounts of very hazardous chemicals to develop and implement a programme to prevent accidental releases of those chemicals and to reduce any consequences from an accidental release.
Specifically, EPA alleged that the Army Corp failed to comply with safety information requirements; adequately identify, evaluate, and control hazards; comply with operating procedures requirements; comply with mechanical integrity requirements; comply with compliance audit requirements; and have an adequate emergency response programme.
In addition to typical refrigeration equipment, the facility had an emergency ammonia dump system on the outside of the building from which ammonia could be discharged during an emergency to a nearby storm water detention pond that drains into the Connecticut River. As this could potentially harm the river, the Army Corps will be disabling this outdated technology and safeguarding the facility through other means.