EPA orders Connecticut winter sports park to correct alleged violation of the Clean Air Act
Powder Ridge Mountain Park, LLC's noncompliance related to its use of anhydrous ammonia in an ice-making unit on its slopes
BOSTON (Aug. 19, 2024) – The U.S. Environmental Protection Agency recently entered into an Administrative Order on Consent with Powder Ridge Mountain Park and Resort, LLC (Powder Ridge) located in Middlefield, Connecticut, addressing an alleged violation of the Clean Air Act's General Duty Clause due to the company's handling of anhydrous ammonia. Powder Ridge was cooperative with EPA's order and quickly corrected the violation.
"EPA's mission is to protect human health and the environment – and one way we do this is working to reduce the risk of chemical accidents," said EPA New England Regional Administrator David W. Cash. "This order will ensure workers and people visiting the park are made safer from the dangerous risks of anhydrous ammonia. Owners of winter sports parks and ice rinks should take note and ensure they are following these requirements. With climate change on the rise, slope-side ice and snow making units may become more common, so it's important to make sure they are designed and used in a safe way."
Powder Ridge owns and operates an outdoor sports recreation park and resort located at 99 Powder Hill Road in Middlefield, Connecticut. The park offers year-round activities including snow-based winter sports like skiing and tubing. The company uses an ice-making unit to lay an ice foundation for the addition of synthetic snow on top. The unit uses an ammonia refrigeration system that contains around 1,200 pounds of anhydrous ammonia.
EPA inspected the Powder Ridge facility to assess its compliance with the Emergency Planning and Community Right-To-Know Act (EPCRA) and with the General Duty Clause requirements of Section 112(r) of the Clean Air Act. EPCRA Section 312 requires facilities to annually submit a "Tier II" form, reporting the presence of hazardous chemicals in order to aid local emergency response planning. Under the General Duty Clause, facilities using extremely hazardous substances, including anhydrous ammonia, must:
- identify hazards which may result from accidental releases using appropriate hazard assessment techniques;
- design and maintain a safe facility taking steps to prevent releases; and
- minimize the consequences of accidental releases that do occur.
EPA alleges that the inspection revealed violations of the General Duty Clause requirements, including the failure to identify the hazards posed by the refrigeration system. Appropriate hazard identification techniques include standard industry checklists and "what-if" analyses. This analysis then guides a facility on how to improve the safety of the system.
In response to this action, Powder Ridge submitted a missing EPCRA Tier II form. The company also hired a third-party expert to perform a Process Hazard Review for the refrigeration system and coordinated with local emergency responders to plan for a possible accidental release of ammonia.
Ski resorts may increasingly use ammonia refrigeration units on their slopes. They also often have ice rinks on-site, which may use chemicals, such as anhydrous ammonia, that are subject to the General Duty Clause and/or EPCRA requirements.
This action is part of the National Compliance and Enforcement Initiative for Chemical Accident Risk Reduction.
Background
The goal of Section 112(r) of the Clean Air Act is to reduce the risk of chemical accidents. Ammonia presents a significant health hazard because it is corrosive to the skin, eyes, and lungs. Exposure to 300 parts per million is immediately dangerous to life and health. Ammonia is also flammable at concentrations of approximately 16% to 25% by volume in air. It can explode if released in an enclosed space with a source of ignition present, or if a vessel containing anhydrous ammonia is exposed to fire.
More information:
- General Duty Clause Fact Sheet
- Hazardous Chemical Inventory (EPCRA Tier II) Reporting
- Ammonia Safety in New England Ice Rinks Fact Sheet (pdf)
- Ice Rink Emergency Planning and Community Right-To-Know Act Reporting Guidance (pdf)
- Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators