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monitoring/snowfall-extremes/US/1 To address the requirement of evaluating the gaps between the codes and standards to which the ammonia refrigeration system was constructed and modified and the current applicable codes and standards, the first step is ensuring that the applicable codes and standards have been identified for the ammonia refrigeration system. While a lot of facilities have this information, there are many that have no idea of what they are. Once the applicable codes and standards have been identified, the next step is to do a gap analysis. In ammonia refrigeration, IIAR Standard 9 identifies the minimum safety requirements for existing systems. This standard requires that a gap analysis be conducted to evaluate the compliance of the facility’s system against its requirements. Due to a lack of clarity when the standard was first published, an Addendum A was published in 2024, which established a deadline of January 1, 2026 for conducting the gap analysis. It is important to note that if a facility’s system was constructed after the publication of IIAR9 in 2020, it does not have to do this gap analysis for the 2020 edition, but rather needs to ensure that it is fully following IIAR2-2014, Addendum A, or IIAR2-2021, whichever applied to the design and construction of the system. It is also important to note that if a facility or its parent company chooses to comply fully with each new edition of IIAR2, then IIAR9 would also not apply to their system, but they must perform a gap analysis with each new edition of IIAR2. Bear in mind that this is if the facility upgrades to be in FULL compliance with the new edition of IIAR2, which may not be possible, depending upon the changes in a particular edition. Once the chosen applicable gap analysis has been performed, step three is to review the gap analysis as part of the PHA and evaluate

safer technology and alternative risk management measures applicable to eliminating or reducing risk from process hazards. At this time, this provision only applies to NAICS code 324, Petroleum or Coal Products Manufacturing, and 325, Chemical Manufacturing. Since it does not apply to the vast majority of facilities with ammonia refrigeration systems, this paper will not address strategies for com- pliance with this provision. Item 10 requires that the PHA shall address any gaps in safety between the codes, standards, or practices to which the process was designed and constructed and the most current version of applicable codes, standards, or practices. STRATEGIES FOR COMPLIANCE The new PHA requirements have several due dates, some of which have already passed. Covered facilities were required to comply with the following provisions as of the effective date of the changes to the regulations, which was May 10, 2024: 1. Addressing the new items as part of stationary source siting 2. Addressing natural hazards that could cause or exacerbate an accidental release 3. Addressing gaps between applicable

codes and standards To comply with items one and two as quickly as possible, hold a short PHA session to address the stationary source siting by reviewing other RMP facilities close by and whether or not they can affect the facility. In this session, review the nearby public receptors, including schools, places of business, places of worship, prisons & jails, and residential neighborhoods. Finally, review a list of possible natural hazards. The following is a list of web site links that will aid the team in evaluating these new topics. • Stationary Sources cdxapps.epa.gov/olem-rmp-pds/ • Nearby public receptors – 2020 census data ejscreen.epa.gov/mapper/ geopub.epa.gov/myem/efmap/ • Natural Hazards – National Risk Index hazards.fema.gov/nri/map

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