Compliance Focus on Ammonia Facilities
EPA initiative establishes minimum key safety measures for inspection.
By Lowell Randel
Compliance and safety in ammonia facilities continues to be a high priority for the Environmental Protection Agency (EPA).
In 2016, EPA announced a series of National Enforcement Initiatives focused on improving safety in a variety of high hazard industries. Among these initiatives was an effort entitled, “Reducing Accidental Releases at Industrial and Chemical Facilities.”
The EPA placed specific emphasis on ammonia facilities as a part of the initiative, which has subsequently been renamed a National Compliance Initiative (NCI). The initial NCI was scheduled to run through fiscal years 2017-2019. The EPA recently announced that the NCI on chemical facilities will continue for fiscal years 2020-2023.
The goal of the NCI is, “to reduce the risk to human health and the environment by decreasing the likelihood of chemical accidents. A successful initiative would reduce communities’ risk by having regulated facilities and industry associations work to: improve safety; increase compliance with RMP and GDC requirements; and promote coordination and communication with state and local responders and communities.”
The Global Cold Chain Alliance (GCCA) and the International Institute of Ammonia Refrigeration (IIAR) are actively engaged with EPA regarding the NCI, and it was the subject of a meeting between industry representatives and EPA as a part of the recent Cold Chain Policy Forum.
Minimum Key Safety Measures
One of the major components of the NCI was the establishment of a list of minimum key safety measures for inspection of ammonia refrigeration systems. These are measures that EPA has determined should be in place, regardless of an ammonia refrigeration system’s age or size. This is not intended to be a complete list of important safety measures but rather a subset of easily verifiable items that could help facilities prevent ammonia releases and prepare for any releases that do occur.
It is important to note that the list does not replace the obligation to comply with EPA Risk Management Program.
Below is a summary of the key safety measures on which EPA inspectors will be focusing when inspecting ammonia facilities:
• Hazard Addressed – Releases or safety deficiencies that stem from a failure to identify hazards in design/operation of system:
› Facility has completed a pro
• Hazard Addressed – High risk of release from operating or maintenance activity:
› System has self-closing/quick closing valves on oil pots.
› Facility has written procedures for maintenance and operation activities.
› Only authorized persons have access to machinery room and the ability to alter safety settings on equipment.
• Hazard Addressed – Leaks/releases from maintenance neglect:
› A preventative maintenance program is in place to, among other things, detect and control corrosion, deteriorated vapor barriers, ice buildup, and pipe hammering, and to inspect integrity of equipment/ pipe supports.
› All piping system openings except the relief header are plugged or capped, or valve is locked.
› Equipment, piping, and emergency shutdown valves are labeled for easy identification, and pressure vessels have legible, accessible nameplates.
› All atmospheric pressure relief valves have been replaced in the last five years with visible confirmation of accessible pressure relief valves [note – replacement every five years is the general rule but there are two other options in IIAR Bulletin 110, 6.6.3]. Machinery Room and System Design
• Hazard Addressed – Inability to isolate and properly vent releases:
› The System(s) has/have emergency shut-off and ventilation switches outside each machinery room.
› The machinery room(s) has/have functional, tested, ventilation. Air inlets are positioned to avoid recirculation of exhaust air and ensure sufficient inlet air to replace exhausted air.
› Documentation exists to show that pressure relief valves that have a common discharge header have adequately sized piping to prevent excessive backpressure on relief valves, or if built prior to 2000, have adequate diameter based on the sum of the relief valve cross sectional areas.
• Hazard Addressed – Inability to regain control and reduce release impact:
› Critical shutoff valves are accessible, and a schematic is in place to show responders where to access them.
› EPCRA Tier II reporting is up to date.
Additional Compliance Items
• For systems that employ hot gas defrost, the process hazard analysis/review includes an analysis of, and identifies, the engineering and administrative controls for the hazards associated with the potential of vapor propelled liquid slugs and condensation-induced hydraulic shock events.
Operating Activities and Maintenance/ Mechanical Integrity
• Written procedures are in place for proper use and care of personal protective equipment.
• If respirators are used, facilities know the location of their respirators, and they are inspected and maintained per manufacturer or industry standards.
• All changes to automation systems (programmable logic controls and/or supervisory control and data acquisition systems) if present, are subject to management of change procedures.
Machinery Room and System Design
• The facility has engineering controls in place to protect equipment and piping against overpressure due to hydrostatic expansion of trapped liquid refrigerant. Administrative controls are acceptable where hydrostatic overpressure can occur only during maintenance operations.
• Eyewash station(s) and safety shower(s) is/are present and functional.
• Emergency response communication has occurred or has been attempted with the Local Emergency Planning Committee and local responders.
• The facility has an emergency action plan pursuant to 29 C.F.R. § 1910.38(a) or an emergency response plan pursuant to 29 C.F.R. § 1910.120(q) and 40 C.F.R. § 68.95.
Members with ammonia facilities, regardless of the size of the ammonia charge, should review their operations to ensure that they have addressed the above items appropriately at their facility.
General Duty Clause Pilot in New England
In addition to the national efforts to address compliance at ammonia facilities, EPA Region 1 in New England is implementing a pilot program focused on facilities with less than 10,000 pounds of ammonia that are subject to the General Duty Clause.
The primary focus of this initiative is facilities with more than 1,000 pounds of ammonia, but less than 10,000.
EPA is sending targeted Information Requests to selected facilities that it has reason to believe may be out of compliance. Facilities will be required to respond to EPA, answering four questions about their ammonia refrigeration systems, including whether a process hazard review has been performed.
If a facility has not performed the required hazard review, EPA will inform the facility that it has violated the first duty of the General Duty Clause. Unless a significant release has occurred at the facility, EPA will offer to resolve this violation for a discounted penalty, provided the company agrees to perform a hazard review of its system with the help of an expert. The company will also be required to meet with emergency responders and submit any missing Tier II forms.
EPA has indicated that it will inspect a small subset of facilities to determine if the Initiative has improved compliance with the General Duty Clause.
Members in New England are strongly encouraged to make sure they have conducted a hazard assessment related to accidental releases of ammonia and have plans in place to prevent releases and minimize the consequences of accidental releases that do occur.
As EPA continues its focus on ammonia facilities through the NCI and efforts like the pilot program in New England, GCCA will remain actively engaged with the agency and key partners, including IIAR, to ensure that industry has the information and tools it needs to promote compliance.
LOWELL RANDEL is Vice President, Government and Legal Affairs at GCCA.