AMMONIA REGULATIONS ASSISTANCE
Over the last two decades, many of the federal regulatory agencies have made stricter policies surrounding hazardous materials. Doubl-Kold’s engineers have experience assisting many companies across the United States with meeting the requirements of these regulatory agencies. Our engineers have knowledge of the regulations and laws for ammonia used in refrigeration systems.
Process Safety Management (PSM)
In 1992, the OSHA standard “Process Safety Management of Highly Hazardous Chemicals” (PSM) was issued in the Federal Register. This standard was developed to give requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthy workplaces. For refrigeration systems the standard applies to systems that contain 10,000 pounds of ammonia, although multiple systems that are not interconnected, have less than 10,000 pounds each may still be covered under PSM due to the proximity of the systems. A careful review of multiple systems must be done to determine the appropriate action to take in the PSM standard. Any facility having the threshold quantity of ammonia must have a PSM program in place, as of May 1992. All new facilities are required to develop a plan and have it in place prior to introducing ammonia above the threshold quantity.
The PSM standard contains the following fourteen elements:
- Process Safety Information (PSI)
- Process Hazard Analysis (PHA)
- Standard Operating Procedures (SOP)
- Employee Participation
- Pre-Startup Safety Review
- Mechanical Integrity (MI)
- Hot Work Permit
- Management of Change (MOC)
- Incident Investigation
- Emergency Planning & Response
- Compliance Audit
- Trade Secrets
Risk Management Program (RMP)
In June of 1996, Environmental Protection Agency (EPA), in accordance with the Clean Air Act Amendments of 1990, issued the “Risk Management Program for Chemical Accidental Release Prevention” (RMP). The goal of this regulation is to prevent accidental chemical releases and minimize their impact. The focus of the RMP regulations is protection of the public and environment from the effects of an accidental release of highly hazardous chemicals. All ammonia refrigeration systems containing 10,000 pounds or more must meet the requirements of the RMP regulations. Implementation of the RMP was required by June 1999.
The RMP has the following major elements:
- Management System for the RMP
- Offsite Hazard Assessment and Consequence Analysis
- Including Five Year Accident History
- Accident Prevention Program (Identical to OSHA’s PSM. See notes below.)
- Emergency Response Program
- Submit Plan to EPA
Note: The OSHA-PSM and EPA-RMP, although different in some respects do have several common elements. These common elements do not have to be duplicated, but can be implemented for each program.
Tier II Reporting
In 1986, the Superfund Amendments and Reauthorization Act (SARA) was signed into law. Title III of the SARA is the “Emergency Planning and Community Right-to-Know Act” (EPCRA). Title III establishes the requirements for federal, state, and local governments as well as for the industry regarding emergency response planning and everyone’s right-to-know about hazardous chemicals in their community. The EPA has developed regulations to implement the Title III Law; however, the state and local governments play a key role under Title III as well.
Under SARA Title III, any business that has an “Extremely Hazardous Substance” (EHS) onsite at any time in excess of it assigned “Threshold Planning Quantity” (TPQ) is required to participate in the local emergency planning process. There are approximately 350 chemicals on the EPA’s EHS list. Ammonia is classified as an EHS and the TPQ for ammonia is 500 pounds.
The law requires that businesses that have over 500 pounds of ammonia must complete an “Emergency and Hazardous Chemical Inventory Form,” known as a “Tier II Report.” This form must be submitted on or before March 1 of each calendar year. The Tier II Report must be submitted to three locations:
- State Emergency Response Commission (SERC)
- Local Emergency Planning Committee (LEPC)
- Local Fire Department
General Duty Clause:
The General Duty Clause is part of the Clean Air Act Amendments of 1990 (Section 112 (r)(1)), which applies to any facility that produces, processes, handles, or stores regulated substances or other extremely hazardous substances such as anhydrous ammonia. The facilities which are subject to these requirements are those who operate an ammonia refrigeration system, regardless of size or age of the system. The facilities subject to the General Duty Clause are responsible for:
- Knowing the hazards posed by the chemicals they use and assessing the impact of possible releases of these chemicals.
- Following codes, standards, and other commonly accepted business practices to ensure that the facility is properly constructed and maintained, and that the chemical is managed safely.
- Having a contingency planning process which would involve community responders, if necessary, to aid the facility in responding to a possible accident.
To comply with the General Duty Clause, Doubl-Kold recommends implementing an ARM Program for any ammonia system with less than 10,000 pounds.
Ammonia Refrigeration Management Program (ARM)
Doubl-Kold provides Ammonia Refrigeration Management Programs facilities that have systems that contain less than 10,000 pounds of ammonia. International Institute of Ammonia Refrigeration (IIAR) developed the program to ensure that these smaller facilities were operating safely and in compliance with relevant regulations. IIAR designed the program in an effort to be “proactive” in the industry. It is currently designed to be a voluntary program to structure a facility’s efforts to managing their ammonia refrigeration system safely and responsibly.
IIAR has established the following ten elements that result in a safe ammonia refrigeration system.
- Management System
- Refrigeration System Documentation
- Operating Procedures
- Preventive Maintenance Program
- Contractor Program
- Emergency Response Program
- Incident Investigation Procedures
- Training Program
- Hazard Review Procedures
- Refrigeration Change Procedures
Department of Homeland Security – Chemical Facilities Anti-Terrorism Standard (CFATS)
Doubl-Kold can assist customers with the Department of Homeland Security (DHS) requirement for Chemical Facilities Anti-Terrorism Standard (CFATS). Any facility that possesses (or later comes into possession of) the listed chemicals in quantities that meet or exceed the standard threshold quantities (STQ) for any applicable security issue must complete and submit a Top-Screen to DHS. This document will help DHS determine whether a facility presents a high level of security risk. This ruling came into effect on November 20, 2007. The threshold for anhydrous ammonia is 10,000 pounds on-site.
Helpful Ammonia Regulations Websites