REGULATIONS

Ammonia Regulations

Over the last three decades, many federal regulatory agencies have strengthened the 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, as well as knowledge of the regulations and laws for ammonia use 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. For refrigeration systems the standard applies to systems that contain 10,000 pounds of ammonia. A careful review of multiple systems must be done to determine the appropriate action to take in the PSM standard. All new facilities are required to develop a plan and have it in place prior to introducing ammonia above the threshold quantity.

Elements of PSM Standard

Process Safety Information (PSI)
Process Hazard Analysis (PHA)
Standard Operating Procedures (SOP)
Employee participation and training
Pre-startup safety reviews
Mechanical Integrity (MI)
Hot work permit
Management of change (MOC)
Incident Investigation
Emergency Planning & Response
Compliance Audit
Trade secrets
Contractors

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 implemented in June of 1999.

Elements of RMP

Management system for the RMP
Offsite Hazard Assessment and Consequence Analysis
Including 5-year Accident History
Accident Prevention Program*
Emergency Response Program
Submit plan to EPA

*OSHA-PSM and EPA-RMP requirements 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 access 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 business 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 1st 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 the size or age of the system.

The facilities subject to Duty Clause are responsible for:

Knowing the hazards posed by the chemicals they used 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 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 manage their ammonia refrigeration system safely responsibly.

IIAR’s 10 elements to a safe ammonia refrigeration system