ACCIDENT PREVENTION AND
RESPONSE MANUAL
for
Anhydrous Ammonia Refrigeration System
Operators
U.S. Environmental Protection Agency Region 7
March 2006
(Third Edition)
EPA-907-B-06-001
www.epa.gov/region07/toxics/arpp.htm
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What's this Manual All About?
There are many environmental laws
and regulations in place to protect
operators, other employees, and
surrounding communities from the
potential hazards of working with toxic
chemicals like anhydrous ammonia.
This manual summarizes the
requirements of these laws for
anhydrous ammonia system operators.
A list of the federal laws and regulations related to process safety, accident
prevention, emergency planning, and release reporting may be found in Chapter 5.
Many anhydrous ammonia system operators know their systems inside and out. If
you are already familiar with the environmental laws and regulations that pertain to
your system, then you are invited to test your knowledge by taking the quiz in
Appendix F. If you score 100% - CONGRATULATIONS and you may not need this
manual. If you score less than 100%, this manual will help you update your
knowledge base. Good luck!
Test your ammonia refrigeration knowledge in Appendix F.
This manual has been prepared by the Environmental Protection Agency Region 7 (Iowa, Kansas,
Missouri & Nebraska). Region 7 thanks all who contributed their time and expertise to the
development of this manual. A special thanks to the final editor, Patricia Reitz, of EPA Region 7.
Notes about this Third Edition:
The first printing of this manual was April 2005. The second printing had minor typographical changes and was printed October 2005.
This third printing corrected typographical and formatting errors. In addition, the "Rupture Disc/Dual Relief Valve Assembly" diagram on
Page 3-5 was modified. The final change was on Page 3-13 with the addition of the "Thermal Imaging" section.
Disclaimers:
This manual provides guidance to assist regulated entities in understanding their obligations in accordance with environmental laws.
For a complete understanding of all legal requirements, the reader must refer to applicable federal and state statutes and regulations.
This manual is not a substitute for regulations, nor is it a regulation itself. Thus, it cannot impose legally binding requirements of EPA,
states, or the regulated community.
This guidance does not represent final agency action and may change in the future, as appropriate.
This guidance does not limit the otherwise lawful prerogatives of regulating agencies. Agencies may act at variance with this guidance
based on facility-specific circumstances.
Mention of trade names, commercial products, industry references, and technical resources does not constitute an endorsement or
recommendation for use.
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
TABLE OF CONTENTS
Chapter 1 WHAT'S THE BIG EMERGENCY?
1.1 Accidents Happen 1-1
1.2 Why is Anhydrous Ammonia So Dangerous? 1-2
Chapter 2 IS MY FACILITY A SAFETY RISK?
2.1 Determine Your Responsibility 2-1
Chapter 3 PREVENTING ACCIDENTS
3.1 Work Safely 3-1
3.2 Property Security 3-18
Chapter 4 WHAT TO DO WHEN THERE IS AN ACCIDENT
4.1 Be Prepared 4-1
4.2 Report the Accident 4-2
Chapter 5 WHERE THE GOVERNMENT COMES IN
5.1 Other Federal Requirements 5-1
5.2 State and Local Requirements 5-6
5.3 Audits 5-6
5.4 Investigations 5-7
5.5 Inspections 5-8
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
CLEAN AIR ACT (CAA) PREVENTION PROGRAM
REQUIREMENTS
EMERGENCY PLANNING
EMERGENCY FIRST AID FOR AMMONIA EXPOSURES
DEFINITIONS OF ACRONYMS
EDUCATION AND INFORMATION RESOURCES
ANHYDROUS AMMONIA HANDLING QUIZ
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
CHAPTER 1 - WHAT'S THE BIG EMERGENCY?
1.1 Accidents Happen
Ammonia is used as a refrigerant at a large number of
industrial facilities. Industrial facilities that typically
use ammonia refrigeration systems include:
Cold storage warehouses and ice plants,
Meat, poultry, or fish processing centers,
Dairy and ice cream plants,
Wineries and breweries,
Fruit/vegetable juice and soft drink processing
facilities, and
Petrochemical facilities.
Accidental ammonia releases cause injuries and death to employees, emergency response
personnel, and people in surrounding communities. Here are some examples.
Cold Storage
Explosion Kills
Firefighter
A firefighter was killed and
another seriously injured
by an explosion at a cold
storage warehouse in 1984.
Investigators determined
the likely cause to be
ignition of a hazardous
accumulation of ammonia
gas. Factors contributing
to the loss of life and the
extensive property damage
included failure of
maintenance workers to
take precautions to
minimize release and
accumulation of the
ammonia.
Forklift Ruptures
Ammonia Pipe
A forklift struck and
ruptured an ammonia
refrigeration pipe at a
meat packing plant in
1992.. Workers were
evacuated when a leak
was later detected. A
short time later, an
explosion caused
extensive damage,
including large holes in
two sides of the building.
The forklift was believed
to be the ignition source.
45,000 Pound
Release of
Ammonia
A 1989 ammonia release
led to the evacuation of
nearly 6,500 residents of
the town where the plant
was located. This release
formed a cloud
approximately 24 city
blocks long. Fifty area
residents where treated
with oxygen at local
hospitals, while dozens
more were treated at
evacuation centers. This
release started when the
end cap of a 16-inch
suction line was knocked
off.
Ammonia Thefts
Cause Releases
EPA receives ammonia
theft reports every few
weeks. Releases during
the thefts have injured
and killed several
people. Valves left
open during siphoning,
plugs removed from
pipes, and wrong hoses,
fittings, and containers
have caused leaks and
spills that would not
otherwise occur.
72% of all reported chemical accidents in this Region's 4-State area
involve anhydrous ammonia. Up to 96% of them are preventable
through increased operator training, improved procedures, and
better communication of lessons learned.
(Based on chemical accidents required by EPA to be reported by industry from 1994-2004).
CHAPTER 1 - WHAT'S THE BIG EMERGENCY?
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
1.2 Why Is Anhydrous Ammonia So Dangerous?
Anhydrous ammonia and ammonium hydroxide are two types of ammonia commonly used
in industry. This manual will focus on the "anhydrous" type, which means, "without
water." (Ammonium hydroxide is formed when ammonia gas is dissolved in water.)
Anhydrous ammonia is very corrosive, and exposure to it may result in chemical-type burns
to skin, eyes, and lungs. It may also result in frostbite, since its boiling point is -28°F.
Ammonia is hygroscopic, which means it has a high affinity for water, and migrates to
moist areas like the eyes, nose, mouth, throat, and moist skin.
Released anhydrous ammonia will rapidly absorb moisture from
air and form a dense, visible white cloud. This dense cloud
tends to travel along the ground on a cool day. Do not enter a
visible cloud of ammonia. It will damage your lungs.
If there is no visible cloud, you can still detect an ammonia
release by it's pungent odor when it is present in the
concentration of 5 to 50 parts per million (ppm*). Exposure
to anhydrous ammonia between 5 and 50 ppm can cause
headaches, loss of the sense of smell, nausea, and vomiting.
Concentrations above 50 ppm result in irritation to the nose,
mouth, and throat causing coughing and wheezing.
Concentrations of 300 to 500 ppm are immediately dangerous
to life and health. People will generally leave the area due to
lung irritation, coughing, and shortness of breath. Higher
exposures can cause fluid in the lungs (pulmonary edema),
and severe shortness of breath.
Ammonia is also flammable and explosive. It can be ignited by something as common as
the electric flash from a switch.
Refer to Appendix C for Emergency First Aid for Ammonia Exposure.
The best first aid is to prevent the injury in the first place. Preventing accidents not only
keeps employees healthier and more productive, it saves a lot of wasted time and money
from having to repair equipment, pay for injured employees' medical expenses, lost
product, and having to clean up the mess. Chapter 3 discusses how to prevent accidents.
*An example of parts per million (ppm) is one (1) needle in a 2000 pound haystack.
CHAPTER 1 - WHAT'S THE BIG EMERGENCY?
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
CHAPTER 2 - IS MY FACILITY A SAFETY RISK?
2.1 Determine Your Responsibility
Keeping employees, emergency workers, and the surrounding community safe is of utmost
importance. Therefore, Congress has enacted laws requiring hazardous chemical facilities
to prevent accidents and respond to emergencies that might occur.
Under Section 112(r) of the Clean Air Act (CAA) and Title 40 of the Code of Federal
Regulations (CFR), Part 68, owners and operators of stationary sources are required to
develop Risk Management Programs for each regulated substance in a process. The goal
of EPA's Risk Management Program is to prevent or minimize consequences of accidental
releases of certain hazardous substances.
Compliance with 40 CFR 68 is required if the facility has more than the threshold
quantity of a regulated substance in a process (including storage) at any given time.
40 CFR 68.130 lists the threshold quantities of regulated substances and the basis for their
listing (i.e., toxic or flammable). Facilities subject to 40 CFR 68 were to be in compliance
by June 21, 1999, or the date when the facility first had over the threshold quantity of a
substance in a process, whichever was later. The threshold quantity for anhydrous
ammonia (CAS#7664-41-7) is 10,000 pounds, which is approximately 2000 gallons.
If you aren't sure whether this rule applies to
your facility, call the EPA HOTLINE at:
(800) 424-9346 or (800) 553-7672 (TDD).
If you find that one or more of your processes are subject to this rule, you will likely need to
develop an accident prevention program and an emergency response program. In order to
develop the correct level of prevention program, you will need to determine whether your
facility is subject to Program 1, Program 2, or Program 3. Appendix A will help you
determine your program level and corresponding responsibilities.
If your facility is subject to this rule, see Appendix A
CHAPTER 2 - IS MY FACILITY A SAFETY RISK?
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
CHAPTER 3 - PREVENTING ACCIDENTS
3.1 Work Safely
As mentioned in Chapter 1, ninety six percent of accidents reported in Region 7 (Iowa,
Kansas, Missouri, and Nebraska) are preventable through increased operator training,
improved procedures, and better communication of lessons learned. A major component
of working safely is to develop and implement "Best Practices" at your facility. Best
practices are intended to help facility engineers and operators:
Learn from experiences of other facility engineers and
operators;
Encourage proactive measures to minimize and prevent
releases from anhydrous ammonia refrigeration systems;
Recognize specific actions taken to improve process safety,
prevent accidents, and enhance emergency planning and
response efforts; and
Be better prepared to help facility managers understand and
approve the efforts required to incorporate these and other
best practices.
Under the Clean Air Act Section 112(r)(l),
facilities, including anhydrous ammonia facilities of any size,
have a general duty "to prevent releases, and to minimize the
consequences of accidental releases which do occur."
Implementing "best practices" helps facilities to comply
with this law.
System Design, Modification, and Protection
Personnel at ammonia refrigeration facilities should be aware of the hazards associated
with anhydrous ammonia releases and the measures that can be taken to prevent such
releases. It is important to consider the chemical characteristics of anhydrous ammonia
when determining appropriate accident prevention measures. Here are steps that
ammonia refrigeration facilities could take to prevent releases and/or reduce the severity
of releases should they occur.
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Find locations for installing
"Self-Closing" Valves
Using a spring-loaded 1/4 turn ball or globe valve
("self-closing" valve) with an oil drain container is
considered a best practice. A "self-closing" valve
functions as an emergency stop valve to prevent an
ammonia release if the operator draining oil is
overcome or must abandon his work station. As an
alternative, the International Institute of Ammonia
Refrigeration recommends "quick turning" ball
valves instead of the self-closing valves. Regardless
of which type of valve is used, maintenance staff
should not leave these valves unattended during oil
drain-off procedures.
"Self-Closing" Valve (Dead Man
Valve)
Protect Equipment, Tanks, Piping
Forklifts, hand trucks, and other maintenance vehicles can and have caused ammonia
releases after damaging unprotected components of ammonia refrigeration systems. It is
good practice to provide barriers or establish safety procedures to protect refrigeration
equipment (e.g., pipes, valves, evaporator coils, tanks, vessels, etc.) likely to be damaged.
Examples of how facilities are protecting refrigeration equipment include:
Warning signs;
Bang plates;
Photo beams;
Incorporating warning devices in forklifts;
Suspending PVC pipes and cowbells below ceiling
mounted evaporator coils;
Installing horizontal and vertical structural members to
prevent products on pallets from falling against
refrigeration equipment;
Blocking access to storage bins immediately adjacent to
and below refrigeration equipment; and
Installing concrete curbs, barriers, bollards, or aprons to
prevent wheeled equipment from impacting equipment.
Install bollards to
protect tanks, lines,
valves and coils from
forklift impact.
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Install, Maintain, and Inspect Ammonia Detector Systems
It is good practice to use ammonia detectors to help monitor anhydrous ammonia systems
for leaks. Consider installing detectors in areas where a leak could occur or an area
which is not manned 24 hours per day and 7 days a week. The detectors could be
monitored by a local alarm company or linked into an automated system that contacts
offsite personnel. Operation of ammonia sensors and alarms should be checked and
calibrated regularly to ensure the alarms are set to alert personnel of a release.
The following are examples of detector problems that have been noted during
inspections:
Ammonia detectors were calibrated to alarm at 600 ppm, twice the IDLH
(immediately dangerous to life and health) level;
Ammonia detectors did not function properly; and
Ammonia detectors were not properly calibrated.
Ammonia detectors should be calibrated every six months with the alarm set at or below
50 ppm for detectors located out of the engine room. Ammonia detectors located in the
engine room should trigger the alarm at or below 300 ppm.
Facilities have also used ammonia detector signals to activate ventilation fans in
compressor rooms and to trigger remote alarms to notify facility security personnel about
accidental releases of ammonia.
In order for the alarm to be
protective within the
facility's operation, the alarm
set points should be site
specific and range specific.
Each alarm should also
activate a call down system
that alerts key ammonia
refrigeration personnel.
Please see the example to the
right.
Alarm
Caution
Warning
Alarm
Set Point
30-60 ppm
60-130 ppm
130-225 ppm
Alarms/Actions
Local alarm horns & strobe lights.
Call down system on.
Alarm Horns & Strobes.
Vent fans activate.
Call down system on.
Alarm Horns & Strobes.
Vent fans activate.
Automated announcement.
Ammonia compressor shuts down.
Call down system on.
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Constant ventilation in a machinery room is an option available in place of ammonia
detection devices per the American National Standards Institute/American Society of
Heating, Refrigerating and Air-Conditioning Engineers 15-1994 Safety Code for
Mechanical Refrigeration. Paragraph 8.14(h) states:
"When ammonia is used, the machinery room is not required to meet Class I, Division 2,
of the National Electric Code providing:
The mechanical ventilation system in the machinery room is run continuously and
failure of the mechanical ventilation system actuates an alarm; or
The machinery room is equipped with a vapor detector that will automatically start
the mechanical ventilation system and actuate an alarm at a detection level not to
exceed 1000 ppm.
Install Check Valves in Ammonia Charging Line
Facilities should consider installing a manual check valve in the ammonia charging line
in a location close to the main control valve. This check valve can be used to isolate any
problems associated with the main control valve and prevent release or removal of
ammonia through the charging line.
Configure Remote Operation of Solenoid Valve on King Valve Line
It is best to install a solenoid valve in the King Valve line near the receiver vessel and
configure operation by a manual switch located outside of the compressor/recycle room.
The system's manual kill switch should also be clearly recognizable by all facility
personnel and emergency responders.
Install Dual Relief Valves
Facilities are replacing single pressure relief valves (PRVs) with dual relief valves to
facilitate the maintenance of relief valves. Installation of a dual relief valve consists of
one three-way shut-off valve and two pressure safety release valves. The American
Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE)'s Standard
15, Safety Code for Mechanical Refrigeration, outlines the required use of dual pressure
relief valves.
Use of dual relief valves and a three-way valve allows one relief valve to be serviced,
tested, or replaced, while the other PRV remains on-line to protect the refrigeration
equipment. This configuration enables the operator to keep the refrigeration system
operational rather than needing to pump down the equipment each time a relief valve is
serviced or replaced. Each valve must be of adequate size to protect the refrigeration
equipment.
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Large Systems with Multiple PRVs
For large systems with many PRVs, consider using the arrangement shown below for
detecting leakage. This arrangement includes installation of a rupture disc upstream of
each PRV with a gauge port or transducer in between the disc and PRV and installation of
an ammonia sensor in the PRV common manifold. In case of leakage from a PRV, the
sensor would set off an alarm. A check of either the pressure gauge, rupture disc, or
transducer signal would permit easy identification of which PRV has popped.
Rupture Disc/Dual Relief
Valve Assembly
NH3 Senso
To common manifold
tying in all PRVs
\
PRV -
Gauge -
Port
Rupture
disc
Highest platform
designed for
human traffic
Pressure Relief Valve (PRV)
Gauge Port
Rupture disc
Three-way valve
Install Emergency Ventilation Switches
Some facilities have installed manual switches to remotely
activate ventilation fans. Others have their ammonia
detectors activate the fans at a certain parts per million
(ppm) level, and some facilities use continuous ventilation.
It is recommended to have the remote switches located
near, yet at a safe distance from, the compressor room.
Identify the switch(es) with signage for use in an
emergency.
Emergency Control Switches
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Color Coding and Labeling
Using a color-coding and/or a labeling system helps to ensure the facility's engineering
drawings or piping and instrumentation diagrams (P&IDs) are up-to-date and reduces the
chances of errors in the facility's operating procedures. One generic example could be as
follows:
1. Use arrows to indicate the direction of ammonia flow.
2. Use abbreviations to properly identify system components.
3. Indicate whether the refrigerant is a liquid, vapor, or both.
Orange color band indicates liquid state
Blue color band indicates vapor state
Use both color bands to indicate both states are present
4. Print "Ammonia" in black letters on yellow background.
5. Indicate whether the internal pipe pressure is high or low.
Red color band indicates high pressure
Green color band indicates low pressure
Facilities that lack clear and comprehensive labeling are
"accidents waiting to happen."
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
All piping, valving, and instrumentation should be uniquely identified as illustrated in
Section 11.2.2 of ANSI/ASHRAE 15 (1994).
ANSI/ASHRAE 15 (1994)
Safety Code for Mechanical Refrigeration; Section 11.1.2, Controls and Piping Identification
"Systems containing more than 110 Ib (50 kg) of refrigerant shall be provided with durable signs
having letters not less than 0.5 in. (12.7 mm) in height designating:
(a) valves or switches for controlling the refrigerant flow, the ventilation, and the refrigeration
compressor(s), and
(b) the kind of refrigerant or secondary coolant contained in exposed piping outside the
machinery room. Valves or piping adjacent to valves shall be identified in accordance with
ANSI A13.1, Scheme for Identification of Piping Systems."
Some examples include:
Select and post the facility's marking and labeling system for
it's components and piping.
Identify the chemicals within the piping system(s) using a color
coding system (e.g., ammonia, new or used oil).
Identify the king valve and all other emergency isolation valves with large, easily
identifiable placards to be used in an emergency.
Clearly and consistently indicate the king valve and all other emergency isolation
valves on the piping and instrumentation diagrams (P&IDs) and any process flow
or control logic diagrams.
Post ammonia placards (i.e., National Fire Protection
Association 704 NH3 diamond) and warning signs in areas
where ammonia is being used as a refrigerant or is being stored
(e.g., compressor room doors).
Distinguish and label storage cabinets used for emergency NFPA diamond
response equipment, supplies, and reference materials.
Field verify line and labeling accuracy using current update of the systems P&IDs.
Consider whether signs should be posted in other languages in addition to
English.
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
SYSTEM OPERATIONS AND MAINTENANCE
Develop Operating Procedures
Operating procedures should be developed and implemented in accordance to 40 CFR
68.69, "Operating Procedures". Refrigeration operators and maintenance personnel
should review and follow the facility's operating procedures before performing routine
tasks (e.g., adding ammonia, replacing a PRV, etc.).
Here are some helpful resources for developing operating procedures:
American National Standard: Safety Code for Mechanical Refrigeration,
ANSI/ASHRAE Standard 15, 1994.
Guidelines for: Suggested Safety and Operating Procedures When Making
Refrigeration Plant Tie-Ins, IIAR Bulletin 107, 1997.
Guidelines for: IIAR Minimum Safety Criteria for a Safe Ammonia
Refrigeration System, IIAR Bulletin 109, 1997.
Guidelines for: Start-Up, Inspection, and Maintenance of Ammonia
Mechanical Refrigeration Systems, EAR Bulletin 110, 1993.
Develop and Maintain Preventative Maintenance Program
In accordance with 40 CFR 68.73, "Mechanical Integrity", procedures must be written
and implemented to maintain the ongoing integrity of process equipment. A preventative
maintenance program and schedule, based on the manufacturer's recommendations,
should be prepared for each component of a refrigeration system.
Monitor Refrigeration System Operating Parameters
The ammonia refrigeration system should be routinely monitored. Many facilities use a
Daily Engine (compressor) Room Log for recording the refrigeration system's various
process temperatures, volumes, vibrations, lubrication levels, and pressures at least once
per operating shift. Startup, shutdown, and pump-down operations, as well as the results
of any work or testing, should be recorded in the daily log.
Operators should regularly review these logs to watch for trends that may indicate system
problems (e.g., increasing system temperatures and pressures, decreases in oil pressure, or
releases of ammonia through PRVs). A defective PRV valve can mean the difference
between a minor release or a major release. Some facilities have the chief engineer, the
plant manager, and a refrigeration technician sign the daily logs to help initiate early,
proactive problem resolution. During design of new systems or retrofitting of existing
systems, most facilities are using computer controls to monitor, record, and alarm process
parameter conditions 24 hours per day.
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Equipment manufacturers and equipment operating manuals should be consulted to
develop and expand operating logs to ensure their usefulness at each unique facility.
A best practice within an operating log is to include a column to document operating
conditions. Record whether conditions are normal or not. If conditions are not normal
indicate levels and trends that should be addressed through maintenance or emergency
actions.
Track Ammonia Purchases and Distribution of Ammonia in Your System
Keep an accurate record of the initial amount of ammonia purchased and any additional
replacement charges of ammonia. This data is not only critical for trend and operations
analysis, but it is also necessary to determine if system-wide ammonia releases are
occurring. If your facility uses more than 10,000 pounds of ammonia in a calendar year,
you may be required to report it in accordance with 40 CFR 372 (See page 5-3). Here is
an example spreadsheet for tracking ammonia distribution in a system:
Component/Unit
Orientation
Diameter (ft)
Length (ft)
Volume (ft3)
Liquid Level (%)
Temperature (QF)
Liquid (ft3)
Liquid (lbs/ft3)
NH3 Liquid (Ibs)
Vapor (ft3)
Vapor (lbs/ft3)
NH3 Vapor (Ibs)
Total NH3 (Ibs)
HPNH3
Receiver V-l
Horizontal
3.50
18
165.44
35.71%
95
59.09
36.67
2,167
106.35
0.6517
69
2,236
Pilot
Receiver V-2
Horizontal
1.67
10.75
23.45
93.02%
95
21.82
36.67
800
1.64
0.6517
1
801
Low Temperature
Suction Trap V-3
Vertical
4.00
8.5
102.04
11.76%
-31
12.00
42.69
512
90.04
0.05134
5
517
Intercooler
V-4
Horizontal
4.00
8.0
100.53
22.92%
17
23.04
40.57
935
77.49
0.159
12
947
Accumulator for #1
V-5
Horizontal
3.00
14.83
104.83
44.44%
17
46.60
40.57
1,891
58.25
0.159
9
1,900
Recirculator Vessel
V-6
Horizontal
4.00
12.33
154.98
56.25%
-31
87.18
42.69
3,722
67.80
0.05134
3
3,725
Refrigeration Oil
For proper system maintenance, refrigeration oil should be removed from the
refrigeration system on a regular basis. The presence of excessive refrigeration oil in the
refrigeration system will only be realized if a facility is recording the volume of oil added
and removed. Extreme caution should be taken to ensure that oil is never directly
removed from a refrigeration system without first pumping down and properly isolating
that component. Since this procedure may be the most dangerous function an
operator performs on a regular basis, a facility should seriously consider the
installation of 1/4 turn, self-closing ball or globe valves (dead-man valves) at all oil
draining points to prevent possible accidents during an oil draining procedure.
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Pressure Relief Valve
Schedule Replacement of Pressure Relief Valves (PRVs)
PRVs should be replaced on a regular schedule, at least
every 5 years. ANSI/IIAR's Standard 2, Equipment,
Design, and Installation of Ammonia Mechanical
Refrigerating Systems, should be consulted to plan
replacement of PRVs. When replacing PRVs, a facility
should also document the replacement dates by date
stamping each PRVs tag as well as by placing an
appropriate entry in the equipment log. Inventories should
then be checked to determine if replacement valves are
available in the event of a PRV malfunction.
Maintain Good Housekeeping Practices
Ensure good housekeeping procedures are followed in the compressor/recycle rooms and
in the immediate vicinity of the evaporators. Accumulated supplies, equipment, and
debris delay detection of equipment damage or ammonia leaks.
Anhydrous ammonia is very corrosive to copper, brass,
and galvanized surfaces and materials. Copper, brass,
and galvanized components should not be present in any
part of an anhydrous ammonia refrigeration system.
Support structure components should be readily visible
such that they can be inspected for deterioration and
replaced before a failure event can occur. The
vulnerable metals used in proximity to ammonia should
be protected with an appropriate coating. All
refrigeration piping should be periodically inspected for
failed insulation/vapor barrier, rust, and corrosion.
Ammonia piping underneath failed insulation should be
carefully inspected for corrosion.
Damaged and deteriorated ammonia piping should be replaced. All uninsulated piping
should be cleaned, primed, and painted with appropriate coating to protect the pipe from
corrosion as well as being consistent with the color coding scheme.
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Piping and Instrumentation Diagrams
Facilities should maintain complete and accurate piping and instrumentation diagrams
(P&IDs) of the ammonia refrigeration system and the equipment manufacturer's
documentation. A P&ID is a set of drawings or detailed schematics that illustrate all
components (e.g., vessels, valves, pumps, piping, pressure relief valves) of the
refrigeration system. Manufacturer's documentation should describe the operation and
control features which are integral to the process. Operating procedures, operation and
maintenance checklists, daily logs, a facility's management plan, and emergency response
materials should all relate to the information found in the manufacturer documentation
and on the facility's P&IDs.
Unfortunately, many facilities have P&IDs that lack critical elements, or do not represent
the current operating configuration and system components. These errors cause operating
errors, delay efforts to minimize an ammonia release, and further increase the risks to
emergency responders.
P&IDs should also be carefully and completely verified while tracing ammonia
throughout a facility. Construction changes, system renovations and repairs, and
draftsman errors all contribute to inaccuracies in P&IDs. Many facilities find that P&ID
verification coupled with a line-and-valve-labeling project is a very cost effective
housekeeping project. Ladder/logic diagrams should then be prepared from the verified
P&IDs and electrical drawings for all system components.
The following is essential P&ID information:
All process chemical-containing equipment (e.g., pressure vessels, compressors,
condensers, evaporators, pumps);
Essential valves (e.g., PRVs, isolation valves, remotely operated valves, control
stations);
Controls (e.g., regulators, float switches, solenoid valves, temperature and
pressure cutoffs, emergency release cutoff valves);
Permanent instruments and sensors (e.g., pressure transducers, meters, gauges);
Equipment and valve numbers;
Permitted-flow direction on all check valves;
Piping sizes, reducers, and block valves; and
Legend of symbols and abbreviations, including date of issue and series of
revisions.
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Conduct a Periodic Process Hazard Analysis
Facilities are required to review the hazards associated with the regulated substance(s) to
look for opportunities for equipment malfunctions or human errors and identify steps
needed to monitor or detect releases. This review is often referred to as a process hazard
analysis (PHA). PHAs help minimize releases and provide a forum for ammonia system
operators to share critical operating knowledge.
A PHA is required every five (5) years or sooner if the facility incurs a major change
(40 CFR 68.50(d) & 68.67(f) and 29 CFR 1910.119). A PHA conducted under the
OSHA Process Safety Management standard can be used as a facility's initial PHA since
OSHA PHAs were to have been completed by May 1997. A well designed PHA should
identify all failure scenarios that could lead to significant ammonia exposure of workers,
the public, or the environment. The facility must keep all PHAs for the life of the
process. Referring to former PHAs ensures that past errors are not repeated and assists
with the process of keeping the PHA current.
Here is an example of a PHA Worksheet:
Example Process Hazard Analysis Worksheet
What if
Drain valve
open/leaking on
lowest vessel
Manual valve
closed in pump
discharge line
Pump stops (due
to mechanical
failure or low
level switch)
Oil lubrication
system fails
Excessive
vibration of
compressor or
pumps
Hazard
Potential release
of ammonia
from leak point
Potential for
high pump
discharge
pressures
Loss of ammonia
flow to
evaporators
Ammonia
discharge
temperatures
increase
Damage to
compressor or
pumps
Consequences
Significant volume of
ammonia release into
engine room
Over pressurize
system, which could
lead to ammonia
release in engine room
No safety or
environmental
consequences
(operation issue)
Compressor bearings
or seals could be
damaged
Potential for
catastrophic ammonia
leak
Safeguards
Log vessel operating
parameters every 4 hours.
Ammonia alarm starts
ventilation fans.
Pressure regulator (vented
back to ultra low vessel) is
in pump discharge line.
Logs of pressure every 4
hours.
Preventative maintenance
program and operator
attention during ammonia
system operations.
Compressor parameters
and oil pressure logged
every 4 hours.
Compressors equipped
with low oil pressure
alarms and cutouts.
Ammonia detector in
engine room will alarm
and start ventilation fans
at lOOppmsetpoint
S
2
1
4
3
2
L
3
4
2
3
3
R
6
4
7
7
6
Recommendations
Ensure operator regularly
checks that caps and plugs
are placed on system and
protected from damage
Consider providing a PRV
on the discharge of pump
No recommendations
No recommendations
Consider conducting
regular vibration analysis
of the compressors and
pumps
By
JF
GH
MS
CW
BW
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
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SYSTEM INSPECTIONS
Conducting any type of inspection is one of the system operator's most valuable tools for
preventing unnecessary accidents due to equipment failure.
Conduct Visual Testing
Visual inspections are relatively inexpensive and provide a great deal of valuable
information to the system operator. To monitor the condition of the ammonia
refrigeration system, the person inspecting the system should note any corrosion of
piping, valves, seals, flanges, and other pertinent equipment. In addition, the insulation
should be visually inspected for breeches in it's integrity. The person conducting the
visual test should keep a log, including photographs, of all findings.
Conduct Leak Testing
All ammonia refrigeration system operators should try to maintain a leak-free ammonia
system. Recommended practice involves leak testing all piping, valves, seals, flanges,
and other pertinent equipment at least four times a year. Some methods that can be used
for leak testing are sulfur sticks, litmus paper, or a portable meter equipped with a
flexible probe.
Operators, maintenance personnel, and other facility workers should be encouraged to
immediately report ammonia odors. Facilities should immediately investigate all
reports of ammonia leaks, and take corrective actions without delay.
Conduct Vibration Testing
Depending on the nature of equipment at the site, some facility operators may elect to
perform vibration testing on rotating equipment (i.e., compressors and pumps). These are
usually performed to supplement the maintenance practices to indicate when equipment
overhauls should be performed. Vibration levels on certain equipment can be logged and
analyzed to determine if abnormal trends are developing or if further inspections are
warranted. Excessive vibration can lead to potential equipment damage which could
increase the probability of an ammonia release. The equipment manufacturer should be
consulted to provide guidance on the usefulness of vibration monitoring for their
particular equipment.
Conduct Thermal Imaging
A growing trend in preventive maintenance is the use of
infrared (thermal) imaging. Infrared thermography helps
locate many problems in their early stages often before
they can be seen or found in any other way. A temperature
difference, usually an abnormal hot spot, is typically
associated with these problems due to high electrical
Infrared image of resistance or excessive friction.
disconnect switch
CHAPTER 3 - PREVENTING ACCIDENTS
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U.S. Environmental Protection Agency Region 7
SYSTEM OPERATORS
Training
Only fully trained and qualified operators should be permitted to operate ammonia
systems. Training is available through a number of trade organizations and professional
societies. Some organizations that provide ammonia refrigeration education and training
are listed in Appendix E, "Education and Information Resources."
In accordance with 40 CFR 68.54 (for
Program 2 facilities) and 68.71 (for Program
3 facilities), the owner or operator of your
facility must provide each employee,
presently operating a process, training or test
their competence in the facility's operating
procedures. The operator is required to take
refresher training at least every 3 years. In
addition, after a major change in operations,
the operator is required to be trained in any
updated or new procedures prior to startup.
For Program 3 facilities, the owner or
operator must record the operator's identity,
date of training and the method used to
verify the operator understood the training.
Training on NH3 System
Provide Awareness Training to Other Facility Personnel
Awareness training should be provided to other
facility personnel who work within ammonia
refrigerated areas. Awareness training of the hazards
associated with ammonia accidents should be
conducted in a manner that encourages immediate
reporting of ammonia system damage and releases.
Immediate awareness of a problem, or potential
problem, can help ammonia operators quickly
minimize and control any accidental releases.
It is important to realize that up to 96% of the anhydrous ammonia accidents reported in
the Iowa, Kansas, Missouri, and Nebraska Risk Management Plans (1994-2004) may
have been preventable through increased operator training, improved procedures, and
better communication of lessons learned.
Factors Causing Ammonia
Releases
Equipment Failure 70%
Human Error 26%
Unusual Weather 2%
Other (e.g., vehicular impacts) 2%
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
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OTHER BEST PRACTICES
In addition to the "best practices" described earlier in this chapter, there are many other
useful resources for those interested in researching additional best practice information.
The following list is not comprehensive, yet we hope you find it to be helpful:
Factory MutuaPs Data Sheet 12-61, Mechanical Refrigeration (May 2002)
Pressure Components:
Piping and appurtenances in ventilated areas
All refrigerant piping should be sleeved through walls and floors
Armored guage glasses and flow check valves minimize losses
4 ft minimum clearance for refrigeration equipment
Preventative Maintenance:
Preventive Maintenance Plans
Effective water treatment program
Purging of moisture and non-condensing gases
Eddy current nondestructive testing of condenser and evaporator tubes
Instrumentation, Controls, Safeguards:
Install various relief and check valves
Install terminal cutout
The Air Conditioning/Heating/Refrigeration News (www.achrnews.com)
Troubleshooting Restricted Air Flow (9/30/00)
Maintenance and Efficiency of Evaporative Coolers (11/8/00)
Technical Tips for Thermostatic Expansion Valves (12/6/00)
Troubleshooting Inefficient Compressors (7/31/01)
How a Dirty or Blocked Condenser Effects System Efficiency (8/29/01)
How to Size Refrigeration System Piping (8/29/01)
The Role of the Suction Line Accumulator (8/29/01)
International Institute of Ammonia Refrigeration (IIAR)
Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems
(ANSI/OAR 2-1999)
Section 5.11 Refrigerant Pumps
Section 5.14 Pressure Relief Valves
Section 5.17 Testing
Section 6.2 Ventilation
Section 7.3 Pressure-Relief Piping
Section 7.5 Field Leak Testing
Appendix A.2 Emergency Discharge Methods
Appendix A.4 Discharge to Atmosphere
CHAPTER 3 - PREVENTING ACCIDENTS
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International Institute of Ammonia Refrigeration (IIAR) - cont.
Good Practices for the Operation of an Ammonia Refrigeration System
(Bulletin No. Rl. 1983)
Chapter II, Section B, Preventive Maintenance
Chapter II, Section C, Observation of System to Prevent Incident
Chapter IV, Section E, First Aid Supplies Checklist
Chapter VI, Section A, Informing Employees
Chapter VI, Section B, Safe Work Practices and Procedures
Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Plant
Tie-Ins (Bulletin No. 107. 12/97)
Section 6, Pumping Out Prior to Tie-In
Section 8, Testing
Water Contamination in Ammonia Refrigeration Systems
(Bulletin No. 108. 1986)
Section VII, Detection of Water Contamination
Section IX, Removal of Water From System
Section X, Safety Precautions
IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System
(Bulletin No. 109. 10/97)
Section 4, Safety Criteria
Section 5, Frequency of Safety Inspections
Section 7, Inspection Checklists
Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems
(Bulletin No. 110.3/93)
Section 5.2, Pre-Start Up Safety Review
Section 6.0, Inspection and Maintenance
Appendix E, Stress Corrosion Cracking
Appendix G, Typical Schedule for Inspection and Maintenance
Appendix H, Sample Details for Register
Appendix I, Sample System Log
Ammonia Machinery Room Ventilation
(BulletinNo. 111. 10/91)
Section 6.0, Operation and Maintenance
Section 7.3 (and Appendix A), Minimum Ventilation Worksheet
Ammonia Machinery Room Design
(Bulletin No. 112.6/98)
Section 4.2.1, Machinery Room Layout and Construction Features
CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
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International Institute of Ammonia Refrigeration (IIAR) - cont.
Identification of Ammonia Refrigeration Piping and System Components
(Bulletin No. 114.9/91)
Section 5.0, Marker Location
Section 6.0, Visibility
Avoiding Component Failure in Industrial Refrigeration Systems Caused by Abnormal
Pressure or Shock
(Bulletin No. 116. 10/92)
Section 4.0, Trapped Liquid
Section 5.0, Sudden Liquid Deceleration
Section 6.0, Vapor Propelled Liquid
Section 7.0, Normal or Not Normal
CHAPTER 3 - PREVENTING ACCIDENTS
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3.2 Property Security
Many accidents can be prevented by taking
proper site safety precautions. Ammonia
theft and vandalism have resulted in death,
injuries, property damage, and chemical
releases from ammonia storage facilities and
refrigeration systems.
The following site security should be
considered at existing facilities as well as at
new sites. Some of these recommendations
will depend on the type and size of your
facility. Appurtenances containing anhydrous
ammonia that are readily accessible to the
general public tend to provide the most serious
security risk. Razor wire is a very effective deterrent.
Educate employees about potential theft events and problems.
Ensure that all outside ammonia vessels and storage areas are well lit.
Know ammonia inventory to quickly identify missing quantities.
Visually inspect all outside vessels and cylinders each morning (especially after
weekends or other periods when the facility is unoccupied).
Consider auditing the facility and setting up a valve protection program for critical
valves that would cause a significant release if opened by mistake.
Consider installing valve locks or fencing, especially for unattended outside
vessels or cylinders.
Install a check valve in the ammonia charging line close to the main control valve.
Evaluate the benefits of installing lockable, quarter-turn ball or globe valves, or
spring-loaded ball or globe valves in series with a manual valve in critical areas
(e.g., ammonia supply connection, oil discharge container).
Report thefts, signs of tampering, leaks, or any unusual activity to local law
enforcement officials.
Consider installing other theft deterrent measures such as multi-lingual warning
signs, fences, walls, motion detector lights, motion detector alarms, security
patrols, and/or video surveillance.
CHAPTER 3 - PREVENTING ACCIDENTS
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To assist in developing your Safety and Security Plans, you may want to look at the
standards and recommended practices from other organizations. Listed below is a partial
list of some resources that can provide information for developing security procedures or
practices:
Standard for Site Security Services for Fire Loss Prevention, National Fire Protection
Assoc. (NFPA)-601.
Responsible Care Employee Health and Safety Code Site Security Management
Practice, Chemical Manufacturers Association.
The Agency for Toxic Substances and Disease Registry (www.atsdr.cdc.gov) provides a
10-step procedure to analyze, mitigate, and prevent public health hazards resulting from
terrorism involving industrial chemicals.
The American Society for Industrial Security (www.securitymanagement.com)
develops educational programs and materials that address security concerns, including
an online version of its magazine.
The Center for Chemical Process Safety (www.aiche.org/ccps) develops engineering
and management practices to prevent and mitigate consequences of catastrophic events
involving chemical releases.
The National Safety Council (www.nsc.org) provides general safety information on
chemical and environmental issues.
The National Security Council (www.energysecuritycouncil.org) is a national industry
association that assists law enforcement agencies and energy companies in combating
all types of criminal activity.
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CHAPTER 3 - PREVENTING ACCIDENTS
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
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Ammonia Release after a facility explosion.
CHAPTER 4 - WHAT TO DO WHEN THERE IS AN ACCIDENT
4.1 Be Prepared
Not knowing how to respond in an
emergency often makes the situation
worse. It is important to develop a
strategic plan for emergency response
and to practice the plan.
In accordance with 40 CFR 68.95, every
Program 2 and Program 3 facility is
required to have an emergency response
program. (Note: If a facility's employees
are not responsible for responding to an
accidental release, then the facility need not comply with 40 CFR 68.95. In this instance,
the facility's emergency response program is to coordinate appropriate emergency
responders and verify they are included in the community response plan. It is the
facility's responsibility to ensure there is a mechanism in place to contact local
responders.) This emergency response program requires the following elements:
An emergency response plan. Your emergency response plan must be specific to
the operations and layout of your facility and must be maintained and kept at your
facility. Each emergency response plan is to include:
S Procedures for informing the public and local emergency response agencies
about accidental releases.
»/ Documentation of proper first-aid and emergency medical treatment for
accidental human exposure.
S Procedures and measures for emergency response after an accidental release.
Procedures for using and maintaining emergency response equipment.
Training for employees in their emergency responsibilities.
Procedures to review and update the emergency response plan.
See APPENDIX B for detailed information on Emergency
Planning.
CHAPTER 4 - WHAT TO DO WHEN THERE IS AN ACCIDENT
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
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4.2 Report the Accident
No matter how well you implement best practices,
planning, and security, accidents may still happen.
Having a well-rehearsed emergency response plan in
place will help alleviate much of the stress when an
accident occurs.
When an accident does occur, it is essential that you
notify the appropriate authorities immediately* so they
can initiate a response if necessary to insure the
protection of the public and the environment.
Notification and response requirements are summarized in the following table:
Ammonia Cloud After a Release
Subject
EPCRA Release Notification
(> 100 pounds of anhydrous
ammonia)
CERCLA Release
Notification (> 100 pounds of
anhydrous ammonia)
&
CWA Release Notification
(> 100 pounds of anhydrous
ammonia over a 24-hour
period that enter "waters of
the U.S.")
Notification of Slug Loading
to POTW
Notification of Hazardous
Waste Discharge to Septic
System
State Statutes
Law and
Regulation
EPCRA
40 CFR 355
CERCLA
40 CFR 300
and 302
&
CWA
40 CFR 117
CWA
40 CFR 403
CWA
40 CFR 144
State Laws
Who to Notify
State Emergency Response
Commission (SERC)
Local Emergency Planning
Committee (LEPC)
National Response Center
1-800-424-8802
POTW, State Hazardous Waste
Authority, EPA Regional Waste
Management Division Director
EPA Regional Underground
Injection Control (UIC) Well
Program, and state UIC Program
State Environmental Agency
When
Immediately*
Immediately*
Immediately*
Immediately*
Varies
* "Immediately" is interpreted as "not to exceed 15 minutes after the person in charge has knowledge of
the release." This interpretation is documented in A Legislative History of the Superfund Amendments
and Reauthorization Act of 1986. Volume 2. October 1990.
CHAPTER 4 - WHAT TO DO WHEN THERE IS AN ACCIDENT
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Immediate Accident Reporting
Initial notifications of a release can be made by telephone, radio, or in person. In
accordance with 40 CFR 302.6(a), a facility is to immediately report releases of more
than 100 pounds of ammonia to the National Response Center at (800) 424-8802.
Reporting should include the following:
Chemical name or identity of the released substance;
Indication of whether the substance is on the CERCLA Section 302(a) list;
Estimated quantity of release;
Time and duration of release;
Medium or media into which the release occurred; and
Whether release threatens waterways (reporting requirement of the Clean Water Act
contained in 40 CFR 117.21).
In accordance with 40 CFR 355.40 a facility is to immediately report ammonia releases
producing offsite exposure and exceeding 100 pounds to their Local Emergency Planning
Committee (LEPC) and State Emergency Response Commission (SERC). The release
report is to include:
Chemical name or identity of all substances involved in the accident;
Estimate of quantity of substances released to the environment; and
Time and duration of release.
The facility owner or operator is also required to provide a written Follow-up
Emergency Notice as soon as possible (and within seven calendar days) to their LEPC
and SERC after a release that requires notification. The follow-up notice should include
the following:
An update of all previously provided information;
Actions taken to respond to the release;
Known or anticipated acute or chronic health risks associated with a release; and
Advice regarding medical attention necessary for exposed individuals.
CHAPTER 4 - WHAT TO DO WHEN THERE IS AN ACCIDENT
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
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CHAPTER 5 - WHERE THE GOVERNMENT COMES IN
5.1 Other Federal Requirements
When it comes to managing your facility in accordance to environmental laws, the
Environmental Protection Agency's laws and regulations are not the only ones to
consider. Federal statutes and regulations relevant to anhydrous ammonia process safety,
accident prevention, emergency planning, and release reporting are summarized in the
table below. Facilities are encouraged to review this information before a release occurs.
Statute and
Regulation
Description
Source(s)
Comprehensive
Environmental
Response,
Compensation, and
Liability Act
(CERCLA,
"Superfund")
40 CFR 302.6(a)
Hazardous Substance Release Reporting
Releases equal to or greater than the reportable
quantity of 100 pounds of ammonia must be
immediately reported to the National Response
Center (NRC).
National Response
Center:
(800) 424-8802
Clean Air Act (CAA)
Section 112(r)(l)
40 CFR 68
General Duty Clause is applicable to facilities that
store or use any amount of extremely hazardous
substances, including anhydrous ammonia. The
General Duty clause indicates facilities "have a
general duty... to identify hazards which may
result from releases using appropriate hazard
assessment techniques, to design and maintain a
safe facility taking such steps as are necessary to
prevent releases, and to minimize the
consequences of accidental releases, which do
occur."
EPA Hotline:
(800) 424-9346 or
(703) 412-9810 or
(800) 553-7672
(TDD)
Clean Air Act (CAA)
Section 112(r)(7)
40 CFR 68
Risk Management Program
Facilities having more than 10,000 pounds of
anhydrous ammonia must develop a hazard
assessment, a prevention program, an emergency
response program, and submit a risk management
plan to EPA.
EPA Hotline:
(800) 424-9346 or
(703) 412-9810 or
(800) 553-7672
(TDD)
CHAPTER 5 - WHERE THE GOVERNMENT COMES IN
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Statute and
Regulation
Description
Source(s)
CAA
40 CFR 608
Regulates the use, recycling, and disposal of certain
ozone-depleting substances (ODS) in applications
including industrial processes and commercial
refrigeration systems. The rules apply to systems
that contain chlorofluorocarbon (CFC) or
hydrochlorofluro-carbon (HCFC) refrigerants or
refrigerant mixtures containing a CFC or HCFC.
(Referenced here to emphasize that 40 CFR 608 is
not applicable to anhydrous ammonia
refrigeration systems.)
(800) 296-1996
Clean Water Act
(CWA)
40 CFR 112
The CWA regulates the discharge of contaminants
to surface water bodies from a point source. If a
facility releases or discharges aqueous ammonia,
then the CWA does apply and discharges of
ammonia effluent would be regulated under state-
specific NPDES permit programs. EPA's published
ambient water quality criteria for ammonia is in
EPA 822-R-99-014 (December 1999).
http://www.epa.gov/ost/
standards/wq s/library
CWA
40 CFR 116.4
Ammonia is listed as a hazardous substance.
http://www.epa.gov/ost/
standards/wq s/library
CWA
40 CFR 117.21
Discharges equal to or greater than the reportable
quantity of 100 pounds of ammonia (that threaten
waterways) must be reported to National Response
Center (NRC) at
(800) 424-8802.
Reporting should be by the person in charge of the
source vessel or facility.
National Response
Center
(800) 424-8802
CWA
40 CFR 122.26
Stormwater Regulations
Regulates runoff from activities that take place at
industrial facilities, such as material handling and
storage that discharges industrial pollutants into
nearby storm sewer systems and water bodies. This
may adversely impact water quality and a permit
may be required for this runoff.
http://cfpub.epa.gov/npd
es/stormwater/indust.cfm
CHAPTER 5 - WHERE THE GOVERNMENT COMES IN
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Statute and
Regulation
Description
Source(s)
EPCRA
40 CFR 355.30
Community Emergency Planning
Facilities that have ammonia equal to or greater
than the threshold planning quantity (TPQ) of 500
pounds must report to their Local Emergency
Planning Committee (LEPC) and State Emergency
Response Commission (SERC), and comply with
EPCRA Section 302 requirements. LEPC and
SERC notification must be within 30 days of the
date of exceedance of the TPQ and include
information for the community emergency response
plan. Facility must also appoint a liaison from the
facility to the LEPC.
EPA Hotline:
(800) 424-9346 or
(703) 412-9810 or
(800) 553-7672 (TDD)
EPCRA
40 CFR 355.40
Emergency Release Notification
Releases equal to or greater than the reportable
quantity of 100 pounds of ammonia must be
immediately reported to the LEPC, SERC, or local
emergency response personnel (911 in the case of
transportation-related release) in accordance with
EPCRA Section 304. Written follow-up is required
within seven calendar days.
National Response
Center:
(800) 424-8802
EPCRA
40 CFR 370.20
Hazardous Chemical Reporting
Facilities that have ammonia equal to or greater
than 500 pounds must submit a Material Safety
Data Sheet (MSDS) or chemicals list to their LEPC,
SERC, and local fire department in accordance with
EPCRA Section 311. Facilities must also comply
with EPCRA Section 312's Tier I (aggregate) or
Tier II (chemical specific)annual, March 1st,
inventory reporting requirements (e.g., quantity,
location, hazards, reactives). MSDSs or chemicals
list must be provided within 3 months of chemical
presence on-site, and then updated with any
significant changes to quantity or process.
National Response
Center:
(800) 424-8802
EPCRA
40 CFR 372
Toxic Chemicals Release Inventory
Manufacturing businesses with certain NAIC codes
and ten or more employees that manufacture,
process, or otherwise use ammonia above an
applicable threshold quantity of 10,000 pounds
must file annually a Toxic Chemical Release form
with EPA and the state by July 1st.
If more than 10,000 pounds of ammonia is added
to a refrigeration system during a calender year it
will trip the "otherwise used" criteria for filing. In
accordance with Section 313, Annual Form A and
Form R (unusual) reports are due July lof each
year.
EPA Hotline:
(800) 424-9346 or
(703) 412-9810 or
(800) 553-7672 (TDD)
TRI User Support:
(202)260-1531;
www.epa.gov/tri and
www. epa. go v/triexplorer
CHAPTER 5 - WHERE THE GOVERNMENT COMES IN
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Statute and
Regulation
Description
Source(s)
Occupational Safety
and Health Act
(OSHA)
29 CFR 1910.38a
Employee Emergency Action Plans and
Fire Prevention Plans
Ammonia incidents should be covered by these
plans. This generally applies to facilities which
plan to rely on off-site services for emergency
response personnel and equipment. Anyone not
part of the Incident Command system should
evacuate the facility.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
OSHA
29 CFR 1910.111
Storage and Handling of Anhydrous Ammonia
This standard does not apply to refrigeration plants
that use ammonia solely as a refrigerant.
This standard does apply to the design,
construction, location, installation, and operation of
any part of an ammonia distribution system (e.g.,
bulk storage facilities, distributors) including its
associated pipelines and is typically applicable to
ammonia retailers. This standard also does apply to
other non-mechanical refrigeration systems users of
ammonia (e.g., anhydrous ammonia used in the
metal treating or reproduction industries).
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
OSHA
29 CFR 1910.119
Process Safety Management (PSM) Standard
Facilities that have ammonia equal to or greater
than the threshold quantity of 10,000 pounds are
subject to a number of requirements for
management of hazards, including process hazards
analysis and maintaining mechanical integrity of
equipment. Note that external threats must be
considered when conducting a process hazard
analysis. The PSM standard is applicable to
ammonia manufacturers and facilities with large
ammonia refrigeration systems, but not applicable
to retail facilities.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
OSHA
29CFR1910.120(q)
Hazardous Waste Operations and
Emergency Response Planning
Generally these requirements apply to employers
who use anhydrous ammonia refrigeration systems.
Requirements include personal protective
equipment testing, levels of protective gear,
compliance guidelines, and training curriculum
guidelines. Generally applies to facilities that
establish capability to offensively respond to an
ammonia release as first responders.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
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Statute and
Regulation
Description
Source(s)
OSHA
29 CFR 1910.132,
1910.133, 1910.134,
and 1910.138
Personal Protective Equipment
Employers are required to provide personal
protective equipment to employees who may be
exposed to ammonia. Employees who wear a
respirator during the course of their job, or who are
expected to wear one during an emergency response
situation, must follow the requirements of the
respiratory protection standard.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
OSHA
29 CFR 1910.156
Personal Protective Equipment
Requirements for the organization, training, and
personal protective equipment of fire brigades
whenever established by an employer.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
OSHA
29 CFR 1910.307
Hazardous (Classified) Locations
There may be locations in an ammonia refrigeration
system that are Class 1 Division 2 hazardous
locations.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
OSHA
29 CFR 1910.1200
Hazard Communication
Requires facilities using toxic and hazardous
chemicals to evaluate potential hazards and
communicate this information to the employees.
OSHA Public
Information:
(202) 219-8151, or
www.osha.gov
Oil Pollution Act
(OPA) of 1990
40 CFR 112,
33 CFR 154,
49 CFR 194,
30 CFR 254
Spill Prevention, Control, and Countermeasure
(SPCC)
Facilities storing oil above 1,320 aggregate gallons
in containers larger than 50 gallons must prepare
and implement SPCC plans. These plans need to
address security elements such as locks, guards,
access, lighting, and vandalism.
http://www.epa.gov/
oilspill/index.htm
Resource
Conservation and
Recovery Act
(RCRA)
40 CFR 264, 265,
and 279.52
Anhydrous ammonia is not a listed hazardous waste
(40 CFR 261). However, disposal of anhydrous
ammonia requires hazardous waste characterization.
Provided that a facility does not treat, store (> 90
days), or dispose of hazardous waste from
anhydrous ammonia systems, the facility does not
have to have a RCRA permit.
EPA Hotline:
(800) 424-9346 or
(703) 412-9810 or
(800) 553-7672 (TDD)
RCRA training
modules:
http ://www. epa. go v/epao
swer/hotline/rmods.htm
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5.2 State and Local Requirements
The federal statutes and regulations discussed above are the primary requirements.
However, state and local governmental agencies may have their own (possibly more
strict) requirements that are based on the federal laws. Therefore, be sure to check
potentially applicable state and local government industrial, agricultural, chemical, and
environmental requirements, including, but not limited to the following:
Department of Agriculture
Fire Marshal
Environmental Division
Local Building/Electrical Codes
Boiler/pressure vessel inspector
Department of Health
State OSHA programs
Your State Emergency Response Commission will also be able to help you determine any
applicable state and local requirements. Refer to the SERC map to locate your state's
web site at: www.osp.state.or.us/oem/RelatedWebSites/states.htm
5.3 Audits
EPA conducts audits at facilities to determine if the facility has a Risk Management Plan
that is in compliance with EPA's Risk Management Program. The EPA will then
typically suggest modifications to a facility's Risk Management Program, leading to
quality improvements. Typical examples of recommendations found during EPA audits
include:
Mount NFPA 704 (NH3) placards on doors to compressor rooms and
condenser/receiver areas;
Install bollards at ammonia fill station to improve
protection against vehicular traffic;
Mechanically protect coils, valves, and pipes
against fork lifts;
Retest, calibrate, and replace ammonia sensors found inoperable during audit;
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Stock spill booms (specific for ammonia) to limit flow of released ammonia;
Perform vibration testing and trend analysis on all motor/compressors every
6 months;
Install check valves in charging line; and
Add audible or strobe alarms tied into ammonia sensors to improve notification to
workers.
Self Audits
In accordance with 40 CFR Part 68.58 and 68.79, facilities with Program 2 and 3
processes must evaluate their compliance at least every three years, documenting their
findings and actions taken to address any problems. Facilities should consider EPA's
Audit Policy, which encourages voluntary auditing and self-disclosure of violations of
environmental regulations. EPA has negotiated numerous corporate-wide auditing
agreements with companies to audit and correct violations across several environmental
regulations. These approaches can offer a facility the opportunity to plan, finance, design,
and implement practices that incorporate environmental compliance into operations.
EPA's EPCRA, RCRA, and CERCLA audit protocols, designed to assist the regulated
community, are available at www.es.epa.gov/oeca/ccsmd/profile.htmltfaudit.
5.4 Investigations
An incident investigation is a requirement of EPA's Risk Management Program, as
contained in 40 CFR 68.60 and 68.81. (Note that these requirements are nearly identical
to those under OSHA's Process Safety Management.)
For processes categorized as a Program 2 or Program 3 process, each incident that results
in (or could reasonably have resulted in) a release must be investigated. The resulting
investigation report should include the following information:
Date of Incident;
Date Investigation Began (< 48 hours after the incident);
Description of Incident;
Factors that Contributed to Incident; and
Recommendations Resulting from the Investigation.
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The goal of an accident investigation is to determine the root causes or management
system failures that ultimately caused the ammonia release. Efforts to determine the
facts, conditions, circumstances, and probable causes of ammonia releases can help to
reduce the likelihood of their recurrence. They can also minimize the consequences
associated with future releases and make anhydrous ammonia refrigeration systems and
operations safer for everyone.
Section 112(r)(6) of the Clean Air Act established an independent safety board known as
the Chemical Safety and Hazard Investigation Board (the "Chemical Safety Board"). One
of the objectives of the Chemical Safety Board is to investigate, determine, and report the
facts, conditions, circumstances, and probable causes of an accidental release that results
in a fatality, serious injury, or substantial property damage. For additional information
concerning the Chemical Safety Board, visit www.csb.gov.
5.5 Inspections
Inspections typically provide an overview of a facility's
compliance with applicable regulations. These are different
from investigations, which specifically focus on events
surrounding an incident and whether specific regulatory
violations occurred.
Section 112(r)(l) of the Clean Air Act is known as the "General Duty Clause", which
expands the range of activities EPA can undertake to promote chemical safety. Under the
General Duty Clause, chemicals and threshold quantities are not listed. Therefore,
ammonia refrigeration systems under 10,000 pounds (RMP Threshold Quantity) are
subject to the General Duty Clause and may be inspected.
Ammonia refrigeration systems under 10,000 pounds
(RMP Threshold Quantity) are subject to the
General Duty Clause and may be inspected.
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APPENDIX A - CLEAN AIR ACT (CAA)
PREVENTION PROGRAM REQUIREMENTS
A.I Determine Your Facility's Program Level
If you have determined that your facility is subject to 40 CFR Part 68, you will first need
to ascertain whether your facility is subject to Program 1, Program 2, or Program 3. This
appendix will guide you in making that determination as well as your corresponding
responsibilities.
Your facility is subject to Program 1 if:
Within the past 5 years of the date you submit your facility's Risk Management Plan
(RMP), the process has not had an accidental release of a regulated substance that
resulted in death or injury, or required restoration of an environmental receptor;
Your process has worst-case release scenarios with no possible impact to public
receptors; and
Your process has emergency response procedures coordinated with local responders.
Your facility is subject to Program 2 if:
It has any process that does not meet criteria for Program 1 or Programs.
(Ammonia refrigeration processes will usually not be eligible for Program 2, because
they are covered by OSHA Process Safety Management (PSM) standard codified at
29 CFR 1910.119.)
Your facility is subject to Program 3 if:
It has any covered process in North American Industrial Classification System
(NAICS) code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211,
325311,32532; or
It has any covered process that does not meet the eligibility requirements for Program
1 and the process is subject to the OSHA PSM standard (29 CFR 1910.119).
If you aren't sure whether this rule applies to
your facility or which Program (1, 2, or 3)
applies, call the EPA HOTLINE at:
(800) 424-9346 or (800) 553-7672 (TDD).
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A.2 Program Responsibilities
Once you have determined your facility's program level, the following table summarizes
what the corresponding requirements are.
Program Level
Management
System
Program 1
40 CFR 68.12 (b)
None required
Program 2 (40 CFR 68.12 (c))
&
Program 3 (40 CFR 68.12 (d))
Required
HAZARD ASSESSMENT
Worst-Case
Scenario
Alternative
Release
Five- Year
Accident History
One for each covered process.
None required.
Program 1 facilities have
certified no accidents.
One worst-case representative of all
regulated toxics and one representative of
all regulated flammables.
One for each regulated toxic and one
representative of all flammables.
Provide information for accidental releases
from covered processes that resulted in:
On-site deaths, injuries, or significant
property damage; or
Off-site deaths, injuries, evacuations,
sheltering in place, property damage,
or environmental damage.
Prevention
Program
None required.
Required.
Emergency
Response
Program
Must ensure that facility is
included in the community
emergency response plan. For
facilities with only flammables,
coordinate response actions with
local fire department.
Required if not included in Community
Emergency Response Plan.
Submit a Risk
Management Plan
Required.
Required.
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The Management System, referred to in the table on the previous page, is a requirement
for Program 2 and 3 facilities to oversee their Risk Management Program. In accordance
with 40 CFR 68.15, facilities are required to do the following:
Develop a management system to oversee implementation of the risk management
program elements;
Designate a qualified person or position with the overall responsibility for developing,
implementing, and ensuring integration of the Risk Management Program elements;
and
Document names of people or positions and define lines of authority through an
organizational chart or other similar document.
The Hazard Assessment, referred to in the table on the previous page, must include a
worst case scenario for Program 1 facilities and an offsite consequence analysis (OCA)
for each covered Program 2 or 3 process as follows:
For worst-case and alternative release scenarios, potential exposures to human
populations must be quantified and potential environmental damage must be
identified;
In accordance with 40 CFR 68.36, revised analyses and a revised Risk Management
Plan is required within six months of changes in processes or any changes that
increase or decrease the distance to an endpoint by a factor of two or more; and
Worst-case and alternative release scenarios must be reviewed and updated at least
once every five years.
Although not required, many facilities provide an accurate map showing these scenario
distances to the Local Emergency Planning Committee (LEPC) for their planning
purposes.
Facilities subject to EPA's Risk Management Program must also provide information for
any accidental releases that resulted in deaths, injuries, significant property damage,
evacuations, sheltering in place, or environmental damage.
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Hazard Assessment Resources
Risk Management Program Guidance for Off site Consequence Analysis,
available at http://www.epa.gov/ceppo/.
Appendix E of EPA's General Risk Management Program Guidance, available at
http://www.epa.gov/ceppo/.
EPA's Technical Background Document for Offsite Consequence Analysis for
Anhydrous Ammonia, Aqueous Ammonia, Chlorine, and Sulfur Dioxide (April 1999),
available at http://www.epa.gov/ceppo/.
RMP*Comp, a software program developed by the National Oceanic and
Atmospheric Administration (NOAA) and EPA, available at
http://www.epa.gov/swercepp/tools/rmp-comp/rmp-comp.html.
Facilities may choose to use publically available or proprietary air dispersion models to do
offsite consequence analysis. However, modelers should carefully review 40 CFR 68
requirements and EPA's General Risk Management Program Guidance to ensure
compliance with the required conditions.
When building a prevention program on OSHA's Process Safety Management (PSM)
standard or creating a new program, please consider:
Assessing all hazards that could affect the public or the environment offsite;
Integrating elements of the prevention program to ensure each change in any element
in the program leads to review of other elements;
Involving staff early on to secure their input in developing a concise and
comprehensive program;
Visiting facilities that have successful accident prevention programs to learn of their
implementation procedures; and
Applying inspection checklists to determine areas in need of improvement.
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Your prevention program requirements may already be satisfied if your facility is in
compliance with OSHA's PSM standard, which is the basis for the Risk Management
Program 3 with the addition of the offsite consequence analysis. Program 3 regulatory
references are listed below.
Program 2 prevention requirements address PSM elements tailored to the less complex
processes and chemical usage, and involve less documentation than Program 3. Program
2 processes demonstrate compliance by following industry standards and codes,
engineering practices, and federal and state regulations. Program 2 regulatory references
are listed below.
Prevention Program Regulatory Reference
Section
68.48
68.50
68.52
68.54
68.56
68.58
68.60
Program 2
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Compliance Audits
Incident Investigation
Section
68.65
68.67
68.69
68.71
68.73
68.75
68.77
68.79
68.81
68.83
68.85
68.87
Program 3
Process Safety Information
Processes Hazard Analysis
Operating Procedures
Training
Mechanical Integrity
Management of Change
Pre-Startup Review
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Permit
Contractors
Program 1 processes have no prevention program requirements.
Five-Year Accident History
In accordance with 40 CFR 68.42 and 68.168, a five-year accident history must be
completed and included within a facility's Risk Management Plan (RMP) if the release
caused at least one of the following:
On-site deaths, injuries, or significant property damage; or
Known off-site deaths, injuries, property damage, environmental damage,
evacuations, or sheltering in place.
The facility's RMP must be modified to include a reportable accident within six months
after its occurrence.
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A Five-Year Accident History Report must include:
Date and Time. Date and approximate time when accidental release began.
Chemical(s). Anhydrous ammonia.
Quantity Released. Estimate of amount released (using at least two significant digits
when possible).
Release Event. Identify cause of release event (e.g., gas release, liquid spill,
evaporation, fire, explosion).
Release Source. Indicate release source(s) (e.g., storage or process vessel, piping,
transfer hose, valve, pump).
Weather Conditions. On-site weather station, or the nearest weather station,
information (e.g., wind speed and direction, temperature, atmospheric stability class,
precipitation). Also, many local airports will have and provide current weather
conditions.
On-Site Impacts. On-site effects including deaths, injuries, property damage.
Known Offsite Impacts. Deaths, injuries, evacuated, sheltered, environmental
damage.
Initiating Event. Immediate cause of accident (e.g., equipment failure, human error,
weather conditions, theft).
Contributing Factors. Factors contributing to the release, but not the initiating
event. For example, equipment failure, human error, improper procedures, over
pressurization, upset condition, bypass condition, maintenance activity/inactivity,
process design, unsuitable equipment, unusual weather conditions, management error.
Offsite Emergency Responder Notifications. If known, indicate the emergency
response agencies that were contacted (e.g., police, fire, EMS, LEPC, SERC, NRC).
Changes Resulting from Accident. Measures taken to prevent recurrence (e.g.,
improved/upgraded equipment, revised maintenance, revised training, revised
operating procedures, new process controls, new mitigation systems, revised
emergency response plan, changed process, reduced inventory).
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Emergency Response Program
A facility has the option to coordinate its response with its LEPC, with the intent that the
facility employees will not be responding to an accidental release (40 CFR 68.90(b)).
If this is the case, then the emergency response program must have mechanisms in place
to notify emergency responders and the facility is not required to comply with the
requirements of 40 CFR 68.95, as described below.
If the facility employees will be responding to the emergency, Program 2 and Program 3
facilities and its employees must follow the steps outlined in the emergency response
program (40 CFR 68.95). The facility must have:
Procedures for informing the public and local emergency response agencies about
accidental releases;
Documentation of proper first-aid and emergency medical treatment for accidental
human exposure;
Procedures and measures for emergency response after an accidental release;
Procedures for using and maintaining emergency response equipment;
Training for employees in their emergency response responsibilities; and
Procedures to review and update the emergency response plan.
Emergency response plans developed to comply with other federal contingency
planning requirements can meet the above requirements if they include the 40 CFR Part
68 required elements. The emergency response plan must be facility-specific. It must be
maintained and kept at the facility.
For more information on emergency response, see Appendix B.
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A.3 Additional Risk Management Plan Information
Registration
Each registration must include, but is not limited to:
Facility Name and Address;
Contact Person at Facility;
Names and Quantities of Regulated Chemicals On-Site; and
NAICS Code (information on NAICS codes may be found at:
www.census.gov/epcd/www/naics.html. Click on NAICS under the "Business"
heading.)
RMP Updates and Resubmittals
A facility must update and resubmit its RMP within six months of:
A change that requires a revised off-site consequence analysis (40 CFR 68.36);
A change that requires a revised hazard review or process safety analysis;
A change that results in a change in program level of a covered process. The
implementing agency for this regulation can ask the facility to revise the RMP under
the audits provisions of 40 CFR 68.220. RMPs must be revised and resubmitted at
least once every five years; or
The date of an accident that meets the criteria for the five year accident history after
April 9, 2004.
A facility must update and resubmit its RMP within one month of:
A change of the emergency contact information.
Facilities no longer covered under the RMP rule, must submit a "de-registration" to EPA
within six months of not being subject in accordance with the provisions of 40 CFR
68.190(c). (See Chapter 8 of RMP*Submit User 2004 Manual. The RMP Submit 2004
Software may be downloaded at: www.epa.gov/ceppo/. Click on "Chemical Preparedness
and Prevention","Tools & Resources", "Databases and Software", "EPA Databases and
Software", then "RMP Submit 2004.")
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Additional RMP Resources
RMP guidance documents and training modules are available through the following
sources:
EPA's Chemical Emergency Preparedness and Prevention Office at
www.epa.gov/swercepp/acc-pre.html:
EPA's EPCRA Hotline at (800) 535-0202; or
EPA's Technology Transfer Network at www.epa.gov/ttn.
Confidential Business Information
Facilities can claim some RMP information as confidential business information (CBI).
Once claimed, EPA will make a determination of the validity of the facility's CBI claim.
If EPA determines that the information is not CBI and has notified the facility, the
information may be released. If EPA determines that the information is CBI, then a local
emergency planning committee (LEPC) may be able to obtain the information under 40
CFR 2.301(h)(3). That regulation provides for sharing of CBI with state and local
agencies having responsibilities under CAA or its implementing regulations. LEPCs can
only gain access to CBI data under this rule if they can protect its confidentiality.
Under EPCRA Section 303(d)(3), LEPCs may compel an EPCRA Section 302 facility to
provide any information necessary to develop and implement a community emergency
plan. An EPCRA Section 302 facility must comply with such LEPC requests for
information even if the facility has made a valid CBI claim.
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APPENDIX B - EMERGENCY PLANNING
B.I Emergency Response Program Development
An emergency response program should be proactive and ongoing. EPA interprets
"response" to be consistent with OSHA's HAZWOPER Standard (29 CFR 1910.120).
OSHA defines emergency response as, "a response effort by employees from outside the
immediate release area or by other designated responders...to an occurrence which
results, or is likely to result, in an uncontrolled release of a hazardous substance."
(Note that responders are designated for such tasks by the facility.)
Any spill of anhydrous ammonia, regardless of quantity, will require a "response" effort
due to immediate ammonia volatilization, the hazardous nature of ammonia gas
dispersing into the environment, and human health risks to on-site and off-site people.
Response Program Development should involve:
Systematic Planning;
Local Emergency Medical Service (EMS) Personnel; and
Consideration of Counter-terrorism (CT) Measures.
Response actions during the first few minutes of an ammonia release are the most critical.
They should not only be planned, but also well rehearsed to minimize the impact of a
release. Facilities that take a comprehensive approach in developing a facility-specific
emergency response program are better prepared to respond in a release event.
An emergency response plan outlines the action and equipment necessary for
effective emergency response. However, a facility must conduct training, evaluate
its program, maintain emergency equipment, and regularly coordinate with local
agencies in order for an emergency response plan to be useful in an emergency.
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Systematic Planning
The following outline is an approach to an emergency response program. These proactive
efforts should enable a facility to efficiently integrate facility-specific information, key
technical and management resources, and relevant existing emergency response programs
that may require coordination.
1. Identify Federal, State, and Local Regulations Relevant to Emergency Responses
for Ammonia Releases
Applicable regulations and guidance documents need to be identified for the
development of your facility emergency response program. Facilities are encouraged
to contact the EPA Hotline at 1-800-424-9346 or 703-412-9810 for assistance with
identifying appropriate Federal and State regulations.
2. The Program Development Team
A facility should select a team of employees who bring expertise from each of its
functional areas. Ideally, the team members should also have varying degrees of
emergency response responsibilities and experience within and outside the subject
facility. A three-member team for a small facility may involve a couple of process
operators who are cross-trained as emergency responders. A large facility with its
own response team may need representatives from the following areas:
Maintenance;
Operations or Production Personnel;
Process or Upper Management;
Legal or Public Affairs;
Fire and Hazmat Response;
Environmental, Health, and Safety;
Security;
Emergency Coordinator; and
Labor Relations or Personnel.
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3. Collect Existing Facility-Specific Documents and Information
Members of the development team should collect, review, and maintain copies of the
following types of facility-specific materials:
Site plans;
Existing emergency plans or procedures;
Submissions to the LEPC;
Hazard evaluation and release modeling information;
Hazard communication and emergency response training;
Emergency drill and exercise programs;
After-action reports and response critiques; and
Mutual aid agreements.
The team may also identify related program materials from the following sources:
Corporate and industry sponsored safety, training, and planning efforts; and
Federal, state, and local government safety, training, and planning efforts.
Under CAA Section 112(r)(l), facilities have a general duty:
to identify hazards which may result from releases using appropriate hazard
assessment techniques;
to design and maintain a safe facility, taking such steps as are necessary to prevent
releases; and
to minimize the consequences of accidental releases, which do occur.
Under this "General Duty Clause", facilities are responsible for ensuring that any
process release can be effectively handled. Facilities relying on local responders must
determine if the local responders have suitable equipment and training. If they do not,
the facility must take steps to meet any needs (e.g., develop facility response
capabilities, develop mutual aid agreements, hire response contractors, partially fund
local responders).
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4. Identify Emergency Response Gaps
Using the information collected, the team or a leadership subset should assess
compliance with each emergency response program element of EPA's Risk
Management Program (40 CFR Part 68). This assessment will expose gaps that exist.
Facilities in compliance with OSHA's HAZWOPER Standard will typically already
satisfy most or all of EPA's requirements. An assessment of the gaps will help the
team focus their efforts. (Note: Even if a facility is in compliance with OSHA's
HAZWOPER Standard, submission of a Risk Management Plan to the EPA is
required in accordance with 40 CFR Part 68.)
5. Tailor Emergency Response Program to Facility-Specific Hazards
Since hazards of using anhydrous ammonia are significant and all processes and
chemicals at a facility pose a variety and range of hazards, it is necessary to tailor
elements of an emergency response program to facility-specific hazards.
Some common considerations of facility-specific hazards include the facility's
susceptibility to the following:
Fires, spills, and vapor releases;
Floods, temperature extremes, tornadoes,
earthquakes, and hurricanes;
Loss of utilities (including power failures
and brown-outs);
Train derailments, vehicle accidents,
bomb threats, and other man-made
disasters; and
Chemical incompatibilities; e.g. ammonia and chlorine.
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6. Integrate Emergency Response Program Across Existing Plans
Many federal statutes and regulations require emergency response planning.
Development of plans for specific responses can leave personnel and emergency
responders confused. Consistent with the Integrated Contingency Plan (ICP)
Guidance's outline, many facilities have developed an ICP to consolidate emergency
response plans into a single response plan. Here is a suggested ICP format:
Introduction
Background Information
Facility Overview
Scope and Objective of ICP
Core Emergency Response Plan
Essential procedures to initiate, conduct, and terminate an emergency response
Procedures for emergency recognition, notification, and initial response (e.g.,
assessment, mobilization, implementation)
Supporting Annexes
Key supporting information and information required for regulatory compliance
S Emergency Response Teams
»/ External Notification
S Evacuation Assembly Areas
»/ Emergency Response Equipment
S Incident Command
/ SPCC Plans
The National Response Team (NRT), a multi-agency group chaired by EPA,
published ICP Guidance in the Federal Register (61 FR 28642) on June 5, 1996. The
guidance provides a mechanism for consolidating multiple plans, prepared to comply
with various regulations, into a single, functional emergency response plan or ICP.
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7. Prepare Written Emergency Procedures
Ammonia refrigeration facilities operate under conditions where a rapid shutdown can
create further hazards if not done properly. In accordance with 40 CFR 68.52 (b)(4)
and 40 CFR 68.69(a)(iv), facilities are required to prepare written emergency
shutdown procedures and instructions for use by operators, emergency responders,
and others. At a minimum, these materials should be developed for each of the most
likely emergency scenarios (e.g., power failure, fire event). In particular, each facility
should prepare specific materials for reference during an ammonia release. These
materials should include the following:
A manual of operating instructions,
A system drawing showing the integral parts and their locations at the facility,
The procedure to shut down the refrigeration unit for an extended period of time,
Emergency shut-down procedures and subsequent start-up procedures,
A table of the ranges of safe operating parameters measured at crucial meter
locations,
Safety procedures to be exercised at various locations, and
Locations for recharging the system as well the specifications of the charge
materials.
EPA suggests that a facility develop an emergency response chart (an example is
provided below.) An emergency response chart may help emergency responders or
the facility's security guard to close specific ammonia valves in the immediate
vicinity of the ammonia detectors tripped by an ammonia release.
Example Emergency Response Chart
Ammonia Alarm
Compressor Room 2W
Compressor Room 2E
Receiving Dock Area
Warehouse Area A
Warehouse Area B
Emergency Action
Close Valves C3 & C7
Close Valves C8 & C9
Close Valve A & Door 3
Close Valves W5 & W6
Close Valves W7 & W8
APPENDIX B - EMERGENCY PLANNING
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8. Develop and Maintain Emergency Tools
There are a number of tools that can be used to
assist in a more orderly response during an
emergency.
One such tool in the event of an accidental release
of anhydrous ammonia is a wind sock. A wind sock
can be an extremely helpful emergency tool as it
can help determine wind direction and approximate
wind speed at a glance. This information will help
determine which direction the ammonia is heading
and help estimate approximate distance of the
release. Facilities should mount wind socks in
appropriate places and incorporate their use in their
emergency response plan.
Some facilities have developed posters and signs with information for employees and
emergency responders. Development of these materials should ensure they will be
effective for the intended people (e.g., other languages, appropriate reading level,
locations of signs relative to hazards and emergency exits). For example: the
significance of the position of the windsock and its implications relative to evacuation
routes should be discussed with all staff members so that an orderly emergency
response will result.
As mentioned previously, ammonia detectors with alarms are an essential emergency
tool to help monitor all systems with anhydrous ammonia.
P&IDs, process flow diagrams, ladder/logic diagrams, or single line diagrams should
be kept up to date and incorporated into operator training programs. Some facilities
laminate the P&IDs and/or ladder/logic diagrams and then post them adjacent to the
equipment and store a copy with on-site emergency response equipment and plans.
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Role of Emergency Medical Service (EMS) in Planning
In an emergency, an integrated emergency medical response is critical. People seriously
injured by a hazardous material have a greater chance of recovery when;
Appropriate emergency treatment is provided by prepared EMS personnel at the
scene;
The patient is transported to a facility having the most appropriate personnel and
technical resources; and
Communication with the medical facility is open to relay information regarding the
material impacting the patient.
EMS agencies are a crucial link in the
community response system that responds
to a facility incident. EMS personnel are
often the first to arrive at an incident scene.
They must be able to assess the nature of
the hazard while attending to the immediate
needs of victims.
The absence of EMS personnel in
emergency response planning has resulted
in the following types of problems:
Incidents have been poorly managed by
facility personnel and first responders;
Communication channels have been ineffective and/or sometimes redundant between
private and public sectors;
Medical facilities have not been adequately prepared to treat or manage incoming
patients involved in hazardous materials incidents; and
Medical staff are not informed as to the lethal effects of a chemical release.
EMS personnel reinforce the importance of defining safe response scenarios, medical
practices, and transportation guidelines in the event of an emergency. They will also be a
critical link in the collaboration with other response agencies (e.g., police and fire
departments) and hospitals.
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EMS personnel should also participate in annual disaster drills and emergency plan
reviews, helping to ensure that each emergency response plan is effective and benefits
from lessons learned during other emergency events.
Your State Emergency Response Commission (SERC) and your Local Emergency
Planning Committee (LEPC) play extremely important roles in Emergency Response
Planning. Their roles are:
SERC
Establish local emergency planning districts
Establish procedures for handling public requests for information
Appoint and oversee LEPCs
Review LEPC emergency plans
LEPC
Prepare and maintain a comprehensive emergency response plan for the district
Provide hazardous chemical data to the public
Respond or coordinate response
In accordance with 40 CFR 355.30, facilities that use or store more than 500 pounds
of anhydrous ammonia are required to notify the SERC and LEPC. These facilities
must appoint a liaison from the facility and work with the LEPC to include facility-
specific emergency response information into the comprehensive emergency response
plan.
Counter-Terrorism (CT) Measures
Before specifically considering CT, a facility should ensure their emergency plan is up to
date. Simply adding CT materials to an outdated plan will not produce an effective
emergency plan. For example, review of an emergency plan sometimes identifies
outdated emergency contact information or process modification and facility construction
that had not yet been addressed. After updating an emergency plan, a facility should
consider adding information and procedures related to potential terrorist threats.
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Each facility should review their emergency response plan based on the following
considerations:
Emergency Contact Information
The National Response Center (NRC) is the sole Federal point of contact for reporting
chemical spills/releases, including anhydrous ammonia. NRC Duty Officers take reports
of actual or potential terrorism, then link emergency calls to the following:
Department of Defense (for technical advice on dealing with weapons of mass
destruction), and
Federal Bureau of Investigation (to initiate Federal response actions and incident
investigations).
Response Functions
An emergency response plan should clearly define responsibilities in an event. The plan
should indicate how response functions change if an emergency occurs as the result of a
known or suspected terrorist event. For example, an Incident Command System will
likely transition to a Unified Command structure. The change in response leadership is
typically necessary to accommodate emergency response efforts that involve mutual-aid
partners, and State and Federal responders.
Hazards Analysis
While reviewing the hazards analysis portion of an emergency response plan, weapons of
mass destruction (e.g., explosive, chemical, biological, and nuclear) should be
considered. A facility could identify potential targets and their vulnerability to attack.
Such a review should result in improvements to help ensure a facility is adequately
protected. The emergency response plan should not include details of the security
system(s) as the information is generally made publically available.
APPENDIX B - EMERGENCY PLANNING
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Mitigation Procedures
Procedures included in an emergency response plan should involve consequence
management efforts. The mitigation activities should be designed to protect workers and
the public from further exposure to hazards. In general, public health officials, EMS
personnel, and criminal investigators should work together to identify and mitigate
hazards following an event. The emergency plan could include a list of basic questions to
ask victims, impacted emergency responders, and other individuals in the affected
population. Information and effective communication are critical in identifying and
mitigating effects of a terrorist incident.
Active and passive mitigation systems should be considered. Passive mitigation means
equipment, devices, or technology that function without human, mechanical, or other
energy input. Examples of passive mitigation include dikes and enclosed systems.
Active mitigation means equipment, devices, or technologies that need human,
mechanical, or other energy input to function. Examples of active mitigation include
interlocks, shutdown systems, pressure-relieving devices, flares, emergency isolation
systems, and fire protection systems.
The system design, location, operating procedures, and emergency response procedures
should be taken into consideration when determining the mitigation system to use. The
design of the mitigation system should consider the different factors that would influence
the system operation and potential release scenarios.
B.2 Emergency Planning and Response Guidance
For further assistance in developing your emergency response program, the following
materials are available:
Criteria for Review of Hazardous Materials Emergency Plans (NRT-1A), National
Response Team, May 1988.
Provides evaluation criteria for emergency response plans.
Emergency Response Guidebook, U.S. Department of Transportation, 2000.
Lists over 1,000 hazardous materials and provides general hazard information and
recommended isolation distances.
Hazardous Materials Emergency Planning Guide (NRT-1), National Response
Team, 1987.
Designed to assist communities in planning for hazardous materials incidents, and
includes useful information on planning teams, plan review, and ongoing planning
efforts.
APPENDIX B - EMERGENCY PLANNING
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Hazardous Materials Guide for First Responders, Federal Emergency Management
Association and U.S. Fire Administration, 1998.
Includes specific emergency response procedures for anhydrous ammonia releases.
LEPCs and Deliberate Releases: Addressing Terrorist Activities in the Local
Emergency Plan, EPA 550-F-01-005, August 2001.
Discusses how counter-terrorism (CT) measures can be incorporated into emergency
planning.
NIOSH Pocket Guide to Chemical Hazards, NIOSH Publication No. 2000-130, July
2000.
Provides ten relevant databases, including recommendations for chemical protective
clothing, toxicologic chemical reviews, and the 2000 Emergency Response
Guidebook.
Integrated Contingency Plan, National Response Team, 61 FR 28642, June 5, 1996.
Guidance on consolidating multiple plans into a single, functional emergency
response plan that complies with various federal regulations.
B.3 Practicing Your Plan
In addition to planning, effective responses
to ammonia releases require practice.
Emergency responders must practice
evaluation, isolation, containment and
mitigation to prevent catastrophic releases.
The following should be reviewed and
practiced, as applicable, on a regular basis:
Typical Anhydrous Ammonia
Accidents
Exposure Limits For Ammonia
Risk Management Program Requirements under Part 68 of the Clean Air Act
APPENDIX B - EMERGENCY PLANNING
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Inspect Emergency Equipment
Emergency equipment should be inspected regularly to
ensure respirators and other equipment are available,
accessible, and usable. Air-purifying respirators must
have appropriate and unexpired cartridges. They must
only be used in an ammonia atmosphere less than 300
ppm. Self-contained breathing apparatus (SCBA) air
should be suitable for the temperature in which the
SCBA will be worn. Facilities should also
periodically verify that onsite response personnel are
trained and fit tested for the proper use of the
emergency equipment.
Inspect Emergency Equipment
Regularly
Establish Emergency Shutdown Procedures
Establish emergency shutdown procedures and instructions on what to do during and
after a power failure.
Conducting Emergency Response Drills
Regular emergency response drills should be conducted at all facilities using
ammonia refrigeration systems. All emergency responders (onsite and offsite) should
"suit up" as part of each drill event.
Several facilities are beginning to stage realistic response exercises with their local
fire department or their hazmat emergency response team. The response drills should
all be announced and involve preplanning to ensure they are realistic but different
from recent drills.
Facilities have used regular emergency response drills to maintain and increase public
awareness of ammonia situations. Facilities may involve citizens in the immediate
vicinity of their property. Emergency response and preparedness brochures may be
distributed to nearby residences and businesses.
Emergency Responders are reminded that ammonia can be replaced - lives
cannot! Offensive actions that threaten responder's lives should not be
attempted unless other lives are in danger. The best practice is to safely
evacuate an area until the ammonia dissipates.
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APPENDIX C - EMERGENCY FIRST AID FOR AMMONIA
EXPOSURES
This is an Emergency First Aid Treatment Guide for Ammonia (CAS: 7664-41-7). This guide
and similar information are available from the EPA at www.epa. gov/swercepp/.
Disclaimer
This guide should not be construed to authorize emergency personnel to perform the procedures or
activities indicated or implied. Care of persons exposed to toxic chemicals must be directed by a physician
or other recognized authority.
Signs and Symptoms of Acute Ammonia Exposure
Warnings:
Ammonia is extremely corrosive to the skin, eyes, and mucous membranes.
Contact with the liquified gas may cause frostbite.
Caution is advised.
Inhalation of ammonia may cause irritation and burns of the respiratory tract, laryngitis, dyspnea
(shortness of breath), strider (high-pitched respirations), and chest pain. Pulmonary edema and
pneumonia may also result from inhalation. A pink frothy sputum, convulsions, and coma are
often seen following exposure to high concentrations. When ammonia is ingested, nausea and
vomiting may result; oral, esophageal, and stomach burns are common.
If ammonia has contacted the eyes, irritation, pain, conjunctivitis (red, inflamed eyes),
lacrimation (tearing), and corneal erosion may occur. Loss of vision is possible. Dermal
exposure may result in severe burns and pain.
Emergency Life-Support Procedures
Acute exposure to ammonia may require decontamination and life support for the victims.
Emergency personnel should wear protective clothing appropriate to the type and degree of
contamination. Air-purifying or supplied-air respiratory equipment should also be worn, as
necessary.
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Inhalation Exposure
1. Move victims to fresh air. Emergency personnel should avoid self-exposure to ammonia.
2. Evaluate vital signs including pulse and respiratory rate, and note any trauma. If no pulse is
detected, provide CPR. If not breathing, provide artificial respiration. If breathing is labored,
administer oxygen or other respiratory support.
3. Obtain authorization and/or further instructions from the local hospital for administration of
an antidote or performance of other invasive procedures.
4. Transport to a health care facility.
Dermal Exposure
1. Remove victims from exposure, while avoiding self-exposure to ammonia.
2. Rinse the exposed area with generous amounts of water for at least 15 minutes.
3. Warning: Do not attempt to neutralize with an acid wash; excessive liberation of heat
may result.
4. Evaluate vital signs including pulse and respiratory rate, and note any trauma. If victim is not
breathing, provide artificial respiration. If victim's breathing is labored, administer oxygen
or other respiratory support. If no pulse is detected, provide CPR.
5. Remove contaminated clothing as soon as possible, after generously rinsing with water for at
least 15 minutes. Be aware that ammonia may cause clothes to freeze to skin.
6. Obtain authorization and/or further instructions from the local hospital for administration of
an antidote or performance of other invasive procedures.
7. Transport to a health care facility.
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Eye Exposure
1. Remove victims from exposure, while avoiding self-exposure to ammonia.
2. IMMEDIATELY flush eyes with lukewarm water for at least 30 minutes.
3. Evaluate vital signs including pulse and respiratory rate, and note any trauma. If victim is not
breathing, provide artificial respiration. If victim's breathing is labored, administer oxygen
or other respiratory support. If no pulse is detected, provide CPR.
4. Obtain authorization and/or further instructions from the local hospital.
5. Transport victim to a health care facility.
Ingestion Exposure
1. Evaluate vital signs including pulse and respiratory rate, and note any trauma. If no pulse is
detected, provide CPR. If not breathing, provide artificial respiration. If breathing is labored,
administer oxygen or other respiratory support.
2. DO NOT induce vomiting or attempt to neutralize!
3. Obtain authorization and/or further instructions from the local hospital for administration of
an antidote or performance of other invasive procedures.
4. Activated charcoal does not strongly bind ammonia, and therefore is of little or no value.
5. Give the victims water or milk: children up to 1 year old, 125 mL (4 oz or 1/2 cup); children
1 to 12 years old, 200 mL (6 oz or 3/4 cup); adults, 250 mL (8 oz or 1 cup). Water or milk
should be given only if victims are conscious and alert.
6. Transport to a health care facility.
APPENDIX C - EMERGENCY FIRST AID FOR AMMONIA EXPOSURES
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APPENDIX D - DEFINITIONS OF ACRONYMS
ACGIH American Conference of Government Industrial Hygienists
AIHA American Industrial Hygiene Association
ANSI American National Standards Institute
ARTD/CRIB Air, RCRA, and Toxics Division / Chemical Risk Information Branch
ASHRAE American Society of Heating, Refrigerating and Air-Conditioning Engineers
ASME American Society of Mechanical Engineers
ASTM American Society of Testing Materials
ATSDR Agency for Toxic Substances and Disease Registry
CAA Clean Air Act
CAS Chemical Abstracts Service
CBI Confidential Business Information
CEPPO Chemical Emergency Preparedness and Prevention Office
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act (or "Superfund")
CFCs Chlorofluorocarbons
CFR Code of Federal Regulations
CT Counter-Terrorism
CWA Clean Water Act
DOT U.S. Department of Transportation
EMS Emergency Medical Service
EPA U.S. Environmental Protection Agency
EPA HQ U.S. Environmental Protection Agency Headquarters
EPCRA Emergency Planning and Community Right-To-Know Act
ERPGs Emergency Response Planning Guidelines
FR Federal Register
GARP Georgia Ammonia Refrigeration Program
GPO Government Printing Office
HAZMAT Hazardous Materials
HAZWOPER Hazardous Waste and Emergency Operations
HCFC Hydrochloroflurocarbon
ICP Integrated Contingency Plan
IDLH Immediately Dangerous to Life and Health
IIAR International Institute of Ammonia Refrigeration.
IRC Industrial Refrigeration Consortium
ISO International Standards Organization
LEPC Local Emergency Planning Committee
MSDS Material Safety Data Sheet
NAICS North American Industry Classification System
NFPA National Fire Protection Association
NIOSH National Institute for Occupational Safety and Health
NH3 Ammonia
NOAA National Oceanic and Atmospheric Administration
NRC National Response Center
NRT National Response Team
NSC National Safety Council
NSCEP National Service Center for Environmental Publications
NTIS National Technical Information Service
ODS Ozone-Depleting Substance
OPA Oil Pollution Act
OSHA Occupational Safety and Health Administration
OSHRC Occupational Safety and Health Review Commission
OSWER Office of Solid Waste and Emergency Response
APPENDIX D - DEFINITIONS OF ACRONYMS
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P&IDs Piping and Instrumentation Diagrams
PEL Permissible Exposure Limit
PHA Process Hazard Analysis
PRV Pressure Relief Valve
PSM Process Safety Management
RCRA Resource Conservation and Recovery Act
RETA Refrigeration Engineers Technicians Association
RMP Risk Management Plan
RQ Reportable Quantity
SCBA Self-contained Breathing Apparatus
SERC State Emergency Response Commission
SIC Standard Industrial Classification
SOPs Standard Operating Procedures
SPCC Spill Prevention, Control and Countermeasures
STEL Short Term Exposure Limit
TDD Telephone Device for the Deaf
TPQ Total Planning Quantity
TRI Toxic Release Inventory
UST Underground Storage Tank
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APPENDIX E - EDUCATION AND INFORMATION RESOURCES
This information is not intended to be all-inclusive or definitive, but it should provide a good
starting point for finding relevant materials. Although the industry standards information
represent good engineering practices, they are not subject to being "adopted" by EPA or OSHA.
The listings in Appendix E do not constitute EPA endorsement.
Education and Training
Refrigerating Engineers Technicians Association (RETA) offers self-study materials and
a tiered certification/evaluation program for refrigeration technicians/mechanics. Call (847)
375-4738 or visit www.reta.com for additional information.
Industrial Refrigeration Consortium (IRC) at the University of Wisconsin-Madison
offers educational opportunities. Call (608) 262-8220 or visit www.irc.wisc.edu for
additional information.
International Institute of Ammonia Refrigeration (IIAR) offers ammonia refrigeration-
related educational videos, short courses, technical publications, and an annual conference.
Call (703) 312-4200 or visit www.iiar.org for additional information
Georgia Ammonia Refrigeration Program (GARP) at the Lanier Technical College
offers hands-on training oriented toward operators of industrial ammonia refrigeration
systems, and PSM/RMP implementation classes. Call (770) 531-4500 or visit
www.garpltc.com for additional information.
Garden City Community College offers hands-on training oriented toward operators of
industrial ammonia refrigeration systems, and PSM/RMP implementation classes.
Call (620) 276-9520 or visit www.nh3gccc.com for additional information.
Garden City Ammonia Program provides training for the industrial ammonia refrigeration
operator for efficiency, safety, and compliance. Call (620) 271-0037 or visit
www.ammoniatraining.com for additional information.
Industry Standards
American National Standards Institute (ANSI) at (202) 857-1110 or www.ansi.org
"^ Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems
(ANSI/EAR 2, 1992)
"^ Mechanical Refrigeration and Air Conditioning Installations Aboard Ships
(ANSI/ASHRAE 26, 1996)
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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American Society of Heating, Refrigerating and Air-Conditioning Engineers
(ASHRAE)
"^ ASHRAE Handbook (1998) covers refrigeration systems for applications other than
human comfort.
^ Safety Code for Mechanical Refrigeration, ANSI/ASHRAE 15 - 1999 (not applicable to
ammonia manufacturing plants) is available for purchase from ASHRAE at (800) 527-
4723.
American Society of Mechanical Engineers (ASME)
"^ Boiler & Pressure Vessel Code (Section V Nondestructive Examination and Section Vm
Pressure Vessels)
"^ Refrigeration Piping Code (ASME B 31.5-1992)
Compressed Gas Association G-2 Anhydrous Ammonia (1995).
Factory Mutual Property Loss Prevention Data Bulletin 12-61 (April 1993) and Data Sheets
7-13 (1998).
International Institute of Ammonia Refrigeration (IIAR) has published a number of
reference materials and industry standard bulletins for the design, operation, and maintenance
of ammonia refrigeration systems. Call (703) 312-4200 or visit www.iiar.org for additional
information.
ISO 5149 (1993) (Mechanical Refrigerating Systems Used for Cooling and Heating - Safety
Requirements) is available from ANSI at (212) 642-4900 or www.ansi.org^
Refrigeration Engineers Technicians Association (RETA) has compiled and can provide
relevant information about ammonia refrigeration industry standards. The association is
currently involved in working with other trade associations and the educational community
through colleges to develop a "National Skills Standard" for an ammonia engine room
operator. RETA can be contacted at (847) 375-4738.
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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Information Sources
The Center for Disease Control's Emergency Preparedness and Response website is:
http://www.bt.cdc.gov/
EPA's Chemical Emergency Preparedness and Prevention Office (CEEPO) can provide
the following:
"^ Chemical Safety Alert regarding Hazards of Ammonia Releases (refer to Appendix H of
this manual).
^ General advisory on ammonia (OSWER 91-008.2 Series 8 No. 2) at
www.epa. gov/ceppo/add-his .html.
"^ Risk Management Plans for participating anhydrous ammonia facilities at www.epa.gov/
ceppo/lepclist.htm.
"^ Model Risk Management Program for ammonia refrigeration facilities available at
www.epa/gov/swercepp/acc-pre.htm#modelplans/.
EPA's National Compliance Assistance Clearinghouse offers a single repository of
directories to Federal, State, local, and other compliance assistance providers at
www.epa.gov/clearinghouse or (202) 564-7071.
EPA's National Response Center (NRC) serves as the sole federal point of contact for
reporting all oil, chemical, and other discharges in the environment anywhere in the United
States and its territories. The NRC phone number is (800) 424-8802. Additional NRC
information is available at www.epa. gov/oilspill/.
EPA's RCRA/UST, Superfund and EPCRA Hotline for a wide variety of technical
assistance materials and answers to specific questions at (800) 424-9346 or (703) 412-9810;
also www.epa/gov/ epaoswer/hotline.
Industrial Refrigeration Consortium (IRC) at the University of Wisconsin-Madison
offers refrigeration-related resources. Call (608) 262-8220 or visit www.irc.wisc.edu for
additional information.
National Service Center for Environmental Publications (NSCEP) at (800) 490-9198 and
www.epa.gov/ncepihom/index.html.
National Technical Information Service (NTIS) at (800) 553-6847 or (703) 605-6000 and
www.ntis.gov.
Nationwide database of LEPCs and SERCs can be found at the Right-to-Know network
www.rtknet.org/lepc.
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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OSHA can provide the following:
"^ Ammonia refrigeration and process safety at www.slc.osha-slc.gov/SLTC/
ammoniarefrigeration/index.html.
"^ Searchable database providing accident summaries at www.osha.gov/oshstats^
"^ Hazard information bulletins are available at www.osha-slc.gov/dts/hib/.
"^ Standard interpretations and compliance letters specifically relevant to anhydrous
ammonia facilities, including: Ventilation for an Anhydrous Ammonia Refrigeration
System, Training for Plant Maintenance Personnel and HAZWOPER, Back-Welding of
Threaded Connections in Anhydrous Ammonia Service, Respiratory Protection for
Anhydrous Ammonia Storage Installations, and Fires Involving Spills or Releases of
Hazardous Substances are available at www.osha-slc.gov/OshDoc/Interp data/.
Occupational Health and Safety Engineering Data Sheet 4-04 (anhydrous ammonia) at
www.govonca3.gov.o.ca/lab/main.htm
Occupational Safety and Health Review Commission (OSHRC) posts OSHA decisions
that are keyword searchable by year at http://www.oshrc.gov/decisions/decisions.html.
U.S. Government Printing Office (GPO) at (202) 512-1800 or www.gpo.gov.
References
Accident Prevention and Emergency Preparedness for Agricultural Anhydrous Ammonia
Systems, U.S. Environmental Protection Agency, Region 6 Response and Prevention Branch,
October 2001.
Ammonia Data Book, International Institute of Ammonia Refrigeration, 1997.
Ammonia Refrigeration Piping Handbook, International Institute of Ammonia Refrigeration),
2000.
Ammonia Refrigeration: A Perspective from 75 Years of Experience, Milton Garland, Frick
Company, NH3 News (A publication of the International Institute of Ammonia Refrigeration),
Fall 2000.
Anhydrous Ammonia Theft, U.S. Environmental Protection Agency, EPA-F-00-005, March 2000.
Annual Report on Enforcement and Compliance Assurance Accomplishments in 1999, U.S.
Environmental Protection Agency, EPA 300-R-00-005, July 2000.
ANSI A 13.1-1981R 1985, Scheme for the Identification of Piping Systems, American National
Standards Institute (ANSI), New York, NY 10036.
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
ANSI K61.1, 1999, Standards for the Storage and Handling of Anhydrous Ammonia, American
National Standards Institute (ANSI), New York, NY 10036.
ANSI/IIAR 2-1992, Equipment, Design, and Installation of Ammonia Mechanical Refrigeration
Systems, American National Standards Institute (ANSI), New York, NY 10036, and International
Institute of Ammonia Refrigeration (IIAR), Washington, DC 22036.
Chemical Accident Prevention and the Clean Air Act Amendments of 1990, U.S. Environmental
Protection Agency, EPA 550-F-96-004, May 1996.
Chemical Accident Prevention: Site Security, U.S. Environmental Protection Agency,
EPA 550-F-00-002, February 2000.
Chemical Accident Risks in U.S. Industry - A Preliminary Analysis of Accident Risk Data from
U.S. Hazardous Chemical Facilities, James C. Belke, U.S. Environmental Protection Agency,
September 25, 2000.
Chemical Safety Network Publications, National Service Center for Environmental Publications.
Clean Air Act Section 112(r), U.S. Environmental Protection Agency, EPA 550-F-96-005,
May 1996.
Compliance Assistance Activity Plan, Fiscal Year 2001, U.S. Environmental Protection Agency,
EPA 305-R-01-002, April 2001.
Control and Pollution Prevention Options from Ammonia Emissions, U.S. Environmental
Protection Agency, EPA 456-R-95-002, April 1995.
Create Your Own Workshop: Ammonia Risk Management Program "Plan in Hand" Training for
Small Businesses, U.S. Environmental Protection Agency.
Criteria for Review of Hazardous Materials Emergency Plans (NRT-1A), National Response
Team, May 1988.
Emergency Response Guidebook, U.S. Department of Transportation, 2000.
Explosion in Cold Storage Kills Fire Fighter, Thomas J. Klem, National Fire Protection
Association Journal, March 1985.
Hazardous Materials Emergency Planning Guide (NRT-1), National Response Team, March
1987.
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Hazardous Materials Guide for First Responders, Federal Emergency Management Agency and
United States Fire Administration.
Hazardous Substance Fact Sheet, New Jersey Department of Health and Senior Services, June
1998.
Hazards of Ammonia Releases at Ammonia Refrigeration Facilities (Update), U.S.
Environmental Protection Agency, EPA 550-F-01-009, August 2001.
IIAR Bulletin 114, 9/91, Guidelines for Identification of Ammonia Refrigeration Piping and
System Components, International Institute of Ammonia Refrigeration.
Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, 60
FR 66706, December 22, 1995.
Integrated Contingency Plan, National Response Team, 61 FR 28642, June 5, 1996.
LEPCs and Deliberate Releases: Addressing Terrorist Activities in the Local Emergency Plan,
U.S. Environmental Protection Agency, EPA 550-F-01-005, August 2001.
Leveling the Playing Field: Eliminating the Economic Benefit of Violating Environmental Laws,
U.S. Environmental Protection Agency, EPA 300-F-00-002, May 2000.
Loss Prevention Data Bulletin 12-61, Factory Mutual, April 1993.
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Protection Agency, EPA 305-B-99-005, March 1999.
NIOSH Pocket Guide to Chemical Hazards and Other Data Bases, National Institute for
Occupational Safety and Health, DHHS Publication No. 2000-130, July 2000.
Owners, Operators of Stationary Sources Must Comply with Clean Air Act's "General Duty"
Clause, U.S. Environmental Protection Agency, EPA 300-N-98-006, August 1998.
Preventing Accidental Releases Under the Clean Air Act, Kansas Small Business Environmental
Assistance Program, November 1999.
Recent Changes to the Risk Management Program Rule, U.S. Environmental Protection Agency,
EPA 550-F-98-022, December 1998.
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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Accident Prevention and Response Manual for Anhydrous Ammonia Refrigeration System Operators
U.S. Environmental Protection Agency Region 7
Risk Management Planning: Accidental Release Prevention, Final Rule: Clean Air Action
Section 112(r), U.S. Environmental Protection Agency, EPA 550-F-96-002, May 1996.
Risk Management Program (RMP) Audit Program, U.S. Environmental Protection Agency, EPA
550-F-00-010, August 2000.
Risk Management Program Guidance for Ammonia Refrigeration (40 CFR Part 68), U.S.
Environmental Protection Agency, EPA 550-B-00-006, May 2000.
RMPs Are on the Way!, How LEPCs and Other Local Agencies Can Include Information from
Risk Management Plans in Their Ongoing Work, U.S. Environmental Protection Agency, EPA
550-B99-003, November 1999.
SARA Title III Fact Sheet, Emergency Planning and Community Right-To-Know Act, U.S.
Environmental Protection Agency, EPA 550-F-93-002, January 1993.
Spill Prevention, Control and Countermeasure (SPCC) Regulation, 40 CFR 112, A Facility
Owner/Operator's Guide to Oil Pollution Prevention, U.S. Environmental Protection Agency,
EPA 540-K-98-003, July 1998.
Storage & Handling of Anhydrous Ammonia, Tanner Industries, Inc., May 1998.
Technical Background Document for Off site Consequence Analysis for Anhydrous Ammonia,
Aqueous Ammonia, Chlorine, and Sulfur Dioxide, Chemical Emergency Preparedness and
Prevention Office, U.S. Environmental Protection Agency, April 1999.
Title III List of Lists, Consolidated List of Chemicals Subject to the Emergency Planning and
Community Right-To-Know Act (EPCRA) and Section 112(r) of the Clean Air Act, as Amended,
U.S. Environmental Protection Agency, EPA 550-B-98-017, November 1998.
Training Module for Industrial Process Refrigeration Leak Repair Regulations Under Section
608 of the Clean Air Act, U.S. Environmental Protection Agency, EPA 300-B-96-001, February
1996.
What Belongs on An Ammonia Refrigeration P&ID, Daniel R. Kuespert, Ph.D., AcuTech
Consulting, Inc., AcuSafe News, July 2000.
7999 Update of Ambient Water Quality Criteria for Ammonia, U.S. Environmental Protection
Agency, EPA 822-R-99-014, December 1999.
Work with your Local Fire Department to Enhance Community Safety: The Cary Company, EPA
550-F-01-002, April 2001.
APPENDIX E - EDUCATION AND INFORMATION RESOURCES
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APPENDIX F - ANHYDROUS AMMONIA HANDLING QUIZ
The following ten (10) questions can help an individual begin to realize the range of information
and knowledge required to safely handle anhydrous ammonia systems and releases. Answers are
on the next page.
1. At what concentration is a person able to smell the presence of anhydrous ammonia?
a) 0-4ppm b) 5-50ppm c) 51-100ppm d) 101-150ppm
2. In accordance with 40 CFR 68, what is the threshold quantity for anhydrous ammonia?
a) 10 pounds b) 100 pounds c) 1,000 pounds d) 10,000 pounds
3. Under the Clean Air Act Section 112(r)(l), facilities subject to this rule are:
a) required to have the "general duty" to prevent releases and minimize consequences of accidental
releases which might occur.
b) are subject to EPA inspection if their ammonia refrigeration system contains <10,000 pounds of
ammonia
c) provide maintenance procedures in written form and implement them to maintain the ongoing integrity
of process equipment
d) only a) and b) are correct
4. If your facility uses more than 1,000 pounds of ammonia in a calendar year, you may be required to report
annually on a Toxic Chemicals Release form.
True or False?
5. A Process Hazard Analysis is required every 4 years on or before April 1st.
True or False?
6. Which of the following information is the owner or operator of Program 3 facilities required to provide when
verifying the completion of the operator's training.
a) the operator's identity c) the date of training
b) the method used to verify the operator understood the training d) a) thru c) are all correct
7. Your facility is required to notify the appropriate authorities when pounds of anhydrous ammonia is
released from your facility.
c) >1 b) >10 c) >100 d) > 1,000
8. A five-year accident history is required if your facility has had:
a) On-site deaths, injuries, or significant property damage
b) Known off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in
place
c) a) and b) are both correct
d) none of the above are correct
9. Facility Emergency Response Plans are required to provide details of the facility's security system(s).
True or False?
10. If anhydrous ammonia splashes on someone's skin, the recommended first aid is to flush the exposed area with
generous amounts of water for at least:
a) 10 minutes b) 15 minutes c) 30 minutes d) 45 minutes
APPENDIX F - ANHYDROUS AMMONIA HANDLING QUIZ
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ANSWERS TO QUESTIONS ON PAGE F-l
1. At what concentration is a person able to smell the presence of anhydrous ammonia?
b) 5-50ppm; See Page 1-2.
2. In accordance with 40 CFR 68, what is the threshold quantity for anhydrous ammonia?
d) 10,000 pounds. See Page 2-1.
3. Under the Clean Air Act Section 112(r)(l), facilities are required to:
d) only a) and b) are correct. See Page 3-1 and Page 5-8.
4. If your facility uses more than 1,000 pounds of ammonia in a calendar year, you may be required to report
annually on a Toxic Chemicals Release form.
False. See Page 3-9.
5. A Process Hazard Analysis is required every 4 years on or before April 1st.
False. See Page 3-12.
6. Which of the following information is the owner or operator of Program 3 facilities required to provide when
verifying the completion of the operator's training.
d) a) thru c) are all correct. See Page 3-14.
7. Your facility is required to notify the appropriate authorities when pounds of anhydrous ammonia is
released from your facility.
c) ^100. See Page 4-2.
8. A five-year accident history is required if your facility has had:
c) a) and b) are both correct. See Page A-5.
9. Facility Emergency Response Plans are required to provide details of the facility's security system(s).
False. See Page B-10.
d) If anhydrous ammonia splashes on someone's skin, the recommended first aid is to flush the exposed area with
generous amounts of water for at least:
b) 15 minutes. See Page C-2.
APPENDIX F - ANHYDROUS AMMONIA HANDLING QUIZ
Page F - 2
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