Doubl-Kold Ammonia Regulations Assistance

Owners of Ammonia refrigeration systems must be aware of the regulations that have been implemented to regulate the use and release of hazardous substances.

OSHA

In 1992, the OSHA standard “Process Safety Management of Highly Hazardous Chemicals” was issued in the Federal Register.  This standard is more commonly referred to as “PSM”.    The standard was developed to give requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.  For refrigeration systems the standard applies to systems that contain 10 ,000 pounds of ammonia, although multiple systems that are not interconnected, have less than 10,000 each may still be covered under PSM due to the proximity of the systems.  A careful review of multiple systems must be done to determine the appropriate action to take in relation the PSM standard.

Any facility having the threshold quantity of ammonia must have a PSM program in place, as of 1997.  Any new facilities would be required to develop a plan and have it in place prior to introducing ammonia above the threshold quantity.

The PSM standard contains fourteen elements, which are titled:

• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Employee Participation
• Training
• Contractors
• Pre-Startup Safety Review
• Integrity
• Hot Work Permit
• Management of Change
• Incident Investigation
• Emergency Planning and Response
• Compliance Audit
• Trade Secrets

EPA

In June of 1996 in accordance with the Clean Air Act Amendments of 1900, the EPA issued the “Risk Management Program for Chemical Accidental Release Prevention.”  This program is commonly referred to as “RMP”.   The goal of this regulation is to protect workers and the public from the effects of an accidental release of highly hazardous chemicals.

All refrigeration ammonia systems containing 10,000 pounds or more must meet the requirements of the RMP regulation.  Implementation of the RMP was required by June 1999.

The RMP has the following major elements:

• Offsite Hazard Assessment and Consequence Analysis
• An Integrated Prevention Program
• A 5-year Release History for the Facility
• An Overall Management System to Supervise the Program Elements

OSHA-PSM and EPA-RMP

These programs although different is some respects do have several common elements.  These common elements do not have to be duplicated, but can be implemented for each program.

Local Emergency Planning Committee (LEPC)

In 1986 the Superfund Amendments and Reauthorization Act (SARA) was signed into law. Title III of SARA is the “Emergency Planning and Community Right-to-Know Act”.  Title III establishes requirements for federal, state, and local governments as well as for industry regarding emergency response planning and everyone’s right -to-know about hazardous chemicals in their community. The EPA has developed regulations to implement the Title III Law. However, the state and local governments play a key role under Title III as well.

Under SARA Title III any business that has an “Extremely Hazardous Substance” (EHS) onsite at any time in excess of it’s assigned “Threshold Planning Quantity” (TPQ) is required to participate in the local emergency planning process.  There are approximately 350 chemicals on the EPA, EHS list. Ammonia is classified as an EHS, and the TPQ for ammonia is 500 pounds.

The law requires that businesses that have over 500 pounds of ammonia must complete an “Emergency and Hazardous Chemical Inventory Form”, know as a “Tier Two Form”. This form must be submitted on or before March 1 of each calendar year.   The Tier Two forms must be submitted to three locations:

The State Emergency Response Commission (SERC)

The Local Emergency Planning Committee (LEPC)

Local Fire Department

Doubl-Kold Can Help

There are substantial monetary and criminal penalties for not meeting the requirements of the OSHA, EPA, and Tier Two regulations and laws.  We have personnel who have helped many companies across the United States with meeting the requirements of each of the elements of these regulations and laws for ammonia used in refrigeration systems. Our people are also actively involved in the Yakima County LEPC and can assist you with not only Tier Two reporting, but how you can be involved in the LEPC.

If you would like further information or assistance with your programs for ammonia as a refrigerant, please contact us a (509) 248-9588, or submit an Email to the Engineering Department at Kem Russell .