WHAT IS A RELEASE OF AMMONIA?

WHAT IS A RELEASE OF AMMONIA? THE AMMONIA GROUP P.O. BOX 600 ALTA, CA 95701 mikectag@colfaxnet.com

BEFORE WE START The ammonia industry has suffered 3 fatal accidents this month. Take a moment and think about your situation and how you can make it better.

RELEASE WHO DECIDES? THE FEDS? THE STATE? THE COUNTY? YOU?

RELEASE? MAYBE

RELEASE? PROBABLY...

RELEASE? HARD TO HIDE

THE REGULATOR HOW SHOULD WE LOOK AT THEM? FRIEND OR FOE?

A REGULATOR TRYING TO BE YOUR FRIEND! GOOD OR BAD? ALMOST ALWAYS.BAD

A PROFESSIONAL ATTITUDE WORKS IN YOUR BEHALF PROFESSIONALS GIVE ACCURATE ADVICE AND INSTRUCTION PROFESSIONALS CARE ABOUT THEIR CAREERS AND TRY TO KEEP UP TO DATE ON THE LATEST CHANGES EXAMPLES: THE DRUNK DRIVER JUVENILE DRAG RACERS THE COMMUNITY

The regulators that we meet in auditing the CalARP/PSM can save you a lot of money! Have you ever operated ammonia equipment outside design limitations?

A RELEASE? A slightly leaking valve (packing).

A RELEASE? Result A $250,000 dollar loss of product. Apples

A RELEASE? >10 pound release in an engine room

A RELEASE? The result One operator sent to the hospital to be checked to be safe (treated and released) Fire department called, but were not needed as the tank had emptied,and had been isolated from the ammonia system $ 15,000.00 fine

A RELEASE? A brief relief valve release at 4am. Reset within a minute or two.

RESULT A four hour delay in starting the reporting process. $ 15,000.00 fine

SIDEBAR I HAVE SEEN REPORTED, THE FIRST MILLION DOLLAR FINE FOR NON REPORTING IN 2008

A RELEASE? Reported concentrations at the scene 3.2 ppm to 8 ppm (10 readings)

A RELEASE? The result Reporting: Not required in Calif. If Highway Patrol is called. They will report by statute. Criminal trial against the carrier. The county wanted the judge and jury to: 1) Revoke the operating authority of the carrier 2) $ 10,000.00 fine for the release 3) $ 250,000.00 in civil penalties

WHICH OF THESE CAUSES MORE PROBLEMS FOR THE INDUSTRY? 1) WHEN DO WE REPORT? 2) HOW DO WE REPORT? 3) WHO HAS THE AUTHORITY TO REPORT? 4) WHAT IS A RELEASE?

How many had it right? 3) WHO HAS THE AUTHORITY TO REPORT?

WHAT IS A RELEASE? 1) One hundred pounds in 24 hours 2) Ten pounds in 12 hours 3) Facility evacuation no release 4) Any amount 5) A threat of a release 6) 15,000 pounds that nobody knows about.

WHAT IS A RELEASE? ANSWER 1) One hundred pounds in 24 hours 2) Ten pounds in 12 hours 3) Facility evacuation no release 4) Any amount 5) A threat of a release 6) 15,000 pounds that nobody knows about.

What Makes Sense? My personal view and recommendation. 1 Any time anyone smells, and or reports an odor of ammonia (other than maintenance personnel working on the Ammonia system should be immediately investigated by trained responders.

What Makes Sense? My personal view and recommendation. 2 Responders (at least 2) shall respond immediately upon notification with portable ammonia detection equipment to the location of the reported odor of ammonia. They may also carry PPE and tools appropriate to mitigate a minor release. (Example: packing leak or a valve not fully closed, etc.

What Makes Sense? My personal view and recommendation. 3 Responders (at least 2) shall record ammonia concentrations from at least 4 different spots in the reported area. All measurements shall be taken at 4 to 6 feet above the floor/ground. (This is the air we and workers are breathing.

What Makes Sense? My personal view and recommendation. 4A If the odor of ammonia is verified: A) Evacuate the area at any concentration of ammonia where anyone reports any personal irritation or injury from the odor of ammonia. (reporting timelines begin here)

What Makes Sense? My personal view and recommendation. 4 B If the odor of ammonia is verified: B) and the levels of ammonia are below 25 ppm (OSHA personal exposure level from which no injury is predicted) and no one is reporting irritation or injury, responders may continue to attempt to locate the leak/ release. (it is not necessary to place the inlet of the detection equipment on the (leaking valve) and record that #)

What Makes Sense? My personal view and recommendation. 4 C If the odor of ammonia is verified: C) and the levels of ammonia are above 35 ppm, stop and evacuate the area even if no one is complaining about he odor of ammonia. Begin Emergency Response procedures here. (reporting timelines begin here)

What Makes Sense? My personal view and recommendation. 5 All of these scenarios shall require the Incident Reporting procedures as contained in your CalArp program. In scenario 4B, the Incident Reports should be filed and kept in house.

Emergency Response Which of the following is most important? 1) Level A suits 2) Knowledge of ammonia 3) Preplan 4) Identifying the Hot, Warm, Cold Zone 5) Call 911 6) Incident Command

Emergency Response Which of the following is most important? 1) Preplan

Emergency Response Which of the following is most important? 1) Preplan

Emergency Response Which of the following is most important? 1) Preplan

Emergency Response Preplan Example #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA ACTION? #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA ACTION? 1)TURN OFF PUMPS #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA ACTION? 2)CLOSE LIQUID LINE #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA ACTION? 3)REMOVE AMMONIA #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA ACTION? #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA (RED) ACTION? 1) CLOSE KING VALVE #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response RELEASE AREA (RED) ACTION? 2) REMOVE AMMONIA #2 #1 ACCUMULATOR TANKS (LPR) PUMPS ENGINE ROOM HPR (KING VALVE) HALLWAY #3 COMFORT COOLING PRODUCTION AREA CONDENSERS (ON ROOF

Emergency Response SOME CLOSING THOUGHTS 1) I USE POSITIVE PRESSURE VENTILATION EVERY WHERE EXCEPT IN A FREEZER IN FREEZER RELEASE I WOULD a) STOP LIQUID FLOW TO RELEASE POINT b) REPAIR OR ISOLATE LEAK c) TURN REFRIGERATION BACK ON d) USE NEGATIVE PRESSURE VENTILATION 2) I HAVE NEVER NEEDED A LEVEL A ENTRY TO AMMONIA 3) NEVER ENTER A VISIBLE CLOUD (without monitoring) 4) IF YOU CAN T SEE THE PROBLEM, YOU CAN T FIX IT

THE AMMONIA GROUP QUESTIONS? COMMENTS THANK YOU