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Many thanks to my friends at EPA (and OSHA) for sharing this EPA RMP Checklist specific to Ammonia Refrigeration Processes.  Here are the "highlights" specific to NH3 processes.  It should be noted that this RMP Checklist specific to Ammonia Refrigeration Processes was developed in conjunction with the International Institute of Ammonia Refrigeration (IIAR) and all EPA Regions.

NOTE: SAFTENG members can download the Entire Checklist in pdf inside the Chemical Process Safety - Document Library)

Section C: Prevention Program, Prevention Program- Safety information [68.65]

For ammonia refrigeration systems, these include (among others):

 Self-closing/quick closing valves on oil pots.

 All piping system openings, except for the relief header, are plugged or capped, or valve is locked.

 Equipment, piping, and valves are labeled for easy identification, and pressure vessels have legible, accessible nameplates.

 All pressure relief valves have been replaced in the last five years with visible confirmation of accessible pressure relief valves. [Note: Replacement every five years is the norm, but there are two other options in IIAR Bulletin 110, 6.6.3].

 The system(s) has emergency shut off and ventilation switches outside machinery room.

 The machinery room(s) has functional, tested, ventilation. Air inlets are positioned to avoid recirculation of exhaust air and ensure sufficient inlet air to replace exhausted air.

 Documentation exists to show that pressure relief valves that have a common discharge header have adequately sized piping to prevent excessive backpressure on relief valves, or if built prior to 2000, have adequate diameter based on the sum of the relief valve cross-sectional areas.

 The system’s critical shutoff valves are accessible, and a schematic is in place to show responders where to access them.

 Eyewash station(s) and safety shower(s) is/are present and functional.  

 If respirators are used, the owner or operator knows where the respirators are located, and the respirators are inspected and maintained per manufacturer or industry standards.

 The facility has engineering controls in place to protect equipment and piping against overpressure due to hydrostatic expansion of trapped liquid refrigerant. Administrative controls are acceptable where hydrostatic overpressure can occur during maintenance operations.

 

Prevention Program- Process Hazard Analysis [68.67]

 For ammonia refrigeration systems that employ hot gas defrost, does the process hazard analysis/review include an analysis of, and identify the engineering and administrative controls for, the hazards associated with the potential of vapor propelled liquid slugs and condensation-induced hydraulic shock events?

 

Prevention Program- Operating procedures [68.69]

 For ammonia refrigeration systems, the procedures include an emergency action plan pursuant to 29 CFR 1910.38(a) or an emergency response plan pursuant to 29 CFR 1910.120(q) and 40 CFR 68.95.

 For ammonia refrigeration systems, only authorized persons have access to refrigeration machinery room and the ability to alter safety settings on equipment.

 For ammonia refrigeration systems, written procedures are in place for proper use and care of personal protective equipment.

 

Prevention Program - Mechanical Integrity [68.73]

A preventative maintenance program is in place to, among other things, detect and control:

o corrosion

o deteriorated vapor barriers

o ice buildup,

o pipe hammering

o to inspect integrity of equipment/pipe supports.

 All piping system openings, except the relief header, are plugged or capped, or valve is locked.

 Equipment, piping, and valves are labeled for easy identification, and pressure vessels have legible, accessible nameplates.

 All atmospheric pressure relief valves have been replaced in the last five years with visible confirmation of accessible pressure relief valves

[Note: Replacement every five years is is general rule, but there are two other options in IIAR Bulletin 110, 6.6.3].

 

Prevention Program - Management Of Change [68.75]

 For ammonia refrigeration systems, only authorized persons have the ability to alter safety settings on equipment.

 For ammonia refrigeration systems, all changes to automation systems (programmable logic controls and/or supervisory control and data acquisition systems), if present, are subject to management of change procedures.

 

Section G - Emergency Response [68.90 - 68.95]

 For ammonia refrigeration systems, emergency response communication has occurred with LEPCs/local responders (although there is no explicit language in 40 CFR Part 68 for this, such communication is supported by industry standards and expected under the General Duty Clause).

 For ammonia refrigeration systems, emergency response communication has occurred or has been attempted with LEPCs and local responders. [Note: Until the regulations change, it may not be appropriate to seek penalties for this item. There is no explicit language in 40 CFR Part 68 requiring such communication, although such communication is supported by industry standards and expected under the General Duty Clause.]

 

Section H – Risk Management Plan [40 CFR 68.190 – 68.195]

Other items:

For fiscal years 2017-2019, EPA will be confirming that the minimum safety measures listed below are in place at facilities that have ammonia refrigeration systems. The measures also have been incorporated into the general checklist, above. The bare minimum measures must be in place, regardless of an ammonia refrigeration system’s age or size, for the system to meet the requirements of 40 C.F.R. Part 68 or the General Duty Clause. This is NOT intended to be a complete list of important safety measures but rather a subset of easily verifiable items that EPA and IIAR believe could most help facilities prevent ammonia releases and prepare for any releases that do occur. The list was developed with the assistance of IIAR and all ten EPA regions.

The second list (in green) contains other important safety measures that should be assessed if at all possible. This list also was developed with IIAR’s input.

 

List of Bare Minimum Safety Measures to Include in Settlements and Inspections

Identifying Hazards

Hazard Addressed: Releases or safety deficiencies that stem from a failure to identify hazards in design/operation of system

 Facility has completed a process hazard analysis or review. Operating Activities: Hazard Addressed: High risk of release from operating or maintenance activity  System has self-closing/quick closing valves on oil pots. 

 

Operating Activities:

Hazard Addressed: High risk of release from operating or maintenance activity

 System has self-closing/quick closing valves on oil pots.

 Facility has written procedures for maintenance and operation activities.  Only authorized persons have access to machinery room and the ability to alter safety settings on equipment.

 

Maintenance/Mechanical Integrity:

Hazard Addressed: Leaks/releases from maintenance neglect

 A preventative maintenance program is in place to, among other things, detect and control corrosion, deteriorated vapor barriers, ice buildup, and pipe hammering, and to inspect

 Only authorized persons have access to machinery room and the ability to alter safety settings on equipment.

 A preventative maintenance program is in place to, among other things, detect and control corrosion, deteriorated vapor barriers, ice buildup, and pipe hammering, and to inspect integrity of equipment/pipe supports.

 All piping system openings except the relief header are plugged or capped, or valve is locked.  

 Equipment, piping, and emergency shutdown valves are labeled for easy identification, and pressure vessels have legible, accessible nameplates.  

 All atmospheric pressure relief valves have been replaced in the last five years with visible confirmation of accessible pressure relief valves [note – replacement every five years is the general rule but there are two other options in IIAR Bulletin 110, 6.6.3].

 

Machinery Room and System Design

Hazard Addressed: Inability to isolate and properly vent releases

 The System(s) has/have emergency shut-off and ventilation switches outside each machinery room.

 The machinery room(s) has/have functional, tested, ventilation. Air inlets are positioned to avoid recirculation of exhaust air and ensure sufficient inlet air to replace exhausted air. 

 Documentation exists to show that pressure relief valves that have a common discharge header have adequately sized piping to prevent excessive backpressure on relief valves, or if built prior to 2000, have adequate diameter based on the sum of the relief valve cross-sectional areas.

 

Emergency Actions

Hazard Addressed: Inability to regain control and reduce release impact

 Critical shutoff valves are accessible, and a schematic is in place to show responders where to access them.

 EPCRA Tier II reporting is up to date.

 

Additional Recommended Items that Should Be Assessed During Inspections and Enforcement

Identifying Hazards  

 For systems that employ hot gas defrost, the process hazard analysis/review includes an analysis of, and identifies, the engineering and administrative controls for the hazards associated with the potential of vapor propelled liquid slugs and condensation-induced hydraulic shock events.

Operating Activities and Maintenance/Mechanical Integrity

 Written procedures are in place for proper use and care of personal protective equipment.  

 If respirators are used, facilities know the location of their respirators, and they are inspected and maintained per manufacturer or industry standards.  

 All changes to automation systems (programmable logic controls and/or supervisory control and data acquisition systems), if present, are subject to management of change procedures. 

Machinery Room and System Design  

 The facility has engineering controls in place to protect equipment and piping against overpressure due to hydrostatic expansion of trapped liquid refrigerant. Administrative controls are acceptable where hydrostatic overpressure can occur only during maintenance operations.  

 Eyewash station(s) and safety shower(s) is/are present and functional.

Emergency Actions

 Emergency response communication has occurred or has been attempted with the Local Emergency Planning Committee and local responders.  

 The facility has an Emergency Action Plan pursuant to 29 C.F.R. § 1910.38(a) or an Emergency Response Plan pursuant to 29 C.F.R. § 1910.120(q) and 40 C.F.R. § 68.95.

 

MEMBERS can log in and download the Full Inspection Checklist (pdf) from the Chemical Process Safety - Document Library

 
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