Refrigerant Monitoring and Environmental Concerns
Refrigeration is important in our daily lives. Keeping product at specific temperatures is required for industrial processes as well as preservation of various food items.
Ammonia refrigeration by design is a mechanical pressurized system containing a Hazardous Material. By law these systems are required to meet minimum safety regulations that include a detailed reporting protocol for any unexpected release of ammonia. If an overpressure condition occurs, Relief Valves are designed into the system by code to relieve the overpressure condition, either to atmosphere or secondary containment. In any case, a release event must be reported to the National Response Center in a timely manner with details of the event. When reporting a release event, the required information must include the start, the end and the duration of the event as well as the estimated quantity of ammonia released.
Compliance with reporting of a release event has been a subjective process at best because in large ammonia systems with many vessels and multiple processes it is virtually impossible to determine where the release originates or when it occurred. Without a defined start time the reporting is inaccurate. Without a known origin of a release, it is unlikely that the end of the event can be defined. Without the timing of the event, duration is unknown and so is the loss of ammonia in pounds.
Many times there is a delay in reporting a refrigerant release because of confusion about what vessel was experiencing high pressure and subsequent release, how many pounds of refrigerant were lost, etc. Resulting fines from Federal, State and Local governments for late reporting have been very costly to these facilities.
Actual case #1: Article excerpted from U.S. local news papers
More than 6,000 pounds of anhydrous ammonia spewed from a refrigeration building at the plant for about seven hours. Environmental regulations require plants to immediately notify the National Response Center, the state Department of Environmental Protection and local emergency planning offices if a plant leaks more than 100 pounds of anhydrous ammonia.
The U.S. Environmental Protection Agency is seeking a penalty of $46,408 against (company name withheld) for not immediately reporting a chemical leak to the proper authorities, officials said.
Actual case #2: Article excerpted from U.S. local news papers
The U.S. Environmental Protection Agency today announced a settlement with food processing company (company name and location with held). The company has agreed to pay $157,900 for violations of federal regulations including failing to notify the proper officials immediately following the release of anhydrous ammonia, failure to submit a required Risk Management Plan, and inadequate chemical accident prevention.
Actual case #3:
BSI was called in to a client’s facility where several ammonia releases had been reported. BSI was asked to evaluate what had happened and to make recommendations to prevent additional releases.
Upon review, it was discovered that some of the releases were due to Leak Detector monitoring devices (sniffers) providing “false positive” alarms. There were also other releases directly attributable to vessel over pressure conditions. There are a good number of refrigerant pressure vessels with a combination of single and dual relief valves in this facility.
All relief valves were piped into a common vent header (in compliance with national codes) which was piped outside to a containment vessel. There was an ammonia sensor (sniffer) in the vent header which detected the presence of ammonia in the header near the containment vessel. Determination of a specific pressure vessel or relief valve experiencing an ammonia release proved impossible. There were no operational alerts indicating a relief valve release condition, only a vent header full of ammonia vapor as a result of a relief valve release.
As a result of BSI’s site evaluation, several concerns became apparent:
- There was no way to determine if an actual refrigerant release had occurred other than a “sniff” test.
- There was no way to determine if an over pressure condition had existed or where it may have occurred.
- There was no realistic method for determining and reporting the time span for a refrigerant release.
- There was no method for accurately determining and reporting the loss of refrigerant.
A system does exist that can take the guesswork out of the event details when reporting an ammonia overpressure relief valve release event. Such details include “Which vessel had the high pressure release,” “Which relief valve released,” “The start time of the release,” “The end time of the release,” “The duration of the release,” and “The pounds of ammonia loss during the release.”
Prevention of an ammonia release is the primary goal with this system, however if a release of refrigerant (anhydrous ammonia) does occur, this system is designed to provide the facility with pertinent information necessary to comply with the E.P.A.’s reporting requirements.
This technology is designed to give facilities the tools to make reporting a refrigerant release quick, accurate and easier than ever before. This system solves so many reporting issues when a refrigerant high pressure event takes place.