IIAR

There are multiple regulatory requirements surrounding the use of ammonia in industrial refrigeration applications, including emergency release reporting requirements. Under the requirements, accidental releases must be promptly reported and managed, but it is important for users to avoid both under and over reporting.

“According to EPA regulations, a facility must report any leak or leaks that exceed the chemical’s reportable quantity (RQ) — 100 pounds (within 24 hours) for anhydrous ammonia — immediately upon becoming aware of the leak,” said Bent Wiencke, principle at ChillOn LLC. “The EPA has established through precedent that ‘immediately’ means ‘within 15 minutes.’”

Navigating a Release

Many scenarios involving larger release amounts are often complex. Determining an accurate release amount requires extensive data gathering, an understanding of the release dynamics, such as if they were instantaneous, intermittent or continuous, and possibly a detailed investigation into the cause of the release.

“In some cases, it may not even be possible to approach the leak source to gather information about the type of leak and size of the leak opening and consequently to conduct an initial estimation of the leak quantity,” Wiencke said. “A 15-minute timeframe is not sufficient to fully understand the situation and provide an initial release amount.”

For example, a 110-pound release over 24 hours will likely have minimal or no off-site consequences, whereas a 10,000-pound instantaneous release is a completely different story. “Consequently, in the latter case, simply reporting that the release was likely over 100 pounds is not very useful for responders,” [but both require reporting nonetheless] Wiencke said.

The need for accuracy is relative to the total release amount. “For small release amounts, a difference of a few pounds can determine whether reporting is required. However, when dealing with large release amounts, such as over 10,000 pounds, a few pounds difference has no real bearing,” Wiencke said.

Mike Chapman, director of business operations for IIAR, said with a high-flow release device, meaning it is very easy to get to 100 pounds in a short period of time and a release likely means something is wrong. “If it is a pressure relief valve that releases, just call it in,” he said.

“You have to protect yourself from liability and enforcement and also the public pressures of bad press.”

If the EPA determines that a facility has not reported a leak above the reportable quantity within 15 minutes, the facility may be subject to significant fines, which are based on the size of the leak and the delay in reporting.

“There is a general concern that erring on the side of caution and reporting every leak, regardless of quantity, may attract the attention of regulators and trigger an audit. Essentially, the concern is that you may be punished for being a good neighbor trying to do the right thing,” Wiencke said.

As a result, some facilities may prefer not to report leaks hope to fly under the radar. However, Wiencke said this strategy can only go so far and may backfire when employees decide to call hotlines due to unsafe conditions.

Chapman said knowing when to report boils down to education. “If you understand the types of releases and how to calculate them, you can get a good representation of what a reportable release is and what is not,” he said.

Measuring Releases

Wiencke has been in the refrigeration industry for more than 30 years and has seen first hand release estimating tools that use questionable calculation methods or unknown sources.

“Consequently, when tasked with performing release calculations, users employing their own unique tools often generate results that vary greatly from one another. This inconsistency has caught the attention of regulators, who have challenged the results accordingly,” he explained.

In response, the IIAR created an industry-specific tool, leading to the development of the Guideline for Estimating Accidental Refrigerant Releases. The guideline and its related software tools are a comprehensive resource for those in the industry. While it cannot cover every possible release scenario, it addresses the most common ones.

As a best practice, users should familiarize themselves with the tool before a leak occurs rather than waiting until an incident happens. Additionally, users should complete the provided training modules and tests to demonstrate proficiency in using the tool to estimate release amounts.

“When the guideline was created, significant attention was given to structuring it in a way that allows users to have an ‘easy’ and systematic start when applying the guideline and tool,” Wiencke explained.

For example, a section within the guideline provides an easy-to-use “quick screening method” to quickly determine if the leak is likely to be below or over 100 pounds within 24 hours. If the release is over 100 pounds, guidance is provided on the next steps to take. “Within the industry, there are different schools of thought, but I believe that the right approach is to ‘report when in doubt,’” Weinke said.

In some facilities, associates may face a chain-of-command challenge. “It can be intimidating for a non-managerial associate to report a leak to authorities and regulators without first informing upper management,” Weinke said. “There have been instances where a facility manager learns about a major incident in their own facility from the local news station, which is far from ideal.”

Being Proactive

In addition to learning how to use the Guideline for Estimating Accidental Refrigerant Releases, Chapman recommends that those in the refrigeration industry get to know their local regulators, first responders, and law enforcement.

“Developing a relationship with those individuals is critical. If there is an incident or someone makes a report, regulators are more likely to come to you with better situational awareness and an open mind,” Chapman said, adding that there is more time to educate emergency response and regulatory personnel before a suspected incident occurs.

“If you educate them, they’ll know there is a difference between a smell of ammonia and emergency,” Chapman said. “Share what you’re trying to do to prevent incidents. Those relationships are invaluable any time a facility has an anomaly.”

Relationships with local regulators and first responders go unnoticed far too often, but they are invaluable and shouldn’t be overlooked. “Education is the common denominator to make sure people understand what to do, how to approach something, how to perceive something with a tempered perspective and be able to look at it with an open mind and make the right judgment,” Wiencke said.