IIAR Guideline to Address Low-Charge Ammonia Systems

IIAR said it is developing an informative guideline document designed to help facilities with low-charge ammonia refrigeration systems simplify compliance with the OSHA and EPA General Duty Clause requirements from the Occupational Safety and Health Administration and Environmental Protection Administration.

The proposed guideline, currently titled Compliance Guidelines for LowCharge Systems, will be independent of IIAR’s existing Ammonia Refrigeration Management Program, which is being updated.

“This is not intended to replace the existing ARM program. It would stand alone. The intention is that this will be applicable to those kind of systems that have a total charge less than a typical industrial ammonia refrigeration system,” said Eric Smith, vice president and technical director for IIAR. It’s been called “ARM light,” Smith added.

The main ARM program was written for anything less than 10,000 pounds, which satisfies the EPA and OSHA General Duty Clause that applies to any amount of ammonia refrigerant less than 10,000 lbs. The ARM program was last published in 2005 and is being reviewed for consistency and accuracy and being updated where necessary. Low-charge, package systems weren’t specifically addressed in the 2005 edition.

“Low-charge is a term that gets thrown around frequently, and it is a relative term,” Smith said. “What many people are referring to these days as low-charge systems are minimally charged, package-type systems where most of the refrigeration equipment will fit on a single skid-mounted assembly.”

Such package systems could be mounted on the roof or on the ground or in other locations, but the idea is that most of the components are factory assembled rather than field assembled, Smith said.

Smith said he believes that the development of this guideline will help to promote the use of ammonia in applications that have traditionally used HCFCs or HFCs, which are being phased out. An easier, yet safe way to be compliant will help to remove the barriers of resistance for owners of facilities with moderate refrigeration needs.

Jim Marrella, president at J. C. Marrella & Associates, said the use of low-charge, package systems is on the rise. “A lot of people are looking at that higher efficiency. That is probably the reason they’re going there since the technology is there.”

The guideline document, which Marrella is drafting, will most likely be utilized by commercial and small industrial occupancies. “The goals of the new program are to make sure everyone is in compliance and to head off any trouble when it comes to hazardous releases,” he said.

The document will include a definition of low-charge ammonia refrigeration systems, the compliance elements that should be incorporated, implementation methodologies that could be utilized, documentation management, program management, written program and example forms, and information on how the program satisfies the General Duty Clause requirements.

“The General Duty Clause has no specific threshold quantity. It is based on release. You have to make sure if you’re going to follow the general duty clause that all of the boxes are checked because it is a minimum requirement,” Marrella said.

The document will also provide a recommendation on what might be the range of ammonia mass that would be used to qualify a system as low charge. The recommendation will consider that the charge amount would be below any program levels for compliance other than the General Duty Clause that presently exists within the U.S., Smith said. It will also consider the impact of having multiple low-charge ammonia refrigeration systems at a common commercial or industrial occupancy and if threshold criteria would change as a result.

It is believed that commercial and industrial facilities with low-charge ammonia refrigeration systems would most often utilize qualified service contractors for their operation, maintenance or both. The final document will provide guidance for the owners, installing contractors, service contractors and package manufacturers.

The document will provide guidance for the service contractors to advise about necessary package and system files to be maintained at the site, the contractor’s facility or both, and address operating instructions, on-going maintenance schedules, emergency plan requirements, and protective equipment and service training for personnel.

It will clarify what information, programs and procedures service contractors should provide to the owner of the facility and help facility owners with instruction on their responsibilities of system ownership. The owner is responsible for understanding, at least on a basic level, the information provided, including operations and maintenance documents, files that need to be maintained on site, an on-going maintenance program and an emergency plan.

Most of the guidance should be drafted by the spring, when it is slated to be reviewed by IIAR’s Compliance Guidelines Committee. It will not be an ANSI standard, so it won’t go through an ANSI standards process review.

The overall goal is to provide a document that will satisfy the General Duty Clause for low-charge ammonia refrigeration systems and how they are easily assembled, and Marrella said his goal is to help members comply with regulations. “The mom-and-pop operations don’t have the money budgeted for compliance issues like the big companies do. But they have to stay in compliance. I want to make it as friendly as possible for the mom-and-pop operation – to operate safe systems and comply with the general duty clause,” he said.