KEM RUSSELL, P.E

Having a well-thoughtout and functional emergency plan can be challenging. I have seen some very good emergency plans, but I have also noticed that several plans are not as complete as they could be. This seems to be a tough lesson to learn, and you may have experienced this. Let me start with an example of a conversation similar to what I have heard many times, and then give some considerations for improving an emergency plan.

“Hey, boss can I talk with you a minute?”

“Sure, I have some time. Come on in.”

“Boss, I have been working on updating our emergency plan for each of our plants and have some questions.”

“OK. Questions like what?”

“Well, our emergency plan is written as an ‘Action Plan’, not a response plan since we don’t have enough people trained to have a response team. So, we rely on the local responders which is the
Fire Department near each of our plants. But as far as I know none of the Fire Departments that will respond to help have hazmat capability. Is that right?”

“Hmmm, well I’m not sure about that but we are included in the community emergency plan.”

“Oh good. I was going to check that out, but I was wondering if we should consider providing the local responders with what they might need to be able to respond to an ammonia release?”

“That has been considered but it would be too costly, so we are good by being included in the community emergency plan.”

In the above discussion of an emergency action plan are the plants/facilities prepared for an ammonia incident? I think improvements can be made.

Fortunately, most ammonia systems are well designed, well built, and well maintained so emergency situations rarely happen. Many facilities with an “Emergency Response Plan” (ERP) do regular training with their emergency teams, employees, and local responders and these facilities are likely in good condition to deal with an ammonia emergency. One advantage to having a well-developed and functioning ERP is that you can be part of the solution in offensively dealing with an emergency. You also should have more input and possibly control into what happens in dealing with an emergency. However, many ammonia facilities don’t have the people to properly support a response team and those facilities have an “Emergency Action Plan” (EAP) to protect people as they coordinate with local responders in dealing with an ammonia emergency. 

All facilities are to have in place an EAP that properly addresses the element stated in OSHA 29 CFR 1910.38 (these elements would also be included in an ERP). In reading this regulation notice it does not address offensively responding to an emergency but rather “procedures for reporting a fire or other emergency.” Many facilities rely on their local responders to do the offensive actions for any type of emergency. EPA has stated that they do not intend to force a facility to develop emergency response capabilities, so facilities rely on being included in their community emergency plan prepared under EPCRA (Emergency Planning and Community Right-to-Know Act) regarding a response to a potential release, and on their local responders being able to deal with whatever the emergency is.

In addition, The General Duty Clause (GDC) of §112(r)(1) establishes that owners and operators of stationary sources producing, processing, and storing extremely hazardous substances have a general duty to identify hazards associated with an accidental release, design and maintain a safe facility, and minimize consequences of any accidental releases that occur. Ammonia is classified by EPA as an extremely hazardous substance, and as stated in the GDC the owner or operator is responsible to minimize the consequences of any accidentally released chemical. Can your facility depend on local responders being able to appropriately handle an ammonia emergency? In many locations, the local responding organizations do not have the staff, training, nor equipment to respond to ammonia releases. So how might a facility develop its emergency plan to address who will respond?

Some possible approaches come to mind: 

• An ERP could be developed. This depends on the staff at a facility, but possibly sufficient employees could be trained to function as a hazard response team. This may require additional costs to purchase appropriate personal protective equipment (PPE) and to provide the necessary training. With your own team in place, you would still coordinate with your local responder(s) and between you and them have a much better chance of successfully dealing with an ammonia emergency. For facilities that have processes that contain 10,000 lbs. or more of ammonia the updated Risk Management Plan rule states that facilities will coordinate with local emergency response officials required by § 68.93, the owner or operator shall consult with these officials to
  establish an appropriate frequency for tabletop exercises, and shall conduct a tabletop exercise before December 21, 2026, and at a minimum of at least once every three years thereafter.”
  Field exercises should also be done and the updated rule states “coordination with local emergency response officials required by § 68.93, the owner or operator shall consult with these
  officials to establish an appropriate frequency for field exercises.”
• Coordinate with the local responders and see what they need to be prepared to deal with an ammonia emergency. Again, for facilities that have processes that have 10,000 lbs. or more of
  ammonia the updated Risk Manage ment Plan rule states “The owner or operator performs the annual emergency response coordination activities required under § 68.93.” This annual
  coordination must have occurred by December 19, 2024.” During this coordination, it should be determined how an ammonia emergency will be dealt with. It may be discovered that something needs to be done before the local responders are ready. This coordination with local responders should also be done for smaller facilities that have less ammonia as part of fulfilling the intent of the General Duty Clause.
• If you have an EAP and your local responders cannot handle an ammonia emergency, then during your coordination efforts determine if a neighboring group has hazmat capability. Through
  a mutual aid agreement possibly that group could respond. How far away that group is, will be an important consideration. If, for example, it would take them three hours or more to get
  to your facility, that probably is not going to be much help.
• The local responding organization may need help to be able to respond to an ammonia emergency. This could be done by providing them with ammonia-specific hazmat training so they
  better understand what might be done to deal with an ammonia release safely and possibly offensively. The purchase of additional PPE may not be required since local responders i.e., Fire Departments likely already have much of what would be needed, but if not, that could be worked out. The training that the local responders may need might best be done with both the facility and local responders together. Both groups participating in this training will help coordinate efforts and plans, plus meet annual required coordination for Risk Management Program facilities.
• Are there other groups or organizations that could respond to an ammonia emergency? This might be a local ammonia refrigeration contractor who has employees trained as “Hazardous Material Technicians,” or an all-hazards materials contractor. Most states have emergency response groups or organizations that may be able to assist, or at least help determine what may be best to consider in responding to an emergency. Again, the length of time for a group or organization to arrive on-site would be an important consideration.
• Review your ammonia system(s) looking for what might be done to mitigate a possible ammonia release quicker. This could be accomplished by developing or reviewing procedures to isolate equipment or sections of a system (it might be found that installing system isolation valve at some locations would be helpful); how to pump down equipment or sections of a system; how to properly shut down equipment or sections of a system, etc. These procedures should also be supported by ongoing review and training with all appropriate personnel and possibly other employees could be trained to assist.

Because you have ammonia and are responsible for it, is your facility really prepared for an ammonia emergency, which includes knowing what local responders can and can’t do? Meet with your local responders to coordinate and discuss your emergency plan considering what will be done to protect your people, the surrounding public, and the environment. Don’t leave gray areas in your plan. That’s the lesson to learn.