Certainly your ammonia technician will pick up any minor leaks during a regularly scheduled walk-through of the facility. But what if that leak starts at 6pm Friday evening and everyone is gone for the weekend? You had better have some sort of ammonia detection according to the latest EPA fine.
Boston, Oct. 5, 2010) – Tanner Industries, an East Providence, R.I., company that distributes ammonia, faces a $149,080 penalty for violating federal regulations meant to prevent chemical accidents, according to a recent complaint by EPA.
The facility is not routinely staffed except when ammonia is transported into or out of the facility. Tanner’s primary emergency plan is to rely on local emergency responders to respond to any ammonia releases, although the facility has no automatic ammonia sensors to alert emergency responders of potential releases. The facility is about a tenth of a mile from a residential neighborhood, and even closer to other public businesses.
According to the complaint filed by EPA, Tanner failed to do the required analyses or take precautions to address the fact that its facility is not routinely staffed except when ammonia is being actually received or distributed. For instance, Tanner failed to consider the use of sensors or monitors to detect leaks of ammonia or conditions that might lead to leaks. Tanner’s emergency response program also did not include adequate communication and coordination with local emergency response agencies, and the company’s plan did not ensure that the public would receive adequate notice of an accidental release.
Ideally you have ammonia detection that initiates the following actions:
- Automatically shut off flow to the area where the ammonia was detected
- If in the engine room, turns on emergency ventilation and shuts down possible ignition points
- Alarms on-call operators through cell phone text messages or email
- Alarms your security company to make voice calls to on-call operators to ensure someone is responding.
The best thing you can do to minimize false alarms (and you will get them) is to initiate an incident investigation every time the alarm goes off. These incident investigations can act as a driver to make the system improvements that minimize these false alarms.
p.s. I note that SAFTENG.net suggests “an AUTOMATED system that uses detectors at LOW LEVEL SET POINTS to shut the system down!” Most ammonia alarm systems have low and high alarm settings. The low setpoints are usually set to a threshold that protects the employees (somewhere around 35ppm and the PEL is fine) but the high level should be set near the high range of the sensor (100-200ppm usually) so you know that you’ll need a higher level of PPE to enter the affected area. I would NOT suggest shutting down the system at the LOW level alarm as it would cause unnecessary system interruption as well as excessive wear on the system. Some facilities have a high-range sensor in the compressor room that initiates a system shutdown at 1,000ppm which is also a great idea.
