“We’re seeing regulatory reform as a continuing effort and priority of this administration, which has directed agencies to identify outdated, redundant, and overly burdensome regulations,” he said. “This represents an opportunity for IIAR to promote our own reform initiatives, so along with partner organizations, we have been looking closely at some of the current regulations at EPA [U.S. Environmental Protection Agency] or OSHA [Occupational Safety and Health Administration] that may actually be hindering safety or else tying up necessary resources that could help respond during a release.”

To that end, IIAR will be focusing on three initiatives going forward:

1. Increase EPA’s ammonia release quantity from 100 pounds;
2. Increase the time allowed for notifications to the National Response Center from 15 minutes to 8 hours; and
3. Increase the immediately dangerous to life or health (IDLH) limit from 300 to 500 ppm and allow air-purifying respirator (APR) use up to 500 ppm.

As far as the first initiative is concerned, the history of the reportable release quantity is a result of studies that showed that releasing 100 pounds of liquid ammonia into a water source could be harmful to aquatic species.

“That’s a pretty rare occurrence within our industry, as the vast majority are aerosol releases that go into the atmosphere and break up into hydrogen and nitrogen,” said Randel. “It’s a natural refrigerant that will not have an impact on the environment.”

Therefore, IIAR is going to propose creating a new reportable release quantity of 500 pounds for aerosol releases, which will help avoid unnecessary reporting that ties up government, facility, and responder resources. Randel noted that there is precedence for creating separate reportable release quantities for liquids and aerosols.

“When you have a de minimis release that’s not having an environmental or life safety impact, we don’t feel that needs to be reported,” he said

The second initiative takes on the question of the definition of “immediate.” Right now, EPA’s interpretation of immediate is 15 minutes, which means that once there is a release of a reportable quantity of ammonia, facility personnel have 15 minutes to report it to local agencies, as well as the National Response Center (NRC). What IIAR will be advancing is to keep the local notification at 15 minutes, as those agencies will have a direct impact on the response to the release, but to allow up to 8 hours to contact the NRC.

“The National Response Center is probably pretty far away from where that release is happening, and it’s our position that whether that call is made at minute 14 or minute 400, there’s really not a lot that the NRC is going to do in regard to that release,” said Randel. “We know they have to be notified, but we think it’s more appropriate for those limited facility resources to be focused on doing emergency shutdowns, life rescue, and other emergency activities during that 15-minute period.”

The third initiative involves changing OSHA’s IDLH level, which is currently set at 300 ppm for ammonia. Randel noted that the research for this level is fairly outdated and does not reflect the advances made in life-saving technology, so IIAR is going to propose moving the level back to 500 ppm, which is where it used to be.

“One of the biggest benefits of doing this would be to allow folks with APRs to enter that release environment at up to 500 ppm and for up to 10 minutes at 1,000 ppm if they’re going in to perform a rescue,” said Randel. “There have been situations where, had someone been able to enter at 500 ppm, we could’ve avoided some negative life and health outcomes in the past. We’re going to make this a safer industry by allowing folks with APRs to go in at those levels and perform emergency shutdowns and rescues using the technology that has improved dramatically since the 300 ppm policy was put into place.”

Randel closed by saying that these are the three big ticket items IIAR will be trying to advance during this new climate of regulatory reform.

“We’re excited to get the ball rolling and move these initiatives forward,” he said.

CODE CHANGES

Jeffrey Shapiro, president of International Code Consultants, Austin, Texas, then discussed the latest developments in the Uniform Mechanical Code (UMC), International Mechanical Code (IMC), and the International Fire Code (IFC), noting that the 2018 codes are all available now, and they represent a giant leap forward for ammonia refrigeration.

In the ammonia industry, codes have generally been seen as obstacles, but thanks to the work of IIAR, many of those obstacles have been removed, said Shapiro.

“We have a formula of success, which involves educating code officials, advocating our interests, and ultimately executing in the code arena to get people to vote in support of our agenda,” he said.

As a result, IIAR now has a suite of standards that have been integrated into the model codes. In fact, out of the nine standards that IIAR has already published — or are in development — six have been widely adopted by the model codes.

“For the past seven or eight years, the focus of IIAR has been to become masters of our own destiny, and by developing all of these standards, we’ve made tremendous progress in that regard,” said Shapiro.

One of the biggest goals for IIAR is to have ammonia refrigeration removed from ASHRAE Standard 15, Safety Standard for Refrigeration Systems, and it has seen some success there.

“We were able to change the 2018 IFC so that it no longer references ASHRAE 15 for ammonia,” said Shapiro. “Now, if you’re designing an ammonia-only system, you only need IIAR Standard 2 (American National Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems), and you do not have to go to ASHRAE 15.”

It is Shapiro’s belief that by the end of the year, ASHRAE 15 will offer an addendum that states the document does not apply to ammonia and that IIAR 2 should be referenced for those systems instead.

“That will be another huge step forward because ASHRAE 15 is no longer sufficient to regulate ammonia refrigeration systems,” said Shapiro. “If you compare it with IIAR 2, there are things in there that 15 doesn’t have. It is my opinion that a system now designed to ASHRAE 15 without following IIAR 2 is a substandard system.”

As far as the IMC is concerned, there was some controversy surrounding how ammonia leak detection would be addressed, as the code always required refrigerated process and storage areas to have ammonia detection.

“What we worked out is that detectors are not required in any unoccupied pipe area without valves, like pipe chases,” said Shapiro. “Then we elaborated and gave an exception for harsh environments and areas that are always occupied.”

For the UMC, IIAR was successful in having ammonia refrigeration excluded entirely from the 2018 edition, and users are directed to follow IIAR Standards 2, 3, 4, and 5.

“Chapter 11 of the UMC does not apply,” said Shapiro. “The reason for that is because of the way we wrote IIAR 2, which incorporates what is needed as a code in addition to having the standards provisions. Our goal is to be the one-stop shop for ammonia refrigeration regulations.”

Publication date: 4/30/2018

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