Fact Sheet: Preventing Accidental Releases: Anhydrous Ammonia

Preventing Releases

Virtually all accidental releases can be prevented. Hazardous substance releases, however, are an all too common occurrence. Releases are costly for communities and facilities.

This fact sheet introduces cost effective options to prevent and mitigate ammonia releases. This information is intended as general guidance only. It is not a substitute for any applicable local, state or federal regulations. Specific release costs and facility prevention choices should be determined on a case-by-case basis. Contact the non-regulatory DEC Pollution Prevention Office, 562-6529, for more information or a copy of a more detailed report on ways to prevent ammonia releases.

Did You Know?

• In Alaska, anhydrous ammonia is one of the most prevalent extremely hazardous substances. Ammonia is primarily used as a commercial refrigerant and is found at seafood processing facilities throughout Alaska.

• Anhydrous ammonia is a colorless gas with a distinctive odor. Ammonia is primarily a respiratory toxicant that can cause lung irritation, and, in higher concentrations, death.

• The risk to community populations associated with ammonia is substantial. According to the State and Regional Hazards Profile, there are 101 facilities in Alaska that use or store over 600 tons of ammonia at any one time, excluding the urea plant in Kenai. Based on population information, people living near 97 of these facilities could be affected by a release.

• National studies estimate that approximately 75% of all accidental releases of hazardous chemicals occur at fixed facilities. Anhydrous ammonia is one of the ten hazardous chemicals most commonly involved in a release, AND the second most likely to result in death or human injury due to a release.

What Are the Common Causes of Releases?

Operations and maintenance failures, equipment failures, and process failures are the three leading causes of accidental releases of ammonia. Significantly fewer releases are caused by unauthorized activity, natural events, and fires.

Operations and Maintenance Failures include lack of adequate training, standard operating procedures, safety programs, management commitment to safety, and faulty repairs and inattentiveness leading to leaks, overfills, and broken equipment.

Equipment Failures include defective equipment design, construction and installation that result in overflowing containers, and leaking piping, valves, and gaskets.

Process Failures include pressure, temperature, flow and fluid chemistry changes that result in tank and/or piping ruptures.

Available Facility and Hazardous Substance Information

Department of Environmental Conservation

• Release reports
  
• Annual Facility Hazardous Substance Reports
  
• State and regional hazards profiles
  
• Preventing Accidental Releases of Anhydrous Ammonia, Chlorine Gas & Bulk Fuels

• State Emergency Response Commission
  
• Local Emergency Planning Committee contacts

Why Prevent Releases?

Preventing accidental releases of anhydrous ammonia benefits both communities and facilities.

Communities Benefit from:

• Good image as a place to live and work with low risk to human health and safety from a release.
  
• Reduced costs from emergency response personnel responding to fewer or no releases.
  
• Cleaner environment creating opportunities for other businesses and increasing visitor popularity.

• Reduced Costs due to fewer or no accidental releases.
  
• Increased worker satisfaction from employee awareness that management is concerned about safety.
  
• Good business practices resulting in fewer federal, state, and local restrictions on operations.

What Could Facility Release Costs Include?

Facility owners/operators and employees are not always aware of the full range of potential costs associated with an accidental release. Below are the types of costs that a facility may incur. For a general estimate of actual release costs, see the Ammonia Release Scenario fact sheet.

Facility Direct Costs

• Chemical loss
  
• Attorney's fees
  
• Equipment damage
  
• Waste disposal
  
• Clean up
  
• Public relations
  
• Process disruption
  
• Increased insurance premiums

Third Party Costs

• Property damage
  
• Economic loss
  
• Punitive damages
  
• Injury/loss of life

State Penalties and Cost Recovery

• Civil and criminal penalties
  
• Restoration and Damages
  
• Administrative penalties
  
• State expenses
  
• Attorney's fees

Federal Penalties and Cost Recovery

• Civil and criminal penalties
  
• Administrative penalties
  
• Cost recovery

What Can Be Done?

There are three basic categories of options that facilities can use to prevent and mitigate accidental releases.

1. Eliminate Releases - Eliminate the use of a hazardous substance by substituting a less or non-hazardous substance. This protects the facility and the surrounding community from a hazardous substance release. By eliminating the use of toxic substances a facility can also significantly reduce current and potential costs and liabilities. Currently, there is no less hazardous and commonly used substitute for anhydrous ammonia. In fact, seafood processors are switching from the more environmentally damaging chlorofluorocarbon refrigerant to anhydrous ammonia refrigeration systems.

2. Reduce Risk - Build a comprehensive program to prevent accidental releases. This step can eliminate the greatest causes of hazardous substance releases: operations, maintenance, and equipment problems. Facilities with greater than 10,000 lbs. of anhydrous ammonia may soon be required by the Clean Air Act Amendments to start a pollution prevention program. A facility should identify risks and determine methods of limiting those risks throughout its operations, including:
   • Inventory reduction/control: Reduce inventories of hazardous substances to the minimum needed, to reduce the potential for releases.
     
   • Management systems: Ensure that management practices and worker training give priority to prevention and release reduction.
     
   • Personnel training: Ensure that all personnel are adequately trained.
     
   • Security measures: Improve security to minimize the potential for unauthorized activities.
     
   • Process design: Install additional sensors to allow better monitoring of process conditions.

3. Reduce Consequences - By installing and maintaining specific equipment and structures a facility is able to reduce the adverse affects of many releases, including those that may not be a function of the facility's operations, such as: natural events, fires, and unauthorized activities. A facility should identify its best options to mitigate accidental releases. Such options include:
   • Gas detectors: solid state and electronic gas detectors are commonly used to detect very low concentrations of anhydrous ammonia. Early detection may allow time for repairs to be made quickly.
     
   • Containment systems: diffusion tanks can be used in some circumstances to dissolve the released ammonia in water. Physical barriers, such as, water sprays, fogs, captive zones, and foams may be used to divert, limit and disperse ammonia.
     
   • Treatment systems: scrubbers are the most common type of treatment system for mitigating anhydrous ammonia releases. Flares, burners, thermal oxidizing units, and high velocity fans are other options.

What Do Ammonia Releases Cost?

The following scenario provides a rough idea of the cost ranges that are usually incurred as a result of an ammonia release from a cold storage facility. A specific facility may incur costs in some or all of these cost categories as the result of an accidental release.

Assumptions

• Average size cold storage facility in Alaska
  
• 20 employees
  
• Facility loses 10,000 pounds of ammonia
  
• People in area are alerted or evacuated

These are the costs a facility usually must bear in the event of a release.

Chemical loss	$11,000-15,000
Process disruption (down time & lost or diminished product)	$10,000-25,000
Litigation (legal fees & personnel time)	$20,000-100,000
State penalties & cost recovery (DEC & OSHA)	$2,000-200,000
Equipment damage	$0-5,000
Public relations (advertising & personnel time)	$2,000-10,000
TOTAL	$45,000-355,000

(see IMI report for basis for estimate)

Possible Costs

Depending on the circumstances, these are additional costs a facility will often have to bear in the event of a release.

• Federal penalties and cost recovery: The EPA and federal OSHA may all be able to assess penalties and/or collect expenses from the facility depending on agency jurisdiction. These fees can vary greatly.

• Third party Suits: Property damage, injury/loss of life, economic loss, and punitive damage suits may be brought by the public against the facility. Depending on the outcome of these suits a facility may incur little or great (millions) additional costs.

• Increased insurance premiums: Worker's compensation and pollution insurance. Worker's compensation may increase according to a schedule, if a worker is injured and situation is not remedied. Pollution insurance is probably not a factor for an ammonia release because many facilities do not have it.