Is a NH3 discharge to a water diffusion system a “reportable release”

4/20/2018 UPDATE:  To further this discussion… consider a diffuser tank is 95% effective (Source: IIAR Technical Paper), meaning that 5% of NH3 would theoretically make it to the atm. WHEN that 5% is greater than 100 pounds, you have a REPORTABLE RELEASE.  Using an actual “oil separator” at a client, the RV has a 0.75″ discharge with a 19 pounds/minute rate @ 300 psi (Parker RV) would equal 1,140 pounds going to the diffuser tank over a 1-hr period. And with the assumed diffuser tank having a 95% effectiveness means that 57 pounds would make it to atm, falling short of the 100 pound RQ.  It appears, using the 95% efficiency assumption on a diffuser tank, we would have needed a scenario of a considerable RV lifting, OR the RV is at full throat for longer than 1-hour, or we have a situation where multiple RV’s lifted, and their flow rates exceeded that as stated above, THEN even with a Diffuser Tank, we could have a reportable release.

One of my go-to guys for NH3 Refrigeration questions/discussions, Brian Chapin, posed a question he was debating with a group…  “If my NH3 refrigeration process has a diffuser tank, if an RV lifts and sends NH3 to the diffuser tank, is this considered a “release”?”  My discussion with another friend who must remain nameless was indeed interesting.  But the short answer is NO, as long as…

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