EPA’s RMP and Ammonia Refrigeration

UPDATED on 2/6/19, based on feedback from my friend and Refrigeration PSM Extrodinare Brian Chapin over at RCE (A former Partner in Safety).  I have shared his analysis and my rebuttal/agreement…

By a long shot, these are the top three (3) issues found with Ammonia Refrigeration RMPs:

  1. The NH3 is “Liquified by Pressure” – not by refrigeration!
  2. Process Purgers are NOT the same as “Purge System” as listed in the Process Controls section of the RMP
  3. If you’re not on the Coast – your process was most likely not built to withstand as Cat 1-5 Hurricane!  The States of NE, MO, and IA have not seen a Hurricane since before the ice age.  LOL

Here is a brief explanation of how these three (3) should be listed in your RMP:

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