Back in December 2017, I wrote about a change in the Anhydrous Ammonia fertilizer industry that would most likely require the industry to perform an MOC and PSSR. (A new grade of anhydrous ammonia fertilizer means a MOC, PSSR, etc.) Now that the product has received its official approval and has found its way into the industry, we have learned even more about these additives and how they will impact “process safety”. Manufacturers and providers of these new nitrogen stabilizers have agreed that these additives will not affect the mechanical integrity of the NH3 process; however, adding this material to the NH3 is undoubtedly a “change” that must be evaluated. As shown in the video below from Koch Agronomic Services, there are many factors to consider in this “change”. In this article, I will identify, at a minimum, the matters that need to be addressed based on my limited exposure to facilities using these stabilizers.
PLEASE NOTE that many of these NH3 distributors are currently exempted from PSM via the “retail exemption” and under EPA’s RMP, they are a Program Level 2 process, meaning they can implement only seven (7) of the 14 elements. My clients do not play these games and have implemented a full-blown PSM/RMP management system, so I have written this article based on how this “change” will impact a full-blown process safety management system. SAFTENG members who manage their process as a Program Level 2 RMP process, can choose to apply my assessment to a Program Level 2 at their choosing. Most notable, a Program Level 2 process is NOT required to have a MOC program nor a PSSR program; I’ll let you come to your own conclusions as to how this could be after you have watched the video and read my assessment. A RMP program Level 2 must have only the following elements: § 68.48 Safety Information, § 68.50 Hazard Review, § 68.52 Operating Procedures, § 68.54 Training, § 68.56 Maintenance.
ALSO, PLEASE pay very close attention to the primary hazards of some brands of Nitrogen Stabilizers, as some of these products are FLAMMABLE LIQUIDS with FP’s just over 100F.
This type of hazardous material can pose a significant process hazard, in the way of a pool fire, to an NH3 storage tank where NH3 is stored as a liquid under pressure, as well as a personnel hazard in the way of flash fires. This material will also need to be grounded and bonded during transfer, which may be a new safety task for some NH3 distributors. Some SDS’s even state:
- Use explosion-proof electrical/ ventilating/ lighting equipment
- Use non-sparking tools
- Take action to prevent static discharges
And these may also be new to a distributor and may require some changes in design and training. CLICK HERE for a side-by-side comparison of a Flammable additive vs. non-flammable and take notice that this “service provider” is stating that the FLAMMABLE additive must be stored and handled in a HAZLOC (their words – not mine).
Here is an EXCELLENT video from Dow AgroSciences that walks us through how they have managed their implementation of this NH3 additive.
Management of Change (MOC)
Without a doubt, a facility that has a PSM/RMP covered process and is considering the use of these additives MUST perform a MOC. This is step #1 and the MOC will guide us through the hazard evaluation and identify the actions that will be needed to safely implement this change.
Process Safety Information (PSI)
1910.119(d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process.
As we saw in the video, we have a new process chemical that we will need to evaluate. This evaluation must include a Certified PPE Hazard Assessment, obtaining the SDS, updating our HAZCOM inventory of Hazardous Chemicals, and provide training to those exposed to this chemical. We will need to establish storage practices based on the manufacturer’s storage requirements (e.g. sunlight, secondary containment, etc. are some of the things to look for).
1910.119(d)(2) Information pertaining to the technology of the process.
1910.119(d)(2)(i)(A) A block flow diagram or simplified process flow diagram (see Appendix B to this section)
We will need to update/revise our block flow diagram or simplified process flow diagram to indicate this new addition to the process.
1910.119(d)(2)(i)(B) Process chemistry
This will need to come from our manufacturer(s)/providers, but this is CERTAINLY a change to our PSI, as before we had no “process chemistry” when we just received NH3 and filled nurse tanks. Now we are adding a new chemical and that is “process chemistry”.
1910.119(d)(2)(i)(D) Safe upper and lower limits for such items as temperatures, pressures, flows or compositions
We will need to establish the safe upper and lower limits of this chemical additive to ensure we are not overfilling nurse tanks, nor do we overpressure the nurse tanks. (See PHA discussion below)
1910.119(d)(2)(i)(E) An evaluation of the consequences of deviations, including those affecting the safety and health of employees
This should be part of the MOC and it appears the manufacturers have agreed that these additives can be safely handled by the same equipment rated for NH3 and Urea. I have not been able to find a simple fact sheet stating this, but if it were my process, I would be asking for some type of official memo from the manufacturer that documents they have performed an official review of the Materials of Construction and established this. I would then place that memo in my PSI.
1910.119(d)(3) Information pertaining to the equipment in the process.
1910.119(d)(3)(i)(A) Materials of construction
We will need spec sheets/cut sheets on the new hoses, tubing, pump, meter, etc.
1910.119(d)(3)(i)(B) Piping and instrument diagrams (P&ID’s)
We will need to update our P&IDs to reflect this new system and connections
1910.119(d)(3)(i)(H) Safety systems (e.g. interlocks, detection or suppression systems)
It appears that the “meter” is intended to perform a “safety function” to ensure the nurse tank is NOT overfilled or over pressurized.
1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices
This is just sort of an “oversight” as our MOC should require us to obtain all the documentation and our PHA will validate our steps of adding this material to a nurse tank.
Process Hazard Analysis (PHA)
After being around a couple of these processes, I have come to the conclusion that someone needs to step up and perform some type of PHA on this new system and how it can lead to an LOPC event involving NH3. At the very minimum, a facility siting assessment should be done so as to establish where these totes and pumps will be located and protected from accidental contact with vehicles. Someone needs to understand the human factors of improper hookup, reverse flow (NH3 flowing to the additive pump and tote, etc.) I have left both sites with more questions than answers from the very people who are installing, operating, and maintaining these additive systems. A PHA will go a long way to better understand the risks associated with adding this new chemical to a loaded nurse tank.
Operating Procedures (SOP) and Training
As we saw in the video, there is CERTAINLY the need for a PSM/RMP compliant SOP(s) and training. Within the SOP development, we will need to perform a “certified PPE hazard assessment” to establish the necessary PPE for the SOP(s) task(s). Personally, I would also do a JSA/JHA that would start with receiving this new chemical through its injection into the nurse tank. Forklifts are NOT a common piece equipment at many of these NH3 distributors, so if they are indeed receiving totes AND they need to move these totes, having a forklift may become a necessity and thus this will require additional evaluations and training for site personnel (if one is not already in place).
NOTE: who is actually making the addition will need to be trained on this practice! So if a PSM/RMP site is allowing “others” to make these additions, then those “others” will need to be trained on all applicable procedures.
Pre-Startup Safety Review (PSSR)
A PSSR is needed for a new process or a change to an existing process that involves updating the PSI for the process. As we noted above, there are a lot of needed updates to the PSI and thus a PSSR will be necessary. Remember, a PSSR is a field inspection that ensures the change was implemented as required by the MOC specifications. The MOC is asking for permission to make a change and then lists the necessary requirements for the change to be implemented safely – the PSSR is the field verification that the change was implemented properly and per the MOC requirements.
Mechanical Integrity (MI)
We will certainly need to update our MI equipment list with the new pump, meter, hoses/tubing, etc. We will need to evaluate the manufacturer’s PM requirements and ensure we are at least meeting these frequencies and activities. We will need to add the hoses that are being connected to the nurse tanks to our “hose rotation/testing/inspection” program. The meter may require some type of “calibration” from time to time and we must ensure we are meeting this requirement. We will also need to have written procedures for these tasks/activities.
Emergency Planning and Response (ER)
Although these additives do not appear to be a major chemical concern, we none the less need to evaluate the facility’s ability to respond to a release of these materials. A PPE review and the ability to contain a spill of this material at the very least will be necessary. Of course, how much we have on site and how large the container(s) is will impact this evaluation.