This article is being posted in my Hazardous Materials section rather than the Process Safety section because the vast majority of my finds regarding the lack of proper design are almost exclusively in processes that have less than 10,000 pounds. I am hoping that those who read this will understand that what I am going to discuss in this article has absolutely nothing to do with being a PSM/RMP covered process and everything to do with basic compliance and safety regarding Anhydrous Ammonia (NH3).
Without a doubt, in my opinion, the biggest risk these facilities face is the unloading of NH3 from a tank truck to their bulk storage tanks. And I am not the only one who believes this is the biggest risks, as OSHA, ANSI and the Compressed Gas Association (CGA) have specific unloading system design requirements; however, this article will only discuss the requirements in 1910.111.
For those processes that are UNDER the PSM/RMP TQ, they will be required to meet:
(emphasis by me)