This month Koch Agronomic Services (KAS) announced they have developed a “nitrification inhibitor” for their anhydrous ammonia (NH3) fertilizer that will significantly improve nitrogen use efficiency (NUE) to increase crop output while minimizing environmental losses. This is great news for all of us; however, for those at the facilities where this new grade of NH3 is being produced, it means some “changes” to their process safety management systems. Most notably, this new “nitrification inhibitor” will require…
- Management of Change (MOC) – The company has a couple of different routes for how this change will be managed: a) from a corporate position or b) at each location where this new grade is being produced AND/OR stored.
- This “change” is requiring a change to the Process Safety Information (PSI) so that means that we will need to do a Pre-Start Up Safety Review (PSSR).
- This change may even impact the long and forgotten PSM element “Trade Secrets”, depending on how the company manages this change.
The PSI that may need updating could be:
- 1910.119(d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process – not sure how this “nitrification inhibitor” works or its hazards if it poses any, but we will need at least the SDS for it
- 1910.119(d)(1)(vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur – not sure how this “nitrification inhibitor” will be added to the NH3, but in the previous process this would have been N/A, but now there is an “addition” being made somewhere in the process and thus we should now consider someone adding the wrong chemical at the wrong place at the wrong time.
- 1910.119(d)(2)(i)(B) Process chemistry – this will certainly be changing
Having no idea as to how this “nitrification inhibitor” will find its way into the NH3, this could mean new process equipment, revised P&IDs, new Operating Procedures, etc.
Having no clue as to how this new “nitrification inhibitor” works, I would be very inquisitive about how it may impact my mechanical integrity, most notably my materials of construction and my test/inspection frequencies. This will be impacted by where the “nitrification inhibitor” is injected into the process, but we must know its impact on our materials of construction; keeping in mind that it may actually IMPROVE our risks. We just have to know.
This new “nitrification inhibitor” sounds like it may be a “selling point” for the manufacturer and thus I would be willing to bet they will be holding their new and improved product close to their vest so as to not let their competitors know how their NH3 is a better buy than the others. “Centuro” is the trade name for this “nitrification inhibitor” and its main ingredient is pending its Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) approval(s) and is not yet available for sale or use. I was not even able to find an SDS for this product. But all indications are that this new addition to their NH3 fertilizer will be a “Trade Secret” and if so would kick-in the “Trade Secret” element.
UPDATE 2/2019 – Koch rolls out new nitrogen inhibitor
“Centuro is non-corrosive to the metals used in anhydrous and UAN equipment. This minimizes the time and costs associated with equipment, maintenance, replacement and downtime. It does not require stainless steel tanks. Centuro does not swell O-rings used in common anhydrous ammonia equipment, which means it can remain in tanks over time without effecting their operation,” Potter said.