Back in December 2017, I wrote about a change in the Anhydrous Ammonia fertilizer industry that would most likely require the industry to perform a MOC and PSSR. (A new grade of anhydrous ammonia fertilizer means a MOC, PSSR, etc.) Now that the product has received it’s 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”. The manufacturer’s and providers of these new nitrogen stabilizers have all agreed that these additives will have no impact on the mechanical integrity of the NH3 process; however, the addition of this material into the NH3 is certainly a “change” that must be evaluated. As can be shown in the video below, from Koch Agronomic Services, there are a lot of matters to consider in this “change”. In this article, I will point out some matters that need to be addressed at a MINIMUM, based on my limited exposures to facilities utilizing 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.