In 2011 EPA inspected a national company that distributes ammonia and found several concerns that were eventually addressed in a settlement agreement. One of the business’s facilities is about a tenth of a mile from a residential neighborhood, and even closer to other public businesses. The way the facility was operating, according to EPA, if an ammonia leak occurred when the facility was un-staffed (the only time the facilities were staffed was during a transfer of NH3), a cloud of ammonia gas could have reached surrounding populated areas before emergency responders or neighbors detected it. EPA also alleged that the business failed to coordinate adequate emergency response plans with local emergency response agencies to ensure that the public would be protected in the event of a release of ammonia. The agreement requires the business to install some detection and alarm systems at facilities across the country, as well as train the responders. Here are the details of the settlement agreement regarding the detection and alarm system(s) being installed…
The Respondent agrees to install an ammonia leak detection system that provides continuous leak detection monitoring of the ammonia transfer and storage areas at each of thefollowing facilities: Lincoln, Alabama; Inkster, Michigan; Belvidere, Illinois; Council Bluffs, Iowa; Neosho, Missouri; Morgantown, West Virginia; Mount Hope, West Virginia; and Fayetteville, North Carolina. (PLEASE NOTE that a seperate and very similar agreement was issued to the same business for facilities in NC, RI, LA, and PA).
At a minimum, each ammonia leak detection system shall be comprised of the following equipment and shall be installed, operated, and maintained as follows:
- each system shall include a series of electrochemical type sensors working in conjunction with a multichannel monitoring station providing continuous monitoring for ammonia vapors, along with all necessary control panels, annunciator panels, power supplies, auto dialers, etc., needed for the operation of each system. Respondent shall work with the appropriate local authorities, e.g., the LEPC and/or fire department, to establish appropriate detection thresholds which would cause the ammonia leak detection system to emit an ammonia alarm alerts and alarm signals, but, in no case shall such limits be set at greater than 25 to 50 parts per million (TLV for ammonia is 25 ppm) for alarm alerts and 230 to 250 parts per million (IDLH for ammonia is 300 ppm) for alarm signals. Whenever an ammonia alarm or alert signal is generated, an on-site warning strobe light and a warning horn or siren shall be activated;
- each ammonia leak detection system shall include an emergency power backup system in the event of power loss to a facility;
- each ammonia leak detection systems shall be supported by routine maintenance and calibration schedules; and
- all ammonia alert and ammonia alarm signals shall be monitored 24 hours a day and seven days a week under one of the following four approaches:
- alert and alarm signals shall be continuously monitored by an external manned third party alarm agency. The alarm agency shall follow a defined hierarchy protocol for immediate notification of site personnel, facility management, and local emergency responders;
- all alert and alarm signals shall be continuously monitored by an automatic dialing system programmed to provide immediate voice phone call notification to a predetermined call list. In the event of an alarm signal, the call list shall include, at a minimum, local emergency response personnel. The automatic dialing system shall continue to provide voice phone call notifications until a security code is entered to terminate the calls;
- a combination of third-party monitoring and automatic dialing notifications, i.e., a combination of the specific requirements set forth in subparagraphs (a) and (b), above, shall monitor ammonia alerts and alarms; or
- such other monitoring protocols as may be required by the local authority, but in no case shall the monitoring protocols be less stringent than the requirements contained in subparagraphs (a) through (c), above.
- Upon installation of the ammonia leak detection systems and their associated alarming systems, “the business” shall coordinate with the appropriate local authorities, e.g., the LEPC and/or fire department, to ensure that they are the familiar with the warning and alarm systems installed and the appropriate protective actions to take in the event the alarms are triggered by an ammonia leak. “The business” shall also ensure that procedures are established that provide reliable and timely notification by the facility emergency coordinators and/or the community emergency coordinator to persons designated in the emergency plan that a release has occurred, and that appropriate protective actions, such as shelter-in-place or evacuation, should be taken. “The business”must also conduct adequate outreach and training about the animonia leak detection systems in order that emergency responders understand the meaning of the on-site warning strobe light and warning horn or siren, if they are activated.
- Beginning within thirty (30) days after the effective date of this CAFO, Respondent shall commence installation of the ammonia leak detection systems, as described above, at one or more of the facilities identified above. On or before April 1, 2013, Respondent shall have completed installation of the ammonia leak detection systems, as described above, at each of the listed transfer facilities. Upon completion of the installation of an ammonia leak detection system at any of individual facilities, Respondent shall commence and continue operation of such system at that facility. Prior to installation and operation of an ammonia leak detection system at a particular facility, Respondent agrees to undertake reasonable efforts to implement an adequate procedure for notifying the local emergency response personnel of an ammonia leak from the facility.
- As part of this settlement Respondent agrees to operate and maintain the ammonia leak detection system at each transfer facility listed above.
- The total capital cost of the ammonia leak detection equipment for the specified transfer facilities is estimated to total $70,235.00. The total installation cost of the ammonia leak detection equipment for the specified transfer facilities is estimated to total $67,025.00. Accordingly, the total of the capital cost and installation cost of the ammonia leak detection system for the facilities identified in Paragraph 53 is $137,260.00. The total cost of operating and maintaining the ammonia leak detection equipment for the specified transfer facilities for a one year period is estimated to total $18,904.00. Respondent must spend at least $175,068.00 on the ammonia leak detection systems described above. For purposes of accounting only, the $175,068.00 includes the capital and installation costs identified above in this Paragraph and the costs associated with two years of operation and maintenance of the ammonia leak detection systems.
- U.S. EPA may inspect the ammonia transfer facilities listed above at any time to monitor Respondent’s compliance with this CAFO’s Work requirements.
- Respondent must maintain copies of the underlying research and data, if any, for all reports submitted to U.S. EPA according to this CAFO. Respondent must provide the documentation of any underlying research and data, if any, to U.S. EPA within seven days of U.S. EPA’s request for the information.
- The Respondent shall submit an ammonia leak detection system Construction Completion Report to U.S. EPA by June 1, 2013. The Construction Completion Report shall contain the following information:
- a description of the ammonia leak detection system as built and as installed at each ammonia transfer facility;
- copies of all operating plans, operating protocols, or manuals for each ammonia leak detection system, including copies of the operating and maintenance plans, for each of the ammonia transfer facilities listed above;
- itemized costs of goods and services used to complete the Work, documented by copies of invoices, purchase orders, or canceled checks that specifically identify and itemize the individual costs of the goods and services; and
- certification that Respondent has completed the construction and installation Work in compliance with this CAFO.
- Within 30 days after the end of the two (2) year period that commences after Respondent completes installation and makes operational the last ammonia leak detection system (in no case shall this two year period commence later than on April 1, 2013), Respondent shall submit an ammonia leak detection system Operation and Maintenance Report to U.S. EPA. The Operation and Maintenance Report shall contain the following information:
- a description of the operation and maintenance of the ammonia leak detection system built and installed at each ammonia transfer facility;
- a description of all ammonia leak detection system operating problems(e.g., problems with the operation of warning lights or sirens; functionality of the phone tree; problems is giving required notices) and the actions taken to correct the problems at each of the ammonia transfer facilities listed above;
- itemized costs of goods and services used to complete the Work, documented by copies of invoices, purchase orders, or canceled checks not previously submitted to U.S. EPA as part of the Construction Completion Report, that specifically identify and itemize the individual costs of the goods and services; and
- certification that Respondent has completed the Work in compliance with this CAFO.
CLICK HERE (pdf) to see the EPA Agreement