2019 RETA Breeze Jul-Aug

EDUCATION

Anhydrous Ammonia and the Form “R” Trap

By: Victor Dearman Corporate Environmental & PSM Manager Peco Foods, Inc.

what that article said. What the article actually says is “An often- cited rule of thumb is 5%-10% loss annually of the total system charge, depending upon the age, size and condition of a system.” I think it stands to reason that a newer system that is well kept should have losses of an absolute minimum. Whereas older, less well kept systems will experience higher rates of losses. 3. Replacing significant amounts of ammonia in a refrigeration system on a frequent basis implies that we do not, in fact, have control of the process. WHAT IS FORM“R” AND HOW DOWE USE IT? First, almost everyone is familiar with having to file annual Tier II’s. The Tier II requirement comes from EPCRA 312 (Emergency Planning and Community Right to Know Act). These Tier II’s go to your LEPC and SERC (local and state) as well as to your local fire department. In the event of a fire or HAZMAT scenario, they need to know what you have on site as a potential hazard, and how much of it there is to deal with. In any Next, if a facility has received into their system 10,000 pounds or more for the purposes of a “re-charge” or topping the system off AND have 10 employees or more then they are required to file a case, this information has to be updated annually by March 1.

Form“R”. Under this premise, the amount used to “re-charge” or “top off” the system, the chemical is considered “otherwise used” by the system. It’s worth mentioning that the facility would also have to be classified as “Standard Industrial” but if very rare for that not to be the case so it’s almost always assumed. This requirement comes from EPCRA 313 and is identified through your NAICS codes. This report is also known as TRIR. The premise for this article was driven from a citation from the EPA against a food manufacturer. So, we’re going to review EPCRA 313 Reporting Guidance for Food Processors. Exact qualifiers for reporting Form“R” under this heading can be negotiated using the flow chart in Figure 2-1. So, as you can see from the flow chart, if you do not meet any of the criteria shown, then filing Form“R” is not required. Now for the obvious question: Where did that ammonia go if we didn’t have any releases of reportable quantity? Ammonia refrigeration systems are closed loop and meant to be leak free. However, there will always be losses through valve packings, shaft seals, oil

THE ISSUE:

Before anyone casts any stones my direction, let me clarify a few things; 1. I am in no way making the stance that I believe that it is normal to be losing this much ammonia from your refrigeration systems, and; 2. The above was referenced from an actual citation and is NOT exactly of ammonia loss. They have done some math and think your losses are excessive and now they want you to explain your losses. The EPA has just visited your facility and mentioned that you’re purchasing too much ammonia for your refrigeration system annually and has referenced the February 2012 IIAR Condenser Magazine Article where the Technical Director for IIAR indicated that 5-10 percent loss annually of the total system charge of ammonia is an often-cited rule of thumb for a typical amount

draining, auto purgers, and line equipment opening for system

maintenance. Projects also account for some losses. There are times when a

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