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Ammonia is one of the most commonly produced industrial chemicals in the United States. It is a naturally occurring compound and it is not considered to be a contributor to ozone depletion, greenhouse effect or global warming. It is a key intermediate in the nitrogen cycle, a process by which nitrogen is converted into various chemicals forms, and carried out through both a biological and physical processes.

Understanding the role of ammonia in the nitrogen cycle is important.

The Process

There are four key processes in the nitrogen cycle that result in the transformation of ammonia. These processes are; Nitrogen Fixation, Ammonification, Nitrification, and Denitrification. As part of this cycle, nitrogen gas and oxidized forms of nitrogen are transformed and returned to the biological world.

The process begins with Nitrogen Fixation, this is the process by which nitrogen gas, in our atmosphere, is converted into organic nitrogen. This occurs naturally in free living soil bacteria as well as other bacteria that forms symbioses with legumes and other plant life.

Organic nitrogen then goes through a process called Ammonification also known as nitrogen mineralization and is the conversion of organic nitrogen into ammonia.

Next, is the biological oxidation of ammonia nitrogen to nitrate, with nitrite serving as the intermediate (NH4) - (NO2) - (NO3) this is referred to as Nitrification.

Finally, there is denitrification a process whereby the nitrogen oxides (i.e., nitrate and nitrite) are reduced under anaerobic conditions to (N2) and (N2O) which are colorless odorless gasses that are safe to be released back into the atmosphere and environment.

The diagram below take from The Ammonia Data Book gives a simplified visual of the Nitrogen Cycle.

Other common ways ammonia is released into the atmosphere.

There are also several other ways in which ammonia is released into the environment. Daily life cycle occurrences play a vital role in the release of ammonia into our water, soil and atmosphere as well.

Decaying matter, livestock excreta, burning of coal wood and other natural products are contributors to ammonia releases in the atmosphere and soil (more or less becoming part of the nitrogen cycle).

Ammonia can also be released into our water through effluent from sewage treatment plants, effluent from the industrial process, and runoff from fertilized fields and over populated areas containing livestock.

The industrial refrigeration industry has a very small effect on the overall environment in terms of ammonia. We contribute less than 1% of ammonia into the atmosphere. Ammonia is a natural part of our environment and imperative, not only to the nitrogen cycle, but to many other biological processes as well. As a natural gas (and refrigerant) in most cases it is hazardless.

For more information on the effects of ammonia as a natural refrigerant check out The Ammonia Data Book or visit our elibrary for related material   


On November 17
th, 2015 Tony Lundell Director of Standards and Safety at IIAR presented “Pressure Vessel Replacements Considerations”, a 12 step question and answer webinar to help identify the most important questions you should ask when considering pressure vessel replacement.  These 12 questions and answers were intended to be a good start when choosing your pressure vessel replacement and can better help you communicate with a manufacturer to ensure the most integrity for the least cost in the long run. The webinar also included detailed pictures of pressure vessels to help illustrate common issues and possible solutions in pressure vessel replacement.

The purpose of this webinar was to identify vital information to consider when indeed it is time to replace pressure vessels. Tony explored the top twelve considerations in depth covering everything from, how long a replacement vessel should operate safely once installed, to whether or not the pressure vessel needs to be insulated.

“The twelve questions are a good start for considerations leading to further questions as needed on a case-by-case basis when replacing a pressure vessel” says Tony. “The most critical of all is to ensure your pressure, temperature, and capacity is adequate for your replacement vessel that meets or exceeds what the current vessel has handled or what the replacement needs to handle in the short range and/or long range for a safe design." 

The information in this webinar is supported by the information in the newly revised IIAR-2 Standard. This previously recorded webinar “Pressure Vessel Replacements Considerations"s is available to all IIAR member through our website in the exclusive members only section. Just sign in to the iiar website, go to Members Only, Member Webinars, IIAR Daily Inspection: Pressure Vessel Replacement Considerations

The COP21 meeting which recently took place in Paris France from November 30th, 2015 to December 11th, 2015, was the 21st meeting of the Countries of Participation (COP) under the UN Framework on Climate Change (UNFCCC).  The main objective of this annual meeting is to review the Rio Declaration on Environment and Development adopted at the Rio Earth Summit in 1992.  Significant meetings of the COP were COP3 when the Kyoto Protocol was adopted and COP11 when the Montreal Action Plan was produced. Both of which have had a significant impact on the residential, commercial and industrial refrigeration industry with regard to ozone depleting substances.

The specific aim of the COP21 meeting was to achieve a legally binding and universal agreement on climate change worldwide. The ultimate goal is to limit the rise of global temperatures to at or below 2 °C by the end of the century by reducing carbon emmisions. 2 °C has been determined to be the point beyond which dangerous climate change could threaten life on Earth.

After much discussion, it was agreed, by the 196 nations in attendance including the United States, to adopt what has been termed as the “Paris Agreement”. Under this agreement the United States, along with 195 other countries, have agreed to develop a carbon reduction plan with Intended Nationally Determined Contributions (INDCs) which are basically emission reduction targets.  Counter to the original goal of the COP21 meeting, this agreement is not legally binding, however, by terms of the agreement, INDCs must be reviewed by each country every 5 years to ensure transparency and accountability.  The issue of legality relates back to the 2009 climate summit in Copenhagen where observers say the attempt to impose legally binding targets on countries at that point was one of the reasons why the talks failed to produce a consensus outcome.

Under the “Paris Agreement” The United States has agreed to reduce its greenhouse gas emmissions by 26-28% below its 2005 level by 2025. You can review the United State's INDC here.

Another achievement of the “Paris Agreement” is what is being referred to as climate aid - rich countries helping poor countries achieve climate goals through funding and loan guarantees to help with financing carbon reduction, clean energy, and clean air initiatives.

The Paris meeting is being hailed as historic in the fact that the world, not just a few invested countries, has agreed that climate change is a huge issue that needs to be addressed.

Most analysts agree that limiting the rise of global temperature is a large task and we might have promised more than we can deliver from a political and social standpoint, nevertheless, the United States has produced an INDC and will be reviewing its goals under the “Paris Agreement” moving forward every 5 years.

What does this mean for the industrial refrigeration community?

The phase out of ozone depleting chemicals and stricter regulations on chemicals with global warming potential has forced the refrigeration industry to rethink the viability of certain refrigerants for future use in domestic, commercial, and industrial systems.

The Montreal Protocol saw us reducing, with the eventual phase out, of CFCs and HCFCs (HCFCs by 2015 in the United States) which were mainly replaced by HFCs, to a world where we are seeing that HFCs are being reduced and/or phased out completely. The EU has already experienced massive mandatory phase outs of certain HFCs.

According to Lowell Randell, Director of Government Relations at IIAR, parties to the Montreal Protocol met in Dubai in November 2015, prior to the Paris meeting, to discuss the potential expansion of the Montreal Protocol to include HFCs.  At the conclusion of the meeting the countries announced an agreement to include HFCs as a part of the protocol.  The so-called “Dubai Pathway” will be the focus of several meetings in 2016, with the goal of completion by the end of next year.

A technical paper entitled “Refrigerant and Regulatory Developments: Changes Impacting the Opportunities for Natural Refrigerants” presented at the 2015 IIAR Industrial Refrigeration Conference & Exhibition by Rajan Rajendran, Ph.D. of Emerson Climate Technologies states that CFCs and HCFCs have already been phased out in Europe and that hydrocarbons like isobutene and propane have already become quite common in domestic refrigeration.  According to the paper, CO2 as a refrigerant in stationary refrigeration systems has grown in usage and acceptance in Europe and Australia and is making inroads in North America and elsewhere and that as the use of HFCs declines in industrial applications we will see the same sort of trends in architecture and fluids as we have seen in commercial applications.

Just recently we witnessed the removal of certain approved HFC refrigerants by the EPA from their list of approved refrigerants. See IIAR's SNAP Action Update

As the United States agrees to abide by stricter climate regulations globally we will see more national restrictions like these take place.

We have only to look toward the EU to understand the challenges they have faced and the changes they are making with regard to the refrigeration industry. They have already had to adhere to stricter phase down and phase out laws. Overall as we see the regulatory climate become much tougher, the industry will need to transition accordingly. The momentum is happening and we have already seen more cross-over with Ammonia, CO2and other natural refrigerants in both commercial and industrial applications.

Ammonia with its GWP of 0 is the perfect refrigerant to lead the pack in this time of transition and CO2 comes in as a close second with a GWP of 1. Dave Rule, President of IIAR says, "Applying these two natural refrigerants in the commercial and industrial sectors makes good sense for the future of the refrigeration industry."

As Lowell Randell states, “The efforts in Dubai and Paris are further indications that the international community is coming together to reduce carbon emissions and phase down the use of substances such as HFCs.  These activities have the potential of generating more interest in natural refrigerants such as ammonia as facilities look for alternatives and transition away from HFCs in the future.”


Member's may access Rajan Rajendran's paper by signing in to the IIAR website.  Go to Members Only, eLibrary, Technical Papers Archives.  

Useful Terminology

CFC Refrigerant: ChloroFluoroCarbon - the refrigerant is comprised of Chlorine, Fluorine, and Carbon. Example: R11, 12,13,113,114, and 115.

HCFC Refrigerant: HydroChloroFluoroCarbon - the refrigerant is comprised of Hydrogen, Chlorine, Fluorine, and Carbon. Example: R22.

HFC Refrigerant: HydroFluoroCarbon - the refrigerant is comprised of Hydrogen, Fluorine, and Carbon Example: R134a.

 

On August 26th and 27th, IIAR’s own Tony Lundell spoke at The Process Safety Compliance for Food and Beverage Industries Conference. This is a two day event focusing on building a strong process safety management culture in order to achieve a high level of operational discipline. This event is held annually and is open to all industry professionals.

Tony’s presentation included discussion on the recent updates to the IIAR suite of Standards. IIAR Standards contain both normative and informative information, establishing both the minimum requirements for industry compliance and advisory information where applicable. IIAR Standards are ANSI approved as they are subject to a rigorous public review process to ensure that they represent an industry consensus.

Tony discussed how changes to IIAR ‘s Suite of Standards could positively affect the natural refrigerant industry and also enhance the Food & Beverage industry by bolstering their Process Safety Management (PSM) and Risk Management Plans (RMP) programs.   

“With the IIAR Suite of Standards being developed and published, the Food & Beverage industry will be able to enhance the PSM and RMP program, clarify Recognized And Generally Accepted Good Engineering Practices (RAGAGEP), and enhance steps to meet their compliance requirements” says Tony Lundell.

As a result, we can expect the communication and cooperation between the facilities and the regulators to be more effortless. Facilities will increase their safety of ammonia refrigeration system by ensuring they are properly operated and maintained, reducing the consequences of potential ammonia release.

The knowledge shared at this event has already been placed into practice and has contributed to the increase in system safety and reduction energy cost. Look out for IIAR’s Suite of Standards updates and be sure you are always in compliance.

For more information about IIAR Standards click here.

On October 27th, 2015, Eric Smith, Vice President and Technical Director of IIAR, attended a U.S. Department of Homeland Security (DHS) roundtable discussion and listening session intended to solicit the public’s views and recommendations on how the current Appendix A, Chemicals of Interest (COI), of the Chemical Facility Anti-Terrorism Standards (CFATS) program might be improved.

As part of the DHS CFATS program, Chemicals of Interest (COI), including anhydrous ammonia over the 10,000 lb threshold, are required to file a Chemical Security Assessment Tool (CSAT) Top-Screen Survey Application developed by the DHS to help identify high-risk chemical facilities which are subject to the Chemical Facility Anti-Terrorism Standards and to determine preliminary tier placements for those facilities. The term tier refers to the risk level associated with a facility covered under the CFATS program. Tier 1 is the highest risk level while Tier 4 would be the lowest.

If a facility possesses a COI that is on the DHS Chemicals of Interest list at or above the Screening Threshold Quantity (STQ) for any security issue including chemicals that pose a significant risk to human life or health if released, stolen or diverted, or sabotaged and contaminated, the facility must complete and submit a Top-Screen to DHS. If DHS makes a preliminary determination that a facility is high-risk, DHS will further require the facility to complete a Security Vulnerability Assessment (SVA).

The roundtable discussion and public listening session was held in Arlington, VA. Eric Smith was in attendance to provide requested feedback and to re-iterate the stance that IIAR has taken on the applicability of the Top-Screen process in regard to closed-circuit ammonia refrigeration systems.

As stated in a coalition letter, submitted to the U.S. Department of Homeland Security on October 17th, 2014 by Lowell Randel, Director of Government Affairs for IIAR, the stance that IIAR has taken, along with several other interested organizations, is that we strongly believe that facilities utilizing closed-circuit systems with anhydrous ammonia should not be subject to filing a Top-Screen unless another threshold quantity COI is present.

Even though IIAR members who operate facilities which include closed-circuit (loop) refrigeration systems with anhydrous ammonia at or above the STQ as their primary refrigerant are required to file a Top-Screen with DHS, we are not aware of any of our members that have been placed in a tier because of the risk posed by ammonia. Rather, these facilities are placed in a tier due to other threshold chemicals of interest also being present at the facility.

Furthermore, the current requirement for facilities with over 10,000 pounds of anhydrous ammonia used for closed-circuit refrigeration systems to file a Top-Screen under the CFATS program is duplicative and unnecessary. The issue of toxicity is thoroughly covered by the Environmental Protection Agency's (EPA) Risk Management Program (RMP) and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) regulations. RMP and PSM require facilities to develop detailed plans that address the risks of a toxic release of ammonia used for closed-circuit refrigeration systems. IIAR believes that through proper coordination and collaboration with other related U.S. government agencies, DHS will have sufficient information about facilities with threshold quantities of anhydrous ammonia, thus removing the need for these facilities to file Top-Screens solely because they have a threshold quantity of anhydrous ammonia that is used for a closed-circuit refrigeration system.

IIAR does not see a need for businesses to incur additional compliance burdens when facilities that use anhydrous ammonia for closed-circuit refrigeration systems are already covered under RMP and PSM. The addition of CFATS compliance adds unnecessary compliance costs for these businesses with no tangible benefit to security.

IIAR continues to advocate on behalf of its members in front of concerned government agencies.  IIAR also continues to create a positive ongoing dialogue with these government agencies to create a better working environment for all.

You may find more information on CFATS Program Here:  Chemical Facility Anti-Terrorism Standards

Attachments
DHS CFATS Coalition Letter October 2014.pdf Lowell Randel's letter to the U.S. Department of Homeland Security stating IIAR's stance on Top-Screen evaluations for closed-circuit ammonia refrigeration facilities.