This last week at the International Institute of Ammonia Refrigeration conference in Colorado the association announced three new initiatives for the association and our regulatory agency. IIAR is a great advocate for the promotion of natural refrigerants and an industry leader for best practices of design, build, maintenance, and operation of closed loop industrial refrigeration systems.
So what is IIAR working on for change with our regulators and what initiatives have emerged?
- Increase the EPA’s ammonia release quantity from 100 pounds
- Increase the time allowed for notifications to the NRC from 15 minutes to 8 hours
- Increase the IDLH for NH3 from 300 PPM to 500 PPM and allow the use of an APR to 500 PPM
All of this things sound like things that could reduce a small piece of the regulatory burdensome of process safety, but what is the likeliness of the regulatory agency conforming to these request? Most in this generation don’t know but the IDLH for NH3 use to be 500 PPM and most all manufacture filter cartridges can filter to levels much higher than either. It would be nice not have to call on all small contolled releases and only focus on emergencies conditions and more time allotted for notifications to the NRC, however how will that affect the timings with the LEPC and SERC?
