Ammonia Release: The ONE PLAN Integrated Response Strategy

By GARY W. SMITH

In 1992, as chief of the Watsonville (CA) Fire Department, I joined with Douglas Hill, then chief executive officer of Hill Brothers Chemicals in San Jose, California, to form the Ammonia Safety and Training Institute (ASTI), a nonprofit organization dedicated to making ammonia one of the most safely managed hazardous materials in the world. Over the past three years, ASTI has received Federal Emergency Management Agency (FEMA) Firefighters Grant Program funding to provide firefighter emergency response training for ammonia emergencies nationwide. In fostering cooperation and coordination between fire service and industrial response teams, during the past four years, ASTI has trained more than 2,000 firefighters in metropolitan areas across the United States.

Firefighters nationwide share the following four key concerns about ammonia emergencies:

• the flammability of ammonia;
• the life hazard within the invisible vapor above the level immediately dangerous to life or health (IDLH) [300 to 5,000 parts per million (ppm)], including the viability of shelter-in-place, and the first-arriving company’s ability to perform rescue;
• the recognition and the mitigation of a potential catastrophic event involving ammonia; and
• the containment, control, and mitigation methods for an aerosol release of ammonia.

MOTIVATION

Several key events led to the formation of ASTI and later to the Integrated Response Strategy (One Plan). In 1982, there was a dramatic release of ammonia from a railcar at Hill’s San Jose, California, plant. He recognized the value of a relationship between his plant’s response team and that of the San Jose Fire Department hazmat team in responding to the release of a dense ammonia cloud into the local community.

In 1985, the Watsonville Fire Department responded to an engine room fire at the Del Mar Cold Storage facility. Although the fire was extinguished before it spread to the cold storage warehouse, no one on the command team or any of the six refrigeration engineers standing by knew much about the hazards, risks, and threats of ammonia while fighting a fire. There was 30,000 pounds of ammonia inside the engine room and within the condensers on the roof. Fortunately, luck prevailed over knowledge. Today, I am grateful for the Del Mar Cold Storage incident for the preparation and training that this potentially catastrophic event inspired.

Several months after the Del Mar incident, I read an article about a 1984 ammonia flash fire at the Dixie Cold Storage building in Shreveport, Louisiana. The flammability of a dense cloud of ammonia surprised me and the emergency response community. Captain Percy Johnson and Assistant Chief Training Officer Pat Johnson (no relation), both members of the Shreveport Hazardous Materials Response Team, entered a cold storage room to repair a leaking valve. A dense ammonia vapor cloud had developed, decreasing visibility. Wearing butyl rubber chemical vapor protective clothing (i.e., Level A), Percy Johnson was positioning a forklift to gain access to the leaking valve while Pat Johnson was standing by with valve repair tools. A spark from the forklift ignited the dense cloud of ammonia, resulting in a flash fire deflagration explosion similar to a structure fire backdraft. Both firefighters were thrown to the floor from the concussion of the flash fire, and their butyl rubber entry suits caught fire. The burn injuries claimed the life of Percy Johnson and seriously burned Pat Johnson.

Few people knew that ammonia would burn with such force. Many from industry would not believe that ammonia was the cause of the flash fire. Pat Johnson survived and began working with ASTI to spread the word on the ammonia flammability issue.

In 1991 Anders Lindborg, an engineer from Helsingborg, Sweden, replicated the circumstances that led to the ammonia flash fire in Shreveport. His work triggered a higher level of concern about the flammability of ammonia. Today, we know that at a concentration of 15 to 28 percent, ammonia in the air will ignite with flash fire explosive force when the mixture is confined within a room or building and exposed to an ignition source at 1,204°F. Anders also showed the difficulty in igniting an ammonia cloud in an outside environment. The fuel/air mixture diffuses quickly to the atmosphere so the potential for a huge flash fire is significantly diminished. After 25 years of investigation, I have found only one case of an ammonia flash fire occurring in an outside environment. That happened in Sacramento, California, in the early morning hours in May 1987. Sacramento Fire Department Battalion Chief (Ret.) Jan Dunbar described how the 5,000-gallon ammonia semi tanker crashed off the overpass leading to Interstate 5. The tank blew open on both ends. A huge dense gas cloud formed and eventually ignited as it rose above the crash site.

THE FIRST 30 MINUTES

Every chief officer that I know agrees that the successful management of an emergency starts with the correct size-up and incident action plan (IAP) engaged by the first responders. If they set it up correctly, the rest of the incident will most likely follow safely and effectively. This is especially true for response to ammonia emergencies. The responders’ actions in the first 30 minutes of response are crucial for controlling the incident.

The plant response team must be prepared to immediately meet the first-arriving fire officer at an agreed-on command post or meeting site to provide a Conditions–Actions–Needs report (CAN). The first responders’ level of engagement may be limited to moving people away from the incident and standing by until a hazmat response team or technical specialist can provide additional tactical guidance. Depending on the location, the response time and setup of a hazmat team could take an hour or more. Meanwhile, the challenge of initiating an emergency shutdown (which will significantly reduce the impact of the problem) may get lost in the “chaotic shuffle” between plant and public safety responders. The following ammonia release scenario is an example of the many things that complicate the discovery and initial response. The scenario exposes the issues that prove the value of developing a properly focused “teaming agreement” between industry and the fire service BEFORE the emergency event occurs.

Release scenario. The fire department is dispatched to an industrial refrigeration cold storage warehouse for a reported ammonia release. The first-arriving fire officer smells a strong odor of ammonia several blocks from the scene.

• Should the fire officer in charge change the response route?
• Is there an alternate travel route available to all responding units based on wind movement?

As the engine enters the driveway, the fire officer sees 30 employees moving in a group; some are coughing and covering their noses and eyes, showing obvious signs of ammonia exposure.

• Where is the person in charge?
• Can the person in charge deliver an accurate, concise CAN report?
• In what direction is the ammonia traveling and how big is the Initial Isolation Zone?
• Where is a safe location to set up command?
• Who will take care of the employees who have been exposed to the ammonia? Will decontamination be necessary?
• What conditions are causing the threats of the emergency event to grow? Is high pressure or fire a possibility? Are there compressors operating, adding more pressure and volume to the release? What can the crew safely do for the next 30 minutes?

The plant incident commander (IC) reports to the fire department IC. What are public emergency responders expected to do?

• Rescue a down refrigeration operator?
• Support (if present) the industrial emergency response team as it engages in emergency shutdown of the refrigeration system?
• Ventilate ammonia vapor before the dense gas cloud ignites?
• Supply and use the ammonia diffusion system, if present, using the fire department connection?
• Decontaminate and provide medical treatment of a semi-conscious victim with an aerosol ammonia burn?
• Who will be in charge, and what will be the initial incident action plan?

What other life safety challenges exist?

• What is the status of the employees, visitors, and anyone downwind in the Initial Isolation Zone?
• What about the truck driver who is asleep in his truck?
• What about the delivery van that just entered the driveway and will drive through the ammonia vapor?

Collaboration at the command scene between the industrial and public safety response teams is critical to forming an effective response plan that minimizes the chaos and maximizes the opportunity to stop the problem when it is small. That’s easy to say, but how do you do it?

INTEGRATED CONTINGENCY PLAN (ONE PLAN)

In October 2007, ASTI hosted a two-day joint meeting with the International Association of Fire Chiefs Hazmat Committee leadership and the ammonia industrial association leaders in Alexandria, Virginia. All agreed that there was a substantial need for improving operational coordination between industrial and public safety response. To meet this need, the group chose the Integrated Contingency Plan (One Plan), developed by the National Response Team (NRT) as the framework for creating operational checklists and other response guidance.

One Plan is designed to consolidate multiple facility response plans into one to minimize duplication and simplify plan development and maintenance. The goal is to coordinate planning and response within the facility and between the public and commercial responders so that it complies with the National Incident Management System.

The One Plan Strategy is to engage preemergency protocols and a four-phase emergency response plan guidance for Discovery, Initial Response, Sustained Response, and Incident Termination by using the following operational guidance.

1 Core plan. This is an overview of the hazards and risks (hazard control zones), response staffing and resources, and strategy for engaging control for the most likely and the highest-threat-potential emergencies.

2 Field operations guide. This is a time-critical (i.e., in the earliest stages of a response) framework to guide responders through the key steps necessary to mount an effective response. The response action section should be convenient to use and understandable at the appropriate skill level. The NRT recommends the use of checklists or flowcharts wherever possible to capture these steps in a concise, easy-to-understand format.

3 Levels of concern. Commonly used in emergency planning for classifying emergencies according to seriousness and assigning an appropriate standard response or series of response actions to each level to reduce reaction time, this process allows response personnel to match the emergency and its potential impacts with appropriate resources and personnel.

The level of concern must connect to the checklists or flowcharts used to engage emergency action. The plant owner must determine appropriate response levels based on the need to initiate time-urgent response actions to minimize or prevent unacceptable consequences to the health and safety of workers, the public, or the environment and the need to communicate critical emergency information to off-site authorities.

The consideration and development of response levels should be consistent with similar efforts that the local emergency planning committee or mutual-aid organizations may make. Response levels, which are used in communications with off-site authorities, should be fully coordinated and use consistent terminology.

CAN report. The decisions that a first-in officer makes for an ammonia emergency closely parallel the logic used for managing a structure fire. The response plan starts with an assessment of life safety concerns. ASTI has worked with the fire service and industry to create a CAN size-up form that highlights the size-up issues.

The 30-Minute Plan Emergency Control Guide. To bring clarity, teamwork, safety, and timely response into the emergency response action plan, ASTI has assembled a quick checklist, the 30-Minute Plan Emergency Control Guide, which covers the first 30 minutes of each phase of emergency response (Discovery, Initial Response, Sustained Response, and Incident Termination). To provide a safe and an effective outcome, local public safety and industrial responders must integrate their joint expectations into a well-rehearsed game plan. To see these and other related response guidance documents, visit http://emberly.fireengineering.com/webxtra.html.

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