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.
Catastrophic event preparedness. Catastrophic ammonia emergencies occur for two main reasons: Responders are not prepared to act swiftly to mitigate the problem safely when it is small or there is an unanticipated explosion, flash fire, or valve failure that immediately releases a large aerosol stream. The overall game plan for addressing an ammonia emergency depends on the response team’s understanding of and preparation for the hazards, risks, and threats. The One Plan provides a Hazard Analysis Quick Guide (Figure 1) to judge the possibility of a catastrophic event. The 30-Minute Plan Emergency Control Guide provides checklist readiness reminders to ensure that the proper actions are taken to prevent, mitigate, and respond to the threats to avert a catastrophic event.
Figure 1. Hazard Analysis Quick Guide |
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Hazards are the chemical/physical characteristics of the products stored in the hazard area. Risks are the probability or likelihood of life safety, environmental damage, and property loss concerns within the Initial Isolation and Protective Action distances. Threats include potential fire/explosion, release, or overpressure circumstances.
Emergency responders should train routinely and develop muscle memory for ammonia’s hazards, risks, and threats. The Hazard Analysis Quick Guide offers reminders for dealing with the emergency challenges during the Discovery and Initial Response phases (life safety, rescue, and emergency shutdown). One Plan provides a more detailed hazard analysis to support the hazmat technicians’ safety before they enter the hot zone to contain, control, and mitigate the emergency event.
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 assessing life safety and the need for rescue.
ASTI created the Hazard Analysis Quick Guide to give the first-in officer information to determine the risk-vs.-gain of a rapid-entry rescue involving ammonia. The Level of Concern (LOC) associated will indicate the status of the release.
The guide first provides data concerning ammonia’s flammability, high pressure, and the National Fire Protection Association 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, reminders.
The IC determines the size of the Initial Isolation Zone, based on the U.S. Department of Transportation Emergency Response Guidebook Table 1 distances. This will be the area of highest life threat for the first 30 minutes.
The LOC will give the IC a method of gauging the progress of the incident. If the LOC is low (Level 1 or 2), the incident is less likely to grow quickly than if the LOC is 3 (uncontained and uncontrolled). The decision to enter for a rescue is safer when emergency shutdown has occurred and conditions are improving.
The officer in charge must decide whether the victim is viable. The National Advisory Committee for the Development of Acute Exposure Guideline Levels (AEGL) developed them to help national/local authorities and private companies deal with emergencies involving spills or other catastrophic exposures. The Environmental Protection Agency (EPA) recommends that emergency responders use the AEGL to describe the risk to humans resulting from once-in-a-lifetime (rare) exposure to airborne chemicals. The listings for the AEGL indicate the beginning level of exposure for each of the three levels:
- AEGL 1: Not disabling and transient and reversible upon cessation of exposure.
- AEGL 2: Could experience irreversible or other serious, long-lasting adverse health effects or an impaired ability to escape.
- AEGL 3: Above which it is predicted that the general population, including susceptible individuals, could experience life-threatening health effects or death.
The likeliness of surviving levels above 5,000 ppm for more than a few minutes is very low.
For more details about the use of AEGL guidelines, go to http://www.epa.gov/oppt/aegl/pubs/define.htm.
Rescue risk vs. gain. The first responder should consider AEGL 3 when deciding the viability of a rescue for a victim who is in an ammonia vapor cloud above 2,700 ppm for more than 10 minutes. ASTI recommends that rescue is appropriate if the levels are between 2,700 and 5,000 ppm. The decision to make a rescue also includes consideration of the growth of the release during the five to 10 minutes it takes to make the rescue. The plant operator’s completion of emergency shutdown and ventilation will reduce the risk and threat of the release, making rapid-entry rescue decisions more viable. ASTI does not recommend entry into a cloud of ammonia anywhere close to an aerosol stream of ammonia; poor visibility and cold temperatures are serious threats to the responder, and the victim will not likely survive more than a few minutes in that level of exposure.
Validation of response recommendations. ASTI does live-ammonia training with industrial and public safety responders. Rapid-entry rescue while wearing turnouts or overalls (with full-length pants inside) within an environment of 5,000 ppm of ammonia VAPOR (without the presence of a dense gas cloud or an aerosol stream) has been acceptable.
The IC must make critical life safety decisions starting with the escape route or shelter-in-place plan-it is often more logical to move people to a safe refuge inside the building. The AEGL levels help the IC to determine the risk associated with vapor exposure to those moving to the rally point vs. those sheltered inside. The eye-level wind movement is also critical when defining the Exclusion Zone (Hot Zone) and movement of personnel. The wind sock on the roof will show the downwind threat while the eye-level wind is bouncing off the building walls going in the opposite direction within the Isolation Zone.
The ammonia One Plan stresses the value of the emergency shutdown procedures for reducing the risk and threat of an emergency. A playbook of actions needed to control sources of ignition, isolate the flow to the release point, manage pressure, and ventilate dangerous vapor can be accomplished by trained plant responders while working outside of the IDLH atmosphere (300 ppm). It is very important that the public safety responders recognize that the plant responders have been trained to engage this plan before an emergency occurs. The fire department officer-in-charge is more likely to support emergency shutdown knowing that a trained and properly equipped plant responder is doing it.
The threats associated with an aerosol stream can be significantly reduced by engaging the “tarp-and-cover” tactic. ASTI has more than 25 years of experience working with tarp-and-cover aerosol containment. The contained aerosol release recondenses into a liquid and settles into a puddle of liquid that is much less dangerous. A properly equipped hazardous materials technician-trained team must perform the tarp-and-cover action when working within a dense gas cloud or near an aerosol stream. The aerosol will easily reach –60°F to –80°F. ASTI works with responders to work outside the dense gas aerosol to place the tarp.
When hazmat technician-level responders arrive, the highest immediate life safety and emergency shutdown challenges should already be managed. The One Plan offers the command team packets that include the following:
- Playbook details (pictures, diagrams, and checklist reminders).
- Incident Command System (ICS) 201 Initial Incident Action Plan.
- ICS 208 Site Safety and Control Plan.
- A Detailed Hazard Analysis.
Deciding whether to enter the Hot Zone is tied directly to the level of personal protective equipment (PPE) training and the ability to monitor the ammonia vapor. The protections PPE affords are summarized at the bottom of the Hazard Analysis Quick Guide.
It is very important to train on the One Plan readiness, especially emphasizing the integration of public safety and plant emergency responder activities. The details of how to accomplish the life safety and emergency shutdown procedures should be on top of the list on the responder teaming agreement. The technical information and review of playbook details relating to an IAP that requires entry into a Hot Zone are essential parts of the annual walk-through training session. ASTI has sample versions of the Teaming Agreement and a lesson plan for performing a joint training session between industry and public safety while using the One Plan.
All-hazards. The One Plan system is designed to provide an all-hazards approach to managing emergencies. The operational tools (playbooks, checklists, and guidance summaries) can all be easily adapted to fire, other chemicals, disaster circumstances, and so forth. The command team and method of integrating response between industry and public safety used for ammonia response can be used by responders dealing with an industrial accident, a medical emergency, a bomb threat, or other type of event. The checklist and other guidance details would change for the specific circumstance.
Industry and fire service leaders agree that the Integrated Contingency Plan (One Plan) provides the most effective emergency planning guidance for the discovery, initial response, sustained response, and termination phases of an emergency. ASTI has created the One Plan checklists, playbooks, and quick guides mentioned above for an anhydrous ammonia response to help emergency responders “operationally” engage the plan in a timely, safe, and effective way.
The four most pressing concerns about ammonia expressed by firefighters trained by ASTI over the past four years (listed at the beginning of this article) have provided a great framework on which to focus the operational guides and the training plan. The issues associated with ammonia risk and threat can be minimized when the emergency responders understand the hazards, risks, and threats of an emergency. The team connection among plant responders, first-in public safety response, and the hazmat team relates directly to the checklist recommendations of the One Plan.
Note: The Ammonia Safety and Training Institute Web site www.ammonia-safety.com offers podcast training and other information on how to implement the One Plan in your community. ASTI will work with departments to sponsor local area classes. We also present free Safety Day training sessions across the country.
GARY W. SMITH is the president of the Ammonia Safety and Training Institute, founded in 1992. He retired in 2003 as chief of the Watsonville (CA) Fire Department.
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