RC&E Chill - Industrial Refrigeration and Process Safety / Risk Management

Chill - We Got This!

IIAR 9-2020 Addendum A (202x) First (1st) Public Review

October 27, 2023 /

IIAR 9-2020 Addendum A (202x) First (1st) Public Review

 

Public Review Announcement

IIAR invites you to make comments for IIAR’s first (1st) public review of IIAR 9-2020 Addendum A (202x) Safety Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems.

 

Public Review Period: October 27th, 2023 through November 26th, 2023

 

Comments must be submitted to the IIAR Headquarters by 5:00 pm EST on November 26th, 2023. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.

You can review the document and make your voice heard at this link.

DHS: CFATS Announcement

August 3, 2023 /

CFATS Announcement

As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire.

Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. This means that CISA will not require facilities to report their chemicals of interest or submit any information in CSAT, perform inspections, or provide CFATS compliance assistance, amongst other activities. CISA can no longer require facilities to implement their CFATS Site Security Plan or CFATS Alternative Security Program.

CISA encourages facilities to maintain security measures. CISA’s voluntary ChemLock resources are available on the ChemLock webpages.

Happy 7/17!

July 17, 2023 /

Today is Ammonia (7/17) Day! 

Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.

Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century Swiss philosopher.

“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel

While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.

  • Show gratitude to your mentors
  • Become a mentor

 

Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.

Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.

 

Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.

“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen

 

To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!

Changing Fixed Ammonia Detectors: Does it need an MOC?

June 20, 2023 /

There are a lot of choices out there for fixed Ammonia Detection these days. Common brands include CTI, Manning / Honeywell, Danfoss, Bacharach, Draeger, Hansen, and CoolAir.

Obviously if you are installing a new detector in a General Duty or PSM/RMP covered process, you want to perform an equipment-level PSSR (pre-Startup Safety Review) for the detector. However, a common question we get is “does changing from one brand to another require an MOC?”

The root of this question is usually an attempt to justify the “change” as a “Replacement in Kind” and therefore avoid the paperwork of an MOC. But an MOC is not about PAPERWORK. An MOC is about thinking through the desired change (in a structured way) to see where problems can arise.

Put another way: Implementing the MOC procedure is how we answer the question of whether or not we need to document how we manage the change.

Let’s consider some things that might change when we replace one detector brand for another.

  • Sensor Type.
  • Sensor Range.
  • Signal Type / Range.
  • Enclosure Rating / Environmental Considerations.
  • Detector Placement.
  • Inspections, Tests & Maintenance.
  • Bump Tests / Calibrations.

Sensor Type: Electrochemical, IR, Catalytic Bead, etc. Each of these types of sensors has benefits and drawbacks based on the conditions they are used for and in. If you are changing technologies, how does that change affect your process?  

Sensor Range: Obviously the range of the sensor has an impact on how it works in your system. Replacing a 1-500ppm sensor with a 1-250ppm sensor without altering the system programming will report the wrong chemical concentration.

Signal Type / Range: Most sensor setups work on a 4-20mA signal, but some use Modbus or proprietary methods. You need to match your technologies or provide signal conversation.

Enclosure Rating / Environmental Considerations: Some sensors are subject to difficult environmental conditions such as blast-freezers and wash-down areas. You need to make sure that the sensor is suitable for the conditions you will expose it to.

Detector Placement: Manufacturer’s often provide recommendations on the height they want their detectors placed at. Make sure you are addressing those recommendations. If you are moving the Detector, are there any guarding considerations in the new location?

Inspections, Tests & Maintenance: Manufacturers have different inspections, tests and maintenance types and schedules. You must make sure you align to the manufacturers recommendations.

Bump Tests / Calibrations: Both the calibration method & frequency must be considered, including any unique calibration equipment and gases.

Conclusion: So, it’s possible that swapping a detector might well be a “Replacement in Kind” but there are a lot of things to consider before you arrive at that decision. You should use your MOC process to see if you need a formal, documented MOC.

June 16, 2023 /

The EPA has made a relatively small update to the process of submitting, updating, or correcting your RMP filing. The change is minor, but if not accounted for, it can slow down or stop your filing process.

What Changed?

  1. The facility’s Certifier (Certifying Official) is required to complete an “identity proofing” process.
  2. The Certifier must sign an electronic signature agreement (ESA) through the CDX portal.
  3. Electronic signature agreements are no longer required within RMP*eSubmit.

It has always been a requirement for the Certifier (and Preparers) to have profiles established through the CDX portal, but the identity proofing and CDX Electronic Signature Agreement (ESA) components are new.

It’s possible that this identity proofing and signature agreement are already taken care of, but it would still be prudent to ensure your Certifier has met these requirements several weeks before your RMP submittal/update are due.

Who is Affected?

The Certifying Official for your process’s RMP filing is the only one affected. The EPA defines these people as:

“Certifiers are facility owners or operators who must certify the accuracy and completeness of the information reported in the RMP. They have signed and submitted a one-time Electronic Signature Agreement (ESA) to the EPA. The ESA legally binds the Certifier’s electronic submission to their signature. Only Certifiers can submit the RMP.”

This is usually a plant manager, owner, or some other member of upper management. In order to be respectful of their time, it would be good to let them work through these new requirements well before the filing is due.

If you believe that your Certifier has already met these requirements, here is what the EPA’s guidance suggests to verify:

”Some existing users may not be impacted if they previously completed identity proofing and signed a standard CDX ESA for another program service that uses the same CDX organization as their RMP*eSubmit Certifying Official role.

…

Existing Users who Registered Before February 24, 2023
Existing users who have not verified their identity or without a standard CDX ESA will be prompted to complete identity verification and ESA when they access the RMP*eSubmit for the first time. The one-time process can be initiated by logging into CDX and clicking on the “Certify Submission” role link. Users will be able to complete this process using one of the below methods:

  1. Electronically – fastest method
    1. Verify identity using LexisNexis.
    2. If you pass verification, electronically sign the standard CDX ESA.
  2. Paper process – if you opt out of or fail the limited LexisNexis identity verification attempts
    1. Click “Paper Verification” option.
    2. Print the standard CDX ESA – the Status for the role will change to “Awaiting ESA Approval” on the MyCDX page.
    3. Sign the paper ESA with wet ink.
    4. Mail all pages of the ESA to the RMP Reporting Center (address located on the last page of the ESA).
    5. The RMP Reporting Center will verify ESA information and activate the role if appropriate.

Once the above electronic or paper process is complete, you will be able to access RMP*eSubmit.”

The EPA’s RMP eSubmit User Manual has more information, and detailed step-by-step instructions for any CDX portal or RMP filing questions you may have. (Link functional as of June, 2023)

As always, we will continue to track any changes we can find concerning Ammonia Refrigeration process safety. Any changes or updates will be posted here and accounted for in the OSPSM compliance templates. If you have questions or would like to find out more, please contact the RC&E Safety and Compliance team ([email protected]).

EPA Proposes to change the RMP rules (again)

August 22, 2022 /

Looks like the Biden administration is going to continue the recent streak of attempting to change the EPA RMP rules that was started in the Obama administration.

Risk Management Program Safer Communities by Chemical Accident Prevention Proposed Rule

On August 18, 2022, EPA Administrator Michael S. Regan signed the Safer Communities by Chemical Accident Prevention (SCCAP) rule, which proposes revisions to the Risk Management Program (RMP) to further protect vulnerable communities from chemical accidents, especially those living near facilities with high accident rates. The proposed rule would strengthen the existing program and includes new safeguards that have not been addressed in prior RMP rules. Some of the proposed requirements include identifying safer technologies and chemical alternatives, more thorough incident investigations, and third-party auditing, all of which should benefit nearby communities. When finalized, the rule is expected to make communities safer by reducing the frequency of chemical releases and their adverse effects.

The public may comment on the SCCAP proposed rule at www.regulations.govEXIT EPA WEBSITE (Docket ID No.: EPA-HQ-OLEM-2022-0174) until 60 days after publication in the Federal Register.

View the Prepublication Version of the Federal Register Notice for the RMP Safer Communities by Chemical Accident Prevention Proposed Rule (pdf) (2.2 MB)

As always, we will continue to monitor the proposed changes and keep you updated should any of them actually come to light!
Note: This previous post covers the history over the past 3 presidential administrations.

Happy 7/17!

July 15, 2022 /

7/17 Day is this coming Sunday! 

Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.

Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century swiss philosopher.

“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel

While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.

  • Show gratitude to your mentors
  • Become a mentor

 

Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.

Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.

 

Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.

“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen

 

To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!

IIAR 1 & IIAR 3 – First (1st) Public Reviews

March 25, 2022 /

Public Review Announcement

IIAR invites you to make comments for IIAR’s public review of IIAR 1-202x Definitions and Terminology Used in IIAR Standards and IIAR 3-202x Ammonia Refrigeration Valves.

 

Public Review Period: March 25, 2022 through May 9, 2022

 

Comments must be submitted to the IIAR Headquarters by 5:00 pm EST on May 9, 2022. Substantive changes resulting from these public reviews will also be provided for comment in a future public review if necessary.

IIAR 1 is about definitions and may have some impact on those using the IIAR suite. IIAR 3 is about valves and is generally thought of as manufacturer-facing meaning it shouldn’t much affect you unless you are in the business of making refrigeration valves.

Link: Access IIAR 1 Draft & Comment forms

Link: Access IIAR 3 Draft & Comment forms

Can long Lead Times impact Process Safety?

December 15, 2021 /


“Time Waits for No one…”

The Issue at hand

When I first started in NH3 refrigeration, you could pick up the phone, talk to your parts-guy, and get a replacement valve quickly: often the same day, but usually within a business day or two. While you were waiting for the part, you either operated the equipment manually (requiring a temporary SOP / MOC) or shut the equipment down during the wait. We call the time between when you order something and when it arrives, lead-time.

Because lead-times *were* short, parts inventory at most facilities were kept fairly low – usually limited to what would stop production. If you could get what you needed in a day or two, why keep it on the shelf, unless you were losing 20k+ an hour in downtime?

The situation has changed around us, and I’m not sure we’ve all thought through the implications of the current supply-chain issues. Lead-times have grown substantially in 2021 and, while relief is promised in the second half of 2022, these long wait times for equipment and components have the potential to adversely affect our Process Safety.

 

Current Lead Time estimates

Equipment / Component Lead-Times in Weeks*
Valves, Shutoff and Control 14-24
Valves, Relief 12-20
Vessels 14-24
Condensers 14-16
Compressors 16
Air Unit / Evaporators 36
Heat Exchangers 14

*Typical for NH3 components. Varies by brand. Some halocarbons lead-times are even longer.

 

How can this affect Process Safety?

When you don’t have a critical spare part, and won’t have one for several months, production demands are likely to force you to operate your equipment in “temporary” modes. Here are a few thoughts:

  • Temporary is a vague term, but we don’t normally think of temporary as “weeks” or “months”. Put this in more personal terms: if your city tells you they are working on a water main and you will be without water for 8hrs, your response is quite different than if you are going to be without water for 3 months. Not having running water for a few hours means you pour some in a pitcher and delay some dish washing / bathing. Not having water for months requires an entirely different approach.
  • It is very likely that the PSM element where you “identify hazards and control them” (the PHA) was based on customary lead-times, not the ones we are now facing!
  • If operating in a temporary mode has negative safety implications, it is far easier to make the argument that we should forgo production for a few hours, or that we can handle manual operations for a few hours, than it is to justify these “temporary” arrangements for several weeks or months. As an example, if an automatic makeup feed valve to a vessel fails, it’s not terribly difficult to manually manage that for a few hour manually while your parts provider gets you the new valve. It’s far more difficult to manage that issue around the clock for several weeks or months!

 

What should I do?

“The first responsibility of a leader is to define reality…” –Max DePree

Well, the first step is to start a discussion with your skilled technicians and make sure they understand the environment we’re all working in. Here are some points for discussion, and further actions to take:

  • Get a good understanding of the lead-times for the replacement components in your system.
  • With that understanding, talk with your skilled technicians about what is critical for operations.
  • Discuss what you’ve learned so far with operations / production management so you can understand what they “need” and they have a better understanding of these issues.
  • Review your PHA (with all the above in mind) to see what (if any) changes you might need to make to your spare parts/equipment inventory. You might want to bias towards a higher on-site inventory, and (especially if you are using a CMMS or other parts control software) increase your “minimum” inventory to 1 or 2, rather than zero.
  • Order what you need.
  • Consider pre-writing some “temporary” SOPs for operations when failures of critical components occur.

RC&E can assist you with your parts and spares. Click Here for our Line Card. Call Dennis Vaught 817-210-1957 or email him at [email protected]

Safety Bulletin on P-Series Valves

November 5, 2021 /

R/S has just released a safety notification regarding the solenoid operator and LED light for the PVS and P-series valves (PA4 regulators and PS4 solenoids).

 

Subject: P-Series Coil Installation and Removal Notification

To properly install and remove solenoid coils on Parker P-Series products:

  • Place the solenoid coil over the solenoid operator.
  • Install the wave spring (included with the coil) over the Solenoid Operator on top of the coil.
  • Inspect the Solenoid Operator threads for damage. If the threads are damaged, the Solenoid Operator Assembly must be replaced.
  • Thread the coil retaining nut (included with the coil) or optional LED knob onto the Solenoid Operator until it contacts the wave spring. Take caution to avoid cross threading.
  • Rotate the nut or knob an additional ¼ to ½ turn, compressing the wave spring.
  • To remove the coil, unthread the coil retaining nut or the LED knob. Torque must not exceed 5 ft-lb.

If cross threading occurred or the threads were damaged, excess torque may be required for removal. This higher torque could unthread the solenoid operator from the valve leading to a refrigerant leak. If the unthreading torque exceeds 5 ft-lbs, the refrigerant in the valve must be evacuated before proceeding.

Do not open to atmosphere the valve, strainer or control until refrigerant had been evacuated. All personnel working on valves must be qualified to work on refrigeration systems. Any person intending to service a valve should read the appropriate product and safety bulletin before performing any work on R/S products.

Please pass this information on to your NH3 refrigeration operators!

 

You can download the safety bulletin at this link.

« Older posts

Contact Us

© 2024 RC&E Chill – Industrial Refrigeration and Process Safety / Risk Management

Theme by Anders Noren — Up ↑