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

Chill - We Got This!

Category: PSM / RMP (Page 4 of 11)

Hot Work – NFPA 51B–2019 and Magic Rooms

September 26, 2019 /

RAGAGEP is always changing and we have to ensure that our safety programs evolve to match the new / changed requirements. Tuesday I took a dive into NFPA 51B 2019, the standard for “Fire Prevention during Welding, Cutting, and Other Hot Work.” After reading through it, some changes were made to my base program. Here’s the section from my running “Change Log”

092419 – Updated both versions Hot Work Written Plans to deal with NFPA51B-2019.

  • Changed NFPA references to match new section numbers
  • Changed fire watch to 60-minute minimum per NFPA.
  • Updated master definitions file (in \01-RMP\ ) to include updated definition of Fire Watch and new definitions for Fire Protection System and Fire Monitoring.

To Implement:

  • Change out \01 – EPA RMP\Definitions – Glossary of Terms and Acronyms with 092419 version by using the appropriate MOC procedure.
  • Replace \09 – Hot Work\09 – Hot Work Permit Element Written Plan with 092419 version by using the appropriate MOC procedure.
  • Train all personnel involved in Hot Work about new 60-minute fire watch requirement. Document training per the written plan.

 

This is a fairly simple change. You may have noticed that there is a new section in the “Change Log” for each entry – a “To Implement” section that tells you how to modify your program if it was written based on the baseline templates. I’ve gone back through the last month’s changes and added this information. Time willing, I might do the same for the previous 100+ entries!

While we are on the subject of Hot Work though, I want to bring up another common issue: “Designated Areas.” This is a particularly “Hot” topic right now, because a recent large industrial fire was caused by Hot Work and some people are saying it was an oil fire caused by Hot Work done in a “shop.”

Designated Areas: Many plants have “Designated Areas” such as maintenance or welding shops where Hot Work is conducted without the use of a permit. It should be noted that nothing in the PSM/RMP or OSHA General Industry rules (as interpreted through 1910.119(k)) appear to support this. For this reason, we’ve always called these areas “Magic Rooms” because people seem to think that these rooms are exempt from OSHA rules. The custom actually comes from NFPA 51B:

In the 2019 version, it is section 5.3.2.1 which allows for areas to be classified as Designated Hot Work areas. These areas would allow Hot Work without the use of the written permit provided certain requirements are met:

  • The specific area designed or approved for Hot Work meets the requirements of 5.5.1*
  • The area is reviewed at least annually by the Permit Authorizing Individual
  • Signs are posted designating Hot Work Areas
  • Prior to the start of the Hot Work, the operator verifies the following:
    • The location is verified as fire resistant.
    • The requirements of 5.4.2(3) are met so that the area is essentially free of combustible and flammable contents.
    • Fire extinguishers are in working condition and readily available.
    • Ventilation is working properly.
    • Hot Work equipment is in working order.

* Section 5.5.1 is the list of requirements that have to be met before issuing a Hot Work Permit. Essentially, you are making sure that the Designated Area meets the requirements for issuing a Hot Work Permit without actually issuing one.

The acceptability of this custom is in question due to a statement made by OSHA in their PSM Preamble:

“…this proposed provision would not require a permit for Hot Work operations in a welding shop unless the welding shop was located in a process area covered by the standard. OSHA believes that such a location would not exist.” (OSHA, PSM Preamble, 1992)

OSHA was clearly thinking of Petroleum and Chemical plants in that quote, where such situations are usually not found. As of 2019, we are not aware of any Ammonia Refrigeration PSM-covered facility receiving a Hot Work citation for Designated Areas if they follow the requirements of NFPA 51B Section 5.3.2.1. Still, it would be far more defensible if you issued Hot Work permits for all Hot Work, even that work conducted in maintenance and welding shops.

 

Here’s a look at the Hot Work element Written Plan section dealing with Designated Hot Work Areas:

Note: Previous discussion on Hot Work at this link. You can read the 2019 version of NFPA-51B in its entirety at NFPA.org

 

Questions from the field: Who is responsible for the PSM/RMP duties?

September 18, 2019 /

From a legalistic perspective, we’ll first turn to the law. In this case, the EPA’s RMP rule…

68.15(a) The owner or operator of a stationary source with processes subject to Program 2 or Program 3 shall develop a management system to oversee the implementation of the risk management program elements.

68.15(b) The owner or operator shall assign a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements.

68.15(c) When responsibility for implementing individual requirements of this part is assigned to persons other than the person identified under paragraph (b) of this section, the names or positions of these people shall be documented and the lines of authority defined through an organization chart or similar document.

The short, legalistic answer is that the owner/operator is responsible. They must pick a qualified person who has overall responsibility for the program.

If the owner then chooses to break up the various requirements of the program to people other than that qualified person, they have to document all those people. In my programs, I call these people a “Responsible Person.”

 

Ok, but how does this actually work. Let’s imagine a small facility that is required to have a PSM/RMP program. They pick their Safety Manager, Sofía as their Process Safety coordinator, so she is now the person responsible under §68.15(b).

But, Sofía, while very knowledgeable in Safety and Environmental issues, is not as familiar with refrigeration or engineering. It’s unlikely she’ll be in the best position to manage most of the program elements on a day-to-day basis.  To address this issue, the facility decides to assign certain skilled people the responsibility for various program elements. They assign the Operating Procedure, Operator Training and Maintenance elements to Robert, their Maintenance Manager. They also decide to assign the Process Safety Information, Management of Change and Pre-Startup Safety Review elements to Jaylen, their Plant Engineer.  Because he usually manages them anyway, they assign Benny, the Lead Operator, the Contractor element. Of course, all these people are going to rely on the knowledge and experience of each other, the Facility Manager John, and the other operators, Tessa, Faraz, and Tiah.

This might be getting a little confusing at this point, which is why §68.15(c) wants us to document these assignments. For example:

Program Element Responsible Person
Overall PSM / RMP Management System PSM Coordinator
Risk Management Plan (RMP) PSM Coordinator
Process Safety Information Plant Engineer
Employee Participation PSM Coordinator
Process Hazard Analysis PSM Coordinator
Operating Procedures Maintenance Manager
Operator Training Maintenance Manager
Contractor Qualification and Safety Lead Operator
Pre-Startup Safety Review Plant Engineer
Hot Work Permit PSM Coordinator
Incident Investigation PSM Coordinator
Mechanical Integrity Maintenance Manager
Management of Change (MOC) Plant Engineer
Emergency Response Plan PSM Coordinator
Compliance Audits PSM Coordinator
Trade Secrets PSM Coordinator

How a facility arranges the responsibilities is entirely up to them as long as they can make the case that the person assigned as a “Responsible Person” is qualified to handle the work being assigned to them.

On a practical level, your Management System should also:

  • Show what person is responsible for each PSM/RMP element / requirement
  • Ensure that only one person is responsible for each requirement
  • Make it clear that a Responsible Person can’t authorize their own work requests, such as Hot Work, MOC, PSSR, etc.
  • Be easily understood by everyone involved

Please note, that just because someone is responsible for an element, doesn’t necessarily mean they are actually doing the work. They are just responsible for ensuring the work is done. A good example outside of PSM is the facility manager of a chicken plant. That facility manager is responsible for ensuring that food safety regulations are met so the chicken is cooled in an appropriate time-frame. It is extremely unlikely that the plant manager actually handles the chicken, the cooling equipment, etc. They simply provide the resources and oversight to ensure the work is done properly.

A good PSM example might be Operating Procedures. In our case, we’ve assigned them to the Maintenance Manager. It is likely that the actual initial creation and review of the operating procedures is done entirely by the operators. Based on the results of that review, the Responsible Person would ensure that appropriate revisions are made and then certify the procedures.

Feel free to contact us If you want templates of a PSM/RMP management system.

Compliance Auditing and the Karenina Principle

August 2, 2019 /

Over the years I’ve audited well over one hundred Ammonia Refrigeration Process Safety (PSM / RMP) programs and one of the things that I always try and remember during the audit is something called the “Anna Karenina” principle. The first line in that Leo Tolstoy novel is:

“All happy families are alike; each unhappy family is unhappy in its own way.”

 

Put another way: Success requires certain key factors are addressed. Meeting those requirements means that those successful systems will be similar to other successful systems. For Process Safety programs, there are many key factors to success, but I think they all boil down to three main categories:

  • Does the facility have a written Process Safety Program that (on paper) meets the safety & compliance requirements of the law, the process, and the people, in a manner that meets the business needs of the company? If so;
  • Is the written Process Safety Program implemented as written? If so;
  • In the actual day-to-day process, does the written Process Safety Program as implemented address the safety & compliance requirements of the law, the process, and the people, in a manner that meets the business needs of the company adequately?

I often call this the “Three Levels of Compliance.” Shown in a flowchart:

While there are nearly infinite ways a Process Safety program can fail, but ALL successful programs will pass these three levels of compliance checks. Understanding this concept will help you be a better auditor, but it can also help you be a better implementer!

 

In Auditing, how does this work in practice?

Let’s look at an example of an identified deficiency of rusted pipe found during the walkthrough portion of an audit. Note, we’ve kind of started at the 3rd level of compliance here because we’ve found a problem in the field and therefore know that the plan as implemented isn’t adequate!

First-pass question concerning written plan could include:

    • Are there written instructions on their inspection frequency and acceptable conditions?
    • Is there a written plan on training to perform these inspections?
    • Does the written Mechanical Integrity Plan address these specific pipes?

The answers to these questions will help you define a finding / recommendation to improve the program.

Second-pass questions concerning implementation could include:

    • Is the written Mechanical Integrity Plan that addresses these pipes being conducted when it is scheduled to be?
    • Are the written instructions being followed?
    • Was the inspector trained in accordance with the written plan?

Again, if the answers to these questions may prompt a finding / recommendation to improve the program. If you have a written MI plan and you are implementing it, but you still have rusting pipes; then you need to fix either the plan or your implementation of it!

 

How can this concept help me be a better implementer?

Your Process Safety Program is, by its very nature, artificially bringing order to chaos. Because of Entropy, we know that all systems and processes will eventually decline into disorder and fail. This decay happens with no effort on your part but, with effort, it can be thwarted.

Ultimately. I believe the only way to continuously, sustainably maintain your Process Safety Program is by forcing a feedback loop. A feedback loop is where you ensure that the output of a system is routed back to the input of the system. In our earlier worked example, we need to ensure that the output (physical condition, daily practices, etc.) of the system is routed back to the input (written plan and implementation of it) so we can know how well the system is performing and make changes as needed.

When it comes to the mechanical world, there is no better feedback loop that actual inspections and tests. If it is properly designed, your Mechanical Integrity program should be providing this information. Your team needs to understand that (no matter how small) every single deficiency you find, or breakdown that you have, is a sign that your plan can be improved.

When it comes to the operation of the system (policies, procedures, etc.) your PSM team is supposed to be providing this feedback. I say “supposed to be” because more and more I see that this important feedback loop is not being properly utilized. For more information on what the purpose of a PSM team is and what it should do see this earlier article: What is the purpose of a PSM Team?

What is the Purpose of a PSM Team?

July 30, 2019 /

The implementation of the PSM/RMP Program is a team-based effort. In my opinion, no single part of a Process Safety Program is more important than your Process Safety Team. Put another way: If you don’t have a strong Process Safety Team you won’t have a strong Process Safety Program.

 

Who should be on the Team?

At a minimum:

  • Each Responsible Person listed in the “Management System” is a member of the PSM team. Responsible Person’s are people that have responsibility for implementing individual elements of the Process Safety Program.
  • If not already included as a Responsible Person, all Process Operators are also included as PSM team members.

The team can also benefit from additional diversity such as senior members of management outside of Process Safety. Examples might include the Plant Manager or Director of Warehousing, Production Supervisors /Managers, Health, Safety & Environmental staff, etc.

 

What should the team do?

While a successful team serves many functions, it is there for two essential purposes:

  • To educate and inform
  • To provide oversight

 

Process Safety Team as an Educator

Your covered process and the safety programs that cover it are large and complex. So it the overall business that they are a part of. Our first priority in the meeting is to inform each other of what is happening in the parts of the program we deal with on a daily basis – or we are responsible for. This is often referred to as “getting everyone on the same page.”

 

Process Safety Team’s Oversight Role

The most often failed function of a Process Safety Team is to provide oversight. The Responsible Person for an element has to make day-to-day decisions to keep the process (and the business) running and we should ensure that they defend these decisions to the Process Safety Team so that the team can either validate or correct them.

For example:If the MOC Responsible Person decided that a specific change was not required to go through the MOC process, they should make that argument to the Process Safety Team which should either validate that choice or – as a group – convince the Responsible Person that their decision was in error so they can take corrective action.

Another example: The Responsible Person and two other staff members have completed an Incident Investigation on a small process leak that recently occurred. The Process Safety Team should either validate that completed Investigation or – as a group – convince the Responsible Person to investigate additional avenues, or provide addition recommendations.

This simple concept: Defend your decisions to a team of your peers so they can validate them or correct your thinking is the beating heart of any Process Safety Program. If you do it well, you provide a feedback loop, and the entire team will get better at their jobs. Whether it’s an Incident Investigation, a Management of Change, Contractor evaluations, etc., Validating your decisions with your Process Safety Team will improve the performance of the program more than nearly any other thing you can do.

 

Bonus Content: What should we discuss at our PSM meetings?

I am often dumbstruck when this question is asked of me, because I NEVER run out of things to talk about. (You can all stop laughing now)

While PSM Team Meetings should be structured to allow diverse topics and input, certain topics should be discussed at any general PSM Team Meeting:

  • Any open recommendations in the program to review status and ensure recommendations are progressing towards resolution.
  • Any upcoming, ongoing, or recently completed MOCs, PSSRs, Incident Investigations, etc. to review status and/or adequacy of documentation.
  • Any upcoming, ongoing, or recently completed work that has, or may have, safety ramifications for the covered process(es).
  • Team Validation of any decisions / work product produced by Responsible Persons

 

Note: Special thanks to end-users VD & CG who prompted me to include this information (and more) directly into my PSM Element Written Plans. We ALL improve with feedback!

 

IIAR 2 2014 Addendum A

July 16, 2019 /

The IIAR has just released IIAR 2-2014 Addendum A:

  • While there isn’t a whole lot that’s changed in the document (compared to IIAR 2-2014) quite a bit of it was re-numbered / re-organized. Based on my review, there’s not too much going on in the new edition:
  • Inclusion of absorption systems
  • Water % allowed in NH3 became more reasonable
  • Significant change to the wording concerning the “corrosion allowance” for vessels such that it is optional now
  • Some equipment hydrostatic protection now points to the “Mechanical Code” rather than the IIAR 2 section 15.6
  • A clearer requirement for pumpout provisions for all equipment
  • Minor clarifications and reorganizations.

I’ve already updated the PHA checklist blanks (and my internal compliance audit template) to reflect the new RAGAGEP.

Here’s my list of changes (which may not be complete) if you are interested in this sort of thing!

 

Section Requirement in IIAR 2-2014 Requirement in IIAR 2-2014a
1.2 Scope *Scope. Stationary closed-circuit refrigeration systems utilizing ammonia as the refrigerant shall

comply with this standard. This standard shall not apply to

1.      Ammonia absorption refrigeration systems.

2.      Replacements of machinery, equipment, or piping with functional equivalents.

3.      Equipment and systems and the buildings or facilities in which they are installed that existed prior to the legal effective date of this standard. Such equipment, systems, and buildings and facilities shall be maintained in accordance with the regulations that applied at the time of installation or construction.

 *Scope. Stationary closed-circuit vapor compression and absorption refrigeration systems utilizing anhydrous ammonia as the refrigerant shall comply with this standard. This standard shall not apply to:

1.      Replacement of machinery, equipment, or piping with functional equivalents.

2.      Equipment and systems and the buildings or facilities in which they are installed that existed prior to the legal effective date of this standard. Such equipment. Systems, and building and facilities shall be maintained in accordance with the regulations that applied at the time of installation or construction.

 

Note: Absorption systems added to appendix
4.2 Permissible Equipment Locations 4.2.1 Listed Equipment. Listed equipment containing not more than 6.6 lb (3 kg) of ammonia and

installed in accordance with the listing and the manufacturer’s instructions shall be permitted in any occupancy without a machinery room.

 4.2.1 Listed Equipment. Listed equipment containing not more than 6.6 lbs (3 kg) of ammonia and installed in accordance with the listing and the manufacturer’s instructions shall be permitted in any occupancy without a machinery room. Listed equipment for use in laboratories with more than 100 ft2 (9.3m2) of floor area is permitted to contain any amount of ammonia if the equipment is installed in accordance with the listing and the manufacturer’s installation instructions.
4.2 Permissible Equipment Locations 4.2.2. *Outdoor Installations. Ammonia refrigeration machinery shall be permitted to be installed outdoors. Ammonia refrigeration machinery, other than piping, installed outdoors shall be located not less than 20 ft from building openings, except for openings to a machinery room or openings to an industrial occupancy complying with Section 7.2. 4.2.2 *Outdoor Installations. Ammonia refrigeration machinery shall be permitted to be installed outdoors when installed in compliance with sections 7.2.2, 7.2.4, 7.2.6, 7.2.7 and 7.2.8. Ammonia refrigeration machinery, other than piping, installed outdoors shall be located not less than 20 ft. from building openings, except for openings to a machinery room or openings to an industrial occupancy complying with Section 7.2.

 

EXCEPTIONS:

1.      Packaged absorption systems for residential and commercial occupancies with refrigerant quantities not exceeding 22 lbs. (10 kg.) are permitted to be installed within 20 ft. of building openings.

2.      Packaged vapor compression systems for commercial occupancies with refrigerant quantities not exceeding 22 lbs. (10 kg.) are permitted to be installed within 20 ft. of building openings.

3.      Packaged absorption or vapor compression systems with refrigerant quantities such that a complete discharge would not exceed a concentration of 300 ppm in any room or area in which the refrigerant could enter. The calculation procedure shall be in accordance with Chapter 5, Section 5.3.
4.2 Permissible Equipment Locations No Exceptions Listed 4.2.4 EXCEPTIONS:

1.      Listed packaged vapor compression or absorption systems, with no refrigerant containing parts that are joined in the field by other than mating valves that permit sections of the system to be joined before opening the valves, installed in areas or rooms that are not public hallways or lobbies and with refrigerant quantities equal to or less than 6.6 lbs. (3 kg) are permitted for residential occupancies.

2.      Listed packaged vapor compression or absorption systems, with no refrigerant containing parts that are joined in the field by other than mating valves that permit sections of the system to be joined before opening the valves, installed in areas or rooms that are not public hallways or lobbies and with refrigerant quantities equal to or less than 22 lbs. (10 kg) are permitted for commercial occupancies.

3.      Listed, sealed packaged vapor compression or absorption systems with no refrigerant containing parts that are joined in the field by other than mating valves that permit sections of the system to be joined before opening the valves, installed in public hallways or lobbies and with refrigerant quantities equal to or less than 3.3 lbs. (1.5 kg) are permitted for residential and commercial occupancies.
5.2 Anhydrous Ammonia Specifications Table 5.2.2 Purity Requirements

Ammonia Content 99.95% minimum

Non-Basic Gas in Vapor Phase 25 ppm maximum

Non-Basic Gas in Liquid Phase 10 ppm maximum

Water 33 ppm maximum

Oil (as soluble in petroleum ether) 2 ppm maximum

Salt (calculated as NaCl) None

Pyridine, Hydrogen Sulfide, Naphthalene None

 Table 5.2.2 Purity Requirements

Ammonia Content 99.95% minimum

Water 50 ppm minimum, 5000ppm maximum

Oil 50 ppm maximum

Salt None

Pyridine, Hydrogen Sulfide, Naphthalene None
5.5 System Design Pressure Note: This item was not present in IIAR 2-2014. It was inserted after 5.5.1.1 which required renumbering 5.5.5.1.3 & 5.5.1.4 to 5.5.1.4 & 5.5.1.5 5.5.1.2 Limited Charge Systems. When parts of a limited charge system are protected from overpressure by a pressure relief device, the design pressure of the protected parts need not exceed the set-pressure of the relief device. The set pressure of the relief device shall not exceed the design pressure of the protected parts.
5.5 System Design Pressure 5.5.1.4 Connecting to Existing Low-Pressure Equipment. Where new low-pressure side

equipment is connected to an existing system that was in operation prior to the adoption of this standard by the AHJ, the design pressure of the new low-pressure side portion of the system shall be permitted to equal the design pressure of the

existing low-pressure side.

 5.5.1.5 Connecting to Existing Low-Pressure Equipment. Where new low-pressure side equipment is connected to an existing system that was in operation prior to the adoption of this Standard by the AHJ, the design pressure of the new low-pressure side portion of the system shall be permitted to equal the design pressure of the existing low-pressure side. All other requirements of this standard shall apply.
5.5 Purging 5.8 *Purging. Means shall be provided to remove air and other noncondensable gases from the

refrigeration system.

 5.8 *Purging. Means shall be provided to remove air and other non-condensable gases from the refrigeration system. Discharge piping for purging systems that discharge to the atmosphere shall conform to sections 13.4 for support, 15.4.3 for materials, and 15.5.1.2 through 15.5.1.7 for termination.

 

EXCEPTION: A means for purging is not required for packaged vapor compression and absorption systems with refrigerant quantities that do not exceed 22 lbs. (10 kg.).
5.12 Service Provisions 5.12.4 Pressure Gauges. Where a pressure gauge is installed on the high side of the refrigeration

system, the gauge shall be capable of measuring and displaying not less than 120% of the

system design pressure.

 16.4.2 Pressure Gauges. High Side Installation. Where a pressure gauge is installed on the high side of the refrigeration system, the gauge shall be capable of measuring and displaying not less than 120% of the system design pressure.

 

Note: Basically, it just moved.
5.12 Service Provisions 5.12.5 *Service Isolation Valves. Serviceable equipment shall have manual isolation valves.

 

EXCEPTION: Packaged systems and portions of built-up systems shall be permitted to have

pump-down arrangements that provide for the removal or isolation of ammonia for servicing

one or more devices in lieu of isolation valves.

 5.12.4 *Service Isolation Valves. Serviceable equipment and control valves shall have manual isolation valves. Where multiple pieces of serviceable equipment are readily isolated by a single set of hand isolation valves, the use of a single set of valves meets the intent of this section.
5.12 Service Provisions Appears to be NEW

 

 5.12.5 *Equipment Pumpout. Provisions for pumpout of equipment and control valves shall be provided for maintenance and service.
5.13 Testing 5.13.2 Ultimate Strength. Pressure-containing equipment shall comply with Sections 5.13.2.1 and 5.13.2.2.

 

EXCEPTION: The following shall be permitted to comply with Section 5.13.2.3 in lieu of

complying with this section:

1.      Pressure vessels.

2.      Piping, including valves, evaporators, condensers, and heating coils with ammonia as the working fluid, provided they are not part of the pressure vessel.

3.      Pressure gauges.

4.      Refrigerant pumps.

5.      Control mechanisms.

 5.13.2 Ultimate Strength. Pressure-containing equipment shall comply with Sections 5.13.2.1 and 5.13.2.2.

 

EXCEPTIONS: The following shall be permitted to comply with Section 5.13.2.3 in lieu of complying with Sections 5.13.2.1 and 5.13.2.2.:

1.      Piping, including valves, evaporators, condensers, and heating coils with ammonia as the working fluid, if they are not part of a pressure vessel.

2.      Pressure gauges.

3.      Control mechanisms.
5.13 Testing 5.13.2.3 Equipment designed based on the exception to Section 5.13.2 shall be required to

comply with additional requirements in Chapter 8 through Chapter 16 and ASME B31.5, as applicable.

 5.13.2.3 Equipment and piping designs based on the exception to Section 5.13.2 shall be required to comply with additional requirements in ASME B31.5 as applicable.
5.14 Signage, Labels, Pipe Marking, and Wind Indicators Appears to be NEW – addition required re-ordering the rest of the 5.14 sections 5.14.2 *NFPA 704 Placards. Buildings and facilities with refrigeration systems shall be provided with placards in accordance with NFPA 704. For equipment located outdoors, the placard shall display the following degrees of hazard: Health-3, Flammability-1, Instability-0. For equipment located indoors, the placard shall display the following degrees of hazard: Health-3, Flammability-3, Instability-0
5.17 General Safety Requirements Appears to be NEW – addition required re-ordering the rest of the 5.17 sections *Vessel Pumpdown Capacity. Liquid ammonia shall not occupy a vessel at a volume large enough to create a risk of hydrostatic overpressure unless the vessel is protected by a hydrostatic pressure relief device.

 

Note: A.5.17.4 The maximum volume of liquid in vessels has traditionally been considered 90% at a temperature of 90°F. Calculations can be done to determine other levels and worst-case temperatures.
5.17.5 Used Equipment This appears to have moved from Section 6.8 5.17.10 Electrical Safety – Electrical equipment and wiring shall be installed in accordance with the Electrical Code.
6 Machinery Rooms 6.3.3.2 Manually operated isolation valves identified as being part of the system emergency shutdown procedure shall be directly operable from the floor or chain operated from a permanent work surface. Emergency valve identification shall comply with Section 5.14.5 6.3.3.2 Manually operated isolation valves identified as being part of the system emergency shutdown procedure shall be directly operable from the floor or chain operated from a permanent work surface. Emergency valve identification shall comply with Section 5.14.4
6 Machinery Rooms 6.6.3 Pipe Marking. Piping shall be marked as required by Section 5.14.5. 6.6.3 Pipe Marking. Piping shall be marked as required by Section 5.14.6.
6 Machinery Rooms 6.7.1 General. Each machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room, each meeting the requirements in Section 6.7.3. Additional eyewash/safety shower units shall be installed such that the path of travel in the machinery room is no more than 55 ft to an eyewash/safety shower unit. 6.7.1 General. Each machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room, each meeting the requirements in Section 6.7.3.
6 Machinery Rooms 6.7.2 – Path of Travel. The path of travel within the machinery room to at least one eyewash/safety shower unit shall be unobstructed and shall not include intervening doors. 6.7.2 Path of Travel. The path of travel within the machinery room to at least one eyewash/safety shower unit shall be unobstructed and shall not include intervening doors. Additional eyewash/safety shower units shall be installed such that the path of travel in the machinery room is no more than 55 ft to an eyewash/safety shower unit. The path of travel to at least one eyewash/safety shower unit located outside of the machinery room shall be within 55 ft. of the principle machinery room door. The path of travel shall be unobstructed and shall not include intervening doors.
6 Machinery Rooms 6.8.1 General. Electrical equipment and wiring shall be installed in accordance with the Electrical Code. 6.8.1 Hazardous (Classified) Locations. Electrical equipment and wiring shall be installed in accordance with the Electrical Code. Machinery rooms shall be designated as Unclassified Locations, as described in the Electrical Code, where the machinery room is provided with emergency ventilation in accordance with Section 6.14.7 and ammonia detection in accordance with Section 6.13.

 

A machinery room not provided with emergency ventilation shall be designated as not less than a Class I, Division 2, Group D Hazardous (Classified) Location, and electrical equipment installed in the machinery room shall be designed to meet this requirement.
6 Machinery Rooms 6.8.2 Machinery rooms shall be designated Ordinary Locations, as described in the Electrical Code, where the machinery room is provided with emergency ventilation in accordance with Section 6.14.7 and ammonia detection in

accordance with Section 6.13.

Machinery rooms not provided with emergency ventilation shall be designated as not less than a Class I, Division 2, Group D Hazardous (Classified) Location, and electrical equipment installed in the machinery room shall be designed to meet this requirement.

 6.8.3 Design Documents. Electrical design documents shall indicate whether the machinery room is designated as an Ordinary Location or as a Hazardous (Classified) Location. Where the machinery room is designated as a Hazardous (Classified) Location, the Class, Division, and Group of the electrical classification, as required by the Electrical Code, shall be indicated in the documentation.
6 Machinery Rooms 6.8.2 Design Documents. Electrical design documents shall indicate whether the machinery room is designated as an Ordinary Location or as a Hazardous (Classified) Location. Where the machinery room is designated as a Hazardous (Classified) Location, the Class, Division, and Group of the electrical classification, as required by the Electrical Code, shall be indicated in the documentation. * Moved up one section
6.14 Ventilation “6.14.3.1 Mechanical exhaust ventilation systems shall be automatically activated by ammonia leak detection in accordance with Section 6.13 or temperature sensors and shall be manually operable.” Appears to have been removed. These requirements are already elsewhere in the document so there is no real effect other than requiring 6.14.3.2-6 to be renumbered to 6.14.3.1-5.
6 Machinery Rooms 6.15.1 *NFPA 704 Placards. Buildings and facilities with refrigeration systems shall be provided with placards accordance with NFPA 704 and the Mechanical Code. 6.15.1 NFPA 704 Placards. A NFPA 704 placard shall be provided in accordance with Section 5.14.2 on or next to all doors through which a person can enter the machinery room.
6 Machinery Rooms Appears to be NEW – Just a reminder about earlier requirements

 

 6.15.4 Emergency Control Switch Signage. Signage shall be provided near the emergency stop and emergency ventilation control switches as described in section 6.12.
7 Equipment in Non-Machinery Rooms 7.2.7 Illumination of Equipment Areas. See Section 5.17.6. 7.2.7 Illumination of Equipment Areas. See Section 5.17.7.
7 Equipment in Non-Machinery Rooms Appears to be NEW 7.2.10 Electrical Classification. Areas in compliance with 7.2.1 through 7.2.9 shall be designated as Unclassified electrical locations as described in the Electrical Code, unless a different electrical classification is required by in the space other than for the ammonia refrigeration system.
7 Equipment in Non-Machinery Rooms 7.3.2 Outdoor Systems. Where a refrigeration system or equipment is located outdoors more than 20 ft (6.1 m) from building entrances and exits and is enclosed by a penthouse, lean-to, or other open structure, natural ventilation shall be provided in accordance with this Section 7.3.2 or

mechanical ventilation shall be provided in accordance with Section 6.14 and Section 7.3.1.2.

 7.3.2 Outdoor Systems. Outdoor systems include those that comply with Section 4.2.2. For outdoor systems, natural ventilation shall be provided in accordance with this Section or mechanical ventilation shall be provided in accordance with Section 6.14 and Section 7.3.1.
8 Compressors 8.2.2 *Positive-Displacement Compressor Protection. Where a stop valve is provided in the discharge connection, a positive-displacement compressor shall be equipped with a pressure relief device to prevent the discharge pressure from increasing to more than 10% above the lowest maximum allowable working pressure of the compressor or any other equipment located in the discharge line between the compressor and the stop valve, or in accordance with Section 15.3.7, whichever is larger. 8.2.2 *Positive-Displacement Compressor Protection. Where a stop valve is provided in the discharge connection, a positive-displacement compressor shall be equipped with a pressure relief device to prevent the discharge pressure from increasing to more than 10% above the lowest maximum allowable working pressure of the compressor or any other equipment located in the discharge line between the compressor and the stop valve, or in accordance with Section 15.3.8, whichever is larger.
8 Compressors 8.2.6 Rotation Arrow. If rotation is one direction only, a rotation arrow shall be cast in or permanently attached to the compressor frame using an attached label or plate or equivalent means. 8.2.6 Rotation Arrow. If rotation is one direction only, a rotation arrow shall be cast in or permanently attached to the compressor.
10.4 Shell-and-Tube Condensers 10.4.1.5 Where the secondary coolant inlet and outlet piping of shell-and-tube condensers can be automatically isolated, protection from hydrostatic overpressure shall be in accordance with Section 15.6. 10.4.1.5 Where the secondary coolant inlet and outlet piping of shell-and-tube condensers can be automatically isolated, protection from hydrostatic overpressure shall be in accordance with the Mechanical Code.
10.4 Shell-and-Tube Condensers 10.4.2 Procedures/Testing. Shell-and-tube condensers shall be strength tested to a minimum of 1.1

times the design pressure, subsequently leak tested, and proven tight at a pressure not less than

design pressure by the manufacturer.

 10.4.2 Procedures/Testing. Shell-and-tube condensers shall be strength tested to a minimum of 1.1 times the design pressure when they are not manufactured as a pressure vessel or shall be pressure tested in accordance with ASME B&PVC, Section VIII, Division 1 when they are manufactured as a pressure vessel. In either case, they shall be subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer
10.5 Plate Heat Exchange Condensers 10.5.1.5 Where the nonrefrigerant process fluid inlet and outlet lines of plate packs can be automatically isolated, they shall be protected from hydrostatic overpressure in

accordance with Section 15.6.

 10.5.1.5 Where the non-refrigerant process fluid inlet and outlet lines of plate packs can be automatically isolated, they shall be protected from hydrostatic overpressure in accordance with the Mechanical Code.
10.5 Plate Heat Exchange Condensers 10.5.2 Procedures/Testing. Plate heat exchanger condensers shall be strength tested to a minimum of 1.1 times the design pressure, subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer. 10.5.2 Procedures/Testing. Plate heat exchanger condensers shall be strength tested to a minimum of 1.1 times the design pressure when they are not manufactured as a pressure vessel or shall be pressure tested in accordance with ASME B&PVC, Section VIII, Division 1 when they are manufactured as a pressure vessel. In either case, they shall be subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer.
10.6 Double- Pipe Condensers 10.6.1.5 Where the secondary coolant inlet and outlet piping of double-pipe condensers can

be automatically isolated, they shall be protected from hydrostatic overpressure in

accordance with Section 15.6.

 10.6.1.5 Where the secondary-coolant inlet and outlet piping of double-pipe condensers can be automatically isolated, they shall be protected from hydrostatic overpressure in accordance with the Mechanical Code.
11.3 Shell-and-Tube Evaporators Appears to be NEW 11.3.1.1.2 Ultimate strength shall be in accordance with section 5.13.2.
11.3 Shell-and-Tube Evaporators (Ammonia in Shell) 11.3.1.1.2 Pressure vessels coupled to shell-and-tube evaporators shall comply with

Chapter 12.

 

Note: Renumbered do to Ultimate Strength addition

 11.3.1.1.3 Pressure vessels coupled to shell-and-tube evaporators shall comply with Chapter 12.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.1 Design 11.3.3 Design
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.1.1 Minimum design pressure shall be in accordance with Section 5.5. 11.3.3.1.1 Minimum design pressure shall be in accordance with Section 5.5.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) Appears to be NEW 11.3.3.1.2 Ultimate strength shall be in accordance with section 5.13.2.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.1.2 Pressure vessels coupled to shell-and-tube evaporators with ammonia in the tubes shall comply with Chapter 12. 11.3.3.1.3 Pressure vessels coupled to shell-and-tube evaporators with ammonia in the tubes shall comply with Chapter 12.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.1.3 Where the tube-side inlet and outlet lines of shell-and-tube evaporators with ammonia in tubes can be automatically isolated, the tube side shall be protected from hydrostatic overpressure in accordance with Section 15.6. 11.3.3.1.4 Where the tube-side inlet and outlet lines of shell-and-tube evaporators with ammonia in tubes can be automatically isolated, the tube side shall be protected from hydrostatic overpressure in accordance with Section 15.6.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.1.4 The tube side shall comply with ASME B31.5 or ASME B&PVC, Section VIII, Division 1. 11.3.3.1.5 The tube side shall comply with ASME B31.5 or ASME B&PVC, Section VIII, Division 1.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.2 Procedures/Testing. Shell-and-tube evaporators shall be strength tested to a minimum of 1.1 times the design pressure, subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer. 11.3.3.2 Procedures/Testing. Shell-and-tube evaporators shall be strength tested to a minimum of 1.1 times the design pressure when they are not manufactured as a pressure vessel or shall be pressure tested in accordance with ASME B&PVC, Section VIII, Division 1 when they are manufactured as a pressure vessel. In either case, they shall be subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer.
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.3 Equipment Identification… 11.3.3.3 Equipment Identification…
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) 11.3.2.4 Installation Considerations. Where design permits servicing of evaporator tubes at their installed location, clearance shall be provided as necessary to accommodate maintenance and replacement. 11.3.3.4 Installation Considerations
11.3 Shell-and-Tube Evaporators (Ammonia in Tubes) Requirement given its own number 11.3.3.4.1 Where design permits servicing of evaporator tubes at their installed location, clearance shall be provided as necessary to accommodate maintenance and replacement.
11.4 Plate Heat Exchanger Evaporators 11.4.1.5 Where the nonrefrigerant process fluid inlet and outlet lines of plate packs can be isolated, they shall be protected from hydrostatic overpressure in accordance with Section 15.6 on the process side. 11.4.1.5 Where the non-refrigerant process fluid inlet and outlet lines of plate packs can be isolated, they shall be protected from hydrostatic overpressure in accordance with the Mechanical Code on the process side.
11.4 Plate Heat Exchanger Evaporators 11.4.2 Procedures/Testing. Plate heat exchanger evaporators shall be strength tested to a minimum

of 1.1 times the design pressure, subsequently leak tested, and proven tight at a pressure not

less than design pressure by the manufacturer.

 11.4.2 Procedures/Testing. Plate heat exchanger evaporators shall be strength tested to a minimum of 1.1 times the design pressure when they are not manufactured as a pressure vessel or shall be pressure tested in accordance with ASME B&PVC, Section VIII, Division 1 when they are manufactured as a pressure vessel. In either case, they shall be subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer.
11.5 Scraped (Swept) Surface Heat Exchangers 11.5.2 Procedures/Testing. Scraped (swept) surface heat exchangers shall be tested in accordance with ASME B&PVC, Section VIII, Division 1, but at a minimum, shall be strength tested to a minimum of 1.1 times the design pressure, subsequently leak tested, and proven tight at a

pressure not less than design pressure by the manufacturer.

 11.5.2 Procedures/Testing. Scraped (swept) surface heat exchangers shall be strength tested to a minimum of 1.1 times the design pressure when they are not manufactured as a pressure vessel or shall be pressure tested in accordance with ASME B&PVC, Section VIII, Division 1 when they are manufactured as a pressure vessel. In either case, they shall be subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer.
11.6 Jacketed Tanks. 11.6.2 Procedures/Testing. Jacketed tanks shall be tested in accordance with ASME B&PVC, Section VIII, Division 1, but at a minimum, shall be strength tested to a minimum of 1.1 times the design pressure, subsequently leak tested, and proven tight at a pressure not less than

design pressure by the manufacturer.

 11.6.2 Procedures/Testing. Jacketed tanks shall be strength tested to a minimum of 1.1 times the design pressure when they are not manufactured as a pressure vessel or shall be pressure tested in accordance with ASME B&PVC, Section VIII, Division 1 when they are manufactured as a pressure vessel. In either case, they shall be subsequently leak tested, and proven tight at a pressure not less than design pressure by the manufacturer.
12. Pressure Vessels 12.2.6 *In applications where pressure vessels are subject to external corrosion, the vessels shall be designed and specified with a minimum of 1/16 in. (0.16 cm) corrosion allowance. The external corrosion allowance is in addition to the minimum vessel thickness as required by

ASME B&PVC, Section VIII, Division 1.

 12.2.6 * In applications where vessels are subject to external corrosion as determined by the owner or owner’s designated agent, suitable means shall be used to address vessel protection.
14.1 General (Packaged Systems) 14.1.3 *‍Packaged systems shall be ventilated based on the intended operation of the equipment, as specified by the manufacturer. In addition, emergency mechanical ventilation shall be provided where required by any of the following:

 

1. Package systems located in machinery rooms shall be included as machinery room equipment. Emergency ventilation for machinery rooms shall be in accordance with Section 6.14.

2. Package systems located indoors and outside of a machinery room in accordance with Section 4.2.3, Item 5, shall comply with Section 7.3.1.

3. Package systems located outside that are designed for human occupancy shall comply with Section 7.3.2. Package systems located outside that are not designed for human occupancy shall not require ventilation.

 14.5 Ventilation. Ventilation for packaged system shall comply with the following:

1.      Packaged systems that are required to be located in a machinery room as determined in Chapter 4 shall comply with Section 6.14.

2.      Packaged systems located indoors and permitted to be located in areas other than a machinery room in accordance with Section 4.2.3., item 5, shall comply with section 7.3.1.

1.      3. Packaged systems located outdoors shall comply with Section 7.3.2.

 

Note: Moved and condensed a bit
14.1 General (Packaged Systems) 14.1.4 Equipment and devices incorporated into packaged systems shall comply with the applicable

provisions of Chapter 8 through Chapter 17.

 14.1.3 Equipment and devices incorporated into packaged systems shall comply with the applicable provisions of Chapter 8 through Chapter 17.
14.1 Design (Packaged Systems) 14.2.6 *‍Access shall be provided for manually operated valves. Isolation valves identified as being

part of system emergency shutdown procedures shall comply with Section 6.3.3.1 and valve

tagging shall comply with Section 5.14.3.

 14.2.6 *Access shall be provided for manually operated valves. Isolation valves identified as being part of system emergency shutdown procedures shall comply with Section 6.3.3.1 and valve tagging shall comply with Section 5.14.4.
14.1 Design (Packaged Systems) 14.2.7 Pipes shall be marked in accordance with Section 5.14.5. 14.2.7 Pipes shall be marked in accordance with Section 5.14.6.
14.1 Design (Packaged Systems) 14.2.8 Equipment shall be labeled in accordance with Section 5.14.2. 14.2.8 Equipment shall be labeled in accordance with Section 5.14.3.
14.1 Alarms (Packaged Systems) 2.      Package systems located indoors and outside of a machinery room, as permitted by Section 4.2, shall be provided with Level 2 detection and alarms in accordance with Section 17.7.2. 3.      Packaged systems located indoors and permitted to be located in areas other than a machinery room, in accordance with Section 4.2.3, shall be provided with detection and alarms complying with Section 7.2.3 or 7.3.1.
14.1 Alarms (Packaged Systems) 3.      Package systems located outdoors that are not  intended for human occupancy shall not require ammonia detection or alarms. 4.      Packaged systems located outdoors that comply with the free-aperture requirements of Section 7.3.2 shall not require ammonia detection or alarms.

 

5.      Packaged systems located outdoors that do not comply with the free-aperture requirements of section 7.3.2 shall be provided with detection and alarms complying with section 6.13 or if permitted by section 4.2.3 shall be provided with detection and alarms complying with Section 7.3.1
15 Overpressure Protection Devices VARIOUS Note: This whole section was renumbered and partially reorganized. I’m limiting this section to the new or changed requirements.
15.1.2 Overpressure Protection Devices General Appears to be NEW 15.1.2 It is permitted to protect system piping and equipment from overpressure through unobstructed piping that is connected to pressure vessels equipped with overpressure protection. Vessels and equipment that relieve into the system must comply with sections 15.3.7 and 15.3.8.
15.1.3 Overpressure Protection Devices General Appears to be NEW 15.1.3 Rupture discs are not permitted as the only means of pressure relief. They are permitted to be used in series with pressure relief valves and in accordance with 15.2.6.
15.1.4 Overpressure Protection Devices General Appears to be NEW 15.1.4 Fusible plugs are not permitted for use as pressure relief devices.
15.2.1 Pressure Relief Devices Appears to be NEW 15.2.1 Pressure relief devices shall be direct-pressure actuated or pilot operated. Pilot-operated pressure relief valves shall be self-actuated, and the main valve shall automatically open at the set pressure. If the pilot valve fails, the main valve shall discharge at its full-rated capacity.
15.2.3 Pressure Relief Devices Appears to be NEW

 

 15.2.3 – Pressure relief devices shall not use cast iron seats or discs.
15.3 ASME pressure vessels and Non-ASME equipment 15.2.7.1 …Resetting of a pressure relief device shall be performed by the manufacturer or a company holding a valid testing certificate for this work. 15.2.8.1 – …Calibration and set pressure adjustments to pressure relief devices shall be performed by the relief device manufacturer or a company holding a certification for this work.
15.3 ASME pressure vessels and Non-ASME equipment 15.3.1 Pressure vessels and other types of equipment built and stamped in accordance with ASME B&PVC, Section VIII, Division 1, shall be provided with certified pressure relief protection. 15.3.1.1 Pressure vessels and equipment built and stamped in accordance with ASME B&PVC, Section VIII, shall be provided with pressure relief protection in accordance with the ASME B&PVC, Section VIII, Division 1
15.3 ASME pressure vessels and Non-ASME equipment 15.3.2 Pressure vessels intended to operate completely filled with liquid ammonia and capable of being isolated by stop valves from other portions of a refrigeration system shall be protected with a certified hydrostatic service relief device as required by ASME B&PVC Section VIII, Division 1. Hydrostatic overpressure relief shall comply with Section 15.6. 15.3.1.2 – *Refrigerant containing equipment not built in accordance ASME BPVC, Section VIII, and having any single ammonia-containing section exceeding 0.5 ft3 of internal volume shall be provided with pressure relief protection that is in accordance with the ASME B&PVC Section VIII, Division 1.

 

EXCEPTION: The following types of equipment are not required to have overpressure protection unless it is required by other sections of this standard:

1.      Compressors, pumps, controls, headers, piping, evaporator coils, and condenser coils

2.      Equipment built in accordance with ASME B31.5

3.      Equipment listed by a nationally recognized testing laboratory
15.3 ASME pressure vessels and Non-ASME equipment Appears to be NEW

 

 15.3.2 – Tube and Fin or microchannel evaporator and condenser coils that are located within 18” of a heating source and capable of being isolated shall be fitted with a pressure relief device that discharges according to the provisions of this chapter. The pressure relief device shall be connected at the highest possible location of the heat exchanger or piping between the heat exchanger and its manual isolation valves.

 

EXCEPTION: Pressure relief protection is not required on tube and fin or microchannel evaporator and condenser coils that are designed for 110% of ammonia’s saturation pressure when exposed to the maximum heating source temperature.
15.3 ASME pressure vessels and Non-ASME equipment 15.3.8 *‍Where combustible material is stored within 20 ft (6.1 m) of a pressure vessel that is outside of a machinery room, the relief device capacity factor, f, in the formulas shall be increased to f = 1.25 (f = 0.1). 15.3.9 *Where combustible material is stored or installed within 20 ft (6.1 m) of a pressure vessel, the relief device capacity factor, f, in the formulas shall be increased to f = 1.25 (f = 0.1).
15.4 Pressure Relief Device Piping 15.4.5 – Where piping in the system and other equipment required to comply with this section could contain liquid ammonia that can be isolated from the system during operation or service, the installation shall comply with Section 15.6 for protection against overpressure due to thermal hydrostatic expansion. * Removed as new items elsewhere address equipment specifically and existing items makes this redundant.
15.4 Pressure Relief Device Piping 15.4.7 – Atmospheric relief piping shall be used only for relieving vapor from refrigerant relief devices or fusible plugs. Relief piping shall not be used to relieve discharge from hydrostatic overpressure relief devices or any other fluid discharges, such as secondary coolant or oil. 15.4.6 – Atmospheric relief piping shall be used only for relieving vapor from refrigerant relief devices. Different refrigerants shall not be vented into a common relief piping system unless the refrigerants are included in a blend that is recognized by ASHRAE Standard 34. Relief piping shall not be used to relieve discharge from hydrostatic overpressure relief devices or any other fluid discharges, such as secondary coolant or oil.
15.5 Discharge from Pressure Relief Devices Appears to be NEW

 

 15.5.1.7 – Piping discharging to atmosphere shall have a provision to mitigate the entry of rain or snow into the discharge piping.
15.6 Equipment and Piping Hydrostatic Overpressure Protection Appears to be NEW

 

 15.6.1 *Protection Required. Protection against overpressure due to thermal hydrostatic expansion

of trapped liquid ammonia shall be provided for equipment and piping sections that can be

isolated and can trap liquid ammonia in an isolated section in any of the following situations: …5. During the shipping of any pre-charged equipment.
16. Instrumentation and Controls 16.1.2 Operating Parameter Monitoring. Instruments and controls shall be provided to indicate operating parameters of the refrigeration system and equipment and provide the ability to manually or automatically control the starting, stopping, and operation of the system or equipment. The instruments and controls shall provide notice if the system’s critical operating

parameters, as determined by the owner or operator, have been exceeded.

 16.1.2 *Operating Parameter Monitoring. Instrumentation and controls shall be provided to indicate operating parameters of the refrigeration system and equipment and provide the ability to manually or automatically control the starting, stopping, and operation of the system or equipment. The instruments and controls shall provide notice to an owner’s representative if the system’s critical operating parameters, as determined by the owner or operator, have been exceeded. Monitoring of parameters is permitted to be automatic or manual or a combination of both methods.
16. Instrumentation and Controls 16.1.7 Ultimate Strength. The pressure-containing envelope maximum allowable working pressure

of instruments and visual liquid level indicators shall be equal to or greater than the design pressure of the system or subsystem in which they are installed.

 16.1.7 MAWP. The pressure-containing envelope maximum allowable working pressure of instruments and visual liquid level indicators shall be equal to or greater than the design pressure of the system or subsystem in which they are installed.
16.4 Pressure Gauges Appears to be NEW Pressure Gauges. Pressure gages used for visually determining system pressures shall comply with this section.
16.4 Pressure Gauges Appears to be NEW 16.4.1 Design and selection. Pressure gauges shall be designed or selected in accordance with one or more of the following:

1.      Comply with the ultimate strength requirements in Section 5.13.2.

2.      Have a documented successful performance history for devices in comparable service conditions.

3.      Use a performance-based pressure-containment design substantiated by either proof tests as described in ASME B&PVC, Section VIII, Division 1, Section UG-101, or an experimental stress analysis.

1.      Is listed individually or as part of an assembly or a system.
16.4 Pressure Gauges Appears to be NEW location 16.4.2 High Side Installation. Where a pressure gauge is installed on the high side of the refrigeration system, the gauge shall be capable of measuring and displaying not less than 120% of the system design pressure.
17.7.2 Ammonia Detection * The “level 2” Ammonia Detection was defined in this section. The “level 2” section has been completely moved to an informative appendix and the “level 3” section has been renumbered to take its place in the normative text.
17.7.2 Ammonia Detection “…For machinery rooms, additional audible and visual alarms shall be located outside of each entrance to the machinery room.” Text Removed – likely because it simply duplicated the existing Machinery Room requirements.
18 Absorption Systems Entirely new section See the document

 

IIAR 9 Public Review 3

June 21, 2019 /

 

Let your voice be heard! The upcoming IIAR 9 standard will be the “fallback” RAGAGEP for older systems. Unfortunately, this is another partial PDF, so you will have to have the earlier Public Review documents to make sense of it.

 

June 21st, 2019
To: IIAR Members
Re: Third (3rd) Public Review of Standard BSR/IIAR 9-201x, Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems.
A third (3rd) public review of draft standard BSR/IIAR 9-201x, Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems is now open. The International Institute of Ammonia Refrigeration (IIAR) invites you to make comments on the draft standard. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.

BSR/IIAR 9-201x, specifies the minimum system safety requirements applicable to existing closed-circuit ammonia refrigeration systems. It presupposes that the persons who use the document have a working knowledge of the functionality of ammonia refrigeration system(s) and basic ammonia refrigeration practices and principles. This standard is intended to provide a method for existing ammonia closed-circuit refrigeration systems to evaluate and document new and revised codes, standards, and practices to determine what provisions within these codes, standards, and practices to adopt. This standard shall apply only to stationary closed-circuit refrigeration systems utilizing ammonia as the refrigerant. It supplements existing general refrigeration standards issued by IIAR and other organizations such as ASHRAE, ASME, and ANSI. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes).

IIAR has designated the draft standard as BSR/IIAR 9-201x. Upon approval by the ANSI Board of Standards Review, the standard will receive a different name that reflects this approval date.

We invite you to participate in the third (3rd) public review of BSR/IIAR 9-201x. IIAR will use the American National Standards Institute (ANSI) procedures to develop evidence of consensus among affected parties. ANSI’s role in the revision process is to establish and enforce standards of openness, balance, due process and harmonization with other American and International Standards. IIAR is the ANSI-accredited standards developer for BSR/IIAR 9-201x, and is responsible for the technical content of the standard.

This site includes links to the following attachments:

 

The 30-day public review period will be from June 21st, 2019 through July 21st, 2019. Comments are due no later than 5:00 pm Eastern Standard Time (EST) on July 21st, 2019.

IIAR 7-2019 Update

May 31, 2019 /

It’s been coming for a while now and yesterday it became official:

Introducing: ANSI/IIAR 7-2019 – Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems

In 2013, the first issue of IIAR 7 replaced the operations information contained in IIAR Bulletin No. 110, Guidelines for Start-Up, Inspection, and Maintenance of Ammonia Mechanical Refrigerating Systems.

This standard was first approved as an American National Standard by the American National Standards Institute (ANSI) in August 2013. ANSI requires reaffirmation or revision for periodic maintenance requirements of existing standards every five years. Work began on periodic maintenance of this standard in February 2017 and was completed in April 2019.

This standard defines the minimum requirements for developing operating procedures for closed-circuit ammonia refrigeration systems. Informative Appendix A was added to provide explanatory information related to provisions in the standard.

 

A little over two years ago, the SOP templates were updated to include all the requirements of IIAR 7 2013. That was a pretty large undertaking, but if you already made those changes, it looks like you are in good shape! I’ve reviewed the new IIAR 7 and it turns out we only need to make one substantive change to programs using the current templates.

 

What’s the requirement / change? 

The 2013 version required a visual inspection of hoses when they were used. This was a pretty minor requirement. The newer version requires that procedures include “Steps to inspect hoses and fittings visually to make sure they are suitable for ammonia refrigeration service”  whenever you Transfer (such as in pump-down) or Charge ammonia. To address this issue, I’ve modified the ROSOP-LEO and Permit form to include an explicit check and a reference to the “ITPMR-AHT-365 – Ammonia Transfer Hose Annual ITPM Record” we recently added due to IIAR 6.

So, if you’ve already updated your system for IIAR 6 compliance, then all you need to do is update your LEO procedure and Permit. If you haven’t updated your system for IIAR 6 compliance, then you need to integrate the new ITPMR as well as make plans to address the entirety of IIAR 6.

Note: Overall the 2019 IIAR 7 is much simpler than the 2013  version. It’s moved a lot of stuff to informative appendices which removes most of my complaints about it. Unfortunately they renumbered* just about every single requirement in the standard. This meant I had to completely renumber / rewrite my standalone SOP audit template. The good news is that the IIAR7-2019 version of that audit was reduced from 110 pages to 87. Of those remaining 87 pages of questions, 60 pages are due to IIAR 7.

* This was not an attempt to drive me closer to insanity, but an attempt to harmonize numbering systems between all the IIAR standards. I know this because I actually asked the IIAR about this. Thankfully, Tony Lundell has a good sense of humor.

Using the Hierarchy of Controls as a tool for Incident Investigations

May 28, 2019 /

The issue: Poor Incident Investigations and how to improve them

Often members of the Incident Investigation team miss some fairly obvious opportunities to improve their process safety. One trick is to use the Hierarchy of Controls as a brainstorming tool when coming up with causes and recommendations.

 

What is the Hierarchy of Controls and How can I use it as a tool during Incident Investigations?

The premise of the Hierarchy of Controls is that while hazards can be controlled in various ways, certain types of controls are inherently better than others. The hazard controls in the hierarchy are, in order of decreasing effectiveness:

Let’s take an example of an Incident Investigation concerning an unexpected employee NH3 exposure during an oil drain. While you will have to address any unique issues relating to the incident, here are some questions that the Hierarchy of Controls can provide for any oil drain incident:

Elimination: Physically removing the hazard. For example, when analyzing the risk of a valve packing leak in a process room, moving that valve to the roof would eliminate the hazard from the production room. Elimination is usually considered the most effective hazard control.

Substitution: Replacing the hazard with something that does not produce a hazard or something that produces a much smaller hazard. A common example of this is removing the hazard of NH3 in product chillers areas with the use of a secondary refrigerant such as CO2 or Glycol. Note that in some instances this results in simply relocating a hazard to another area with lesser consequences.

Note: We usually combine these two methods because if we don’t, we tend to spend more time arguing whether or not a control is an elimination or a substitution.

  • Can we avoid, or reduce the frequency of, the oil drains? Better coalescers, higher minimum head pressure to reduce oil blow-by, installation of an oil still to minimize oil draining from the system, etc.
  • Can we eliminate / reduce the NH3 involved in the oil drain? Pumpout of the oil pot and re-pressurization with shop air, conversion to a gravity drain oil pot, lower pressure suction during pumpout, etc.

 

Engineering Controls: These controls do not eliminate hazards but tend to attempt to control them or give notice when the process is approaching an unsafe state. Examples include NH3 sensors, Interlocks, High-Level Floats, Pressure and Temperature transducers, etc.

  • Is the equipment properly configured for a safe oil drain? Oil pot, “Dead-Man” valve, safe access, easy egress routes, etc.
  • Can we improve the ventilation in the area? Portable fans, local exhaust ventilation, manual use of existing Machine Room fans, etc.
  • Can we improve the hazard awareness? Local / Personal NH3 detector rather than relying on a fixed detector, pressure gauge installed during the pump-down, etc.

 

Administrative Controls: These controls are changes in the way the work is performed on or around the process. Training, Procedures, Signs and Warning labels are all administrative controls.

  • Can we improve the SOP? Better steps to address the hazards, mandating more oversight, required use of PPE, more effective use of ventilation, etc.
  • Can we improve the training? Better understanding of the hazards, procedures, PPE, tools, etc.

 

Personal Protective Equipment: PPE such as gloves, respirators, etc. is generally considered the last resort of hazard control.

  • Can we improve the PPE available? Can we make certain PPE mandatory? Improved gloves, smocks, respirators, etc.

 

Using the Hierarchy of Controls can be a great brainstorming tool to help you look at your possible causes, and your possible corrections from some new angles.

The Five Stages of PSM Grief

May 20, 2019 /

How many times have you as a PSM manager had to present to operators or management some new understanding of the requirements of PSM? Maybe it’s a new IIAR standard, or some other RAGAGEP requirement.

Individuals don’t like to change. Organizations REALLY don’t like to change. There is always some resistance and many years ago, I noticed that it resembled the Kübler-Ross stages of grief that people go through when losing a loved one or being diagnosed with a terminal disease.

Here’s a humorous take on the stages of policy acceptance we deal with from our coworkers:

  • Denial: “There is no way I am doing that. We’ve been doing it this way for 25 years. They can’t be serious. You must have misunderstood the requirement.”
  • Anger: “You’re an idiot. Why are you putting us through this – this will never work. I’ll tell those OSHA/EPA/IIAR guys what for!”
  • Bargaining: “Fine, I’ll just pencil whip it and ignore the policy as soon as you turn your back. My buddy at another place says they just ignore this so we should too. It’s not like we’ll ever get caught anyway.”*
  • Depression: “They’re serious! We’re actually going to have to follow this new policy. This is insane! We’ll never have time to get our work done now.”
  • Acceptance: “You know. This isn’t as bad as I thought. On balance, it might actually be a little bit better than the old way.”

*Note: It’s possible to stop at this stage – and still be compliant – if you actually create an alternative means of addressing the issue that the new requirement does. It’s difficult to prove that your alternative solution is as safe or safer than the RAGAGEP, but it is possible. In most cases, it’s just easier to move on to Acceptance and implement the new RAGAGEP!

One Hazard, Multiple Attempts at Control

May 7, 2019 /

Given the catastrophic nature of the hazards associated with PSM, the interrelationship of the PSM elements work together as a safety net to help ensure that if the employer is deficient in one PSM element, the other elements if complied with would assist in preventing or mitigating a catastrophic incident. Consequently, the PSM standard requires the use of a one hazard-several abatement approach to ensure that PSM-related hazards are adequately controlled. (OSHA, CPL 2-2.45A, 1994)

 

The text above, from OSHA’s old PQV (Program Quality Verification) audit is critical to understanding a key concept of successful Process Safety: The more ways you attempt to control a hazard, the more likely you are to be successful.

Sometimes this concept is referred to as the “Swiss Cheese Model.” I’ll quote from Wikipedia:

It likens human systems to multiple slices of swiss cheese, stacked side by side, in which the risk of a threat becoming a reality is mitigated by the differing layers and types of defenses which are “layered” behind each other. Therefore, in theory, lapses and weaknesses in one defense do not allow a risk to materialize, since other defenses also exist, to prevent a single point of failure. The model was originally formally propounded by Dante Orlandella and James T. Reason of the University of Manchester, and has since gained widespread acceptance. It is sometimes called the cumulative act effect.

To understand how this works in a functioning program, I want to point out how we recently addressed a single hazard in our program to show how many different ways we attempted to control it.

 

The hazard

 In IIAR’s upcoming standard 6 “Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems” a hazard is identified and a prohibition is put in place to address that hazard:

 

5.6.3.4 Hot work such as the use of matches, lighters, sulfur sticks, torches, welding equipment, and similar portable devices shall be permitted except when charging is being performed and when oil or ammonia is being removed from the system.

 

The IIAR is recognizing that there is an increased likelihood of an Ammonia / Oil fire during charging operations and when oil / ammonia is being drained from the system. They are prohibiting Hot Work operations during these operations to remove potential ignition sources.

 

The Control(s)

You can make a (weak) case that simply referencing the RAGAGEP and inserting a single line in your Hot Work policy address the compliance requirement, but we’re going to need to do a lot more to make this prohibition a “real” thing in our actual operations.

 

Control Group #1: The Hot Work element

In the element Written Plan, we added two new “call-out’s” in the two places they are likely to be seen when planning Hot Work policies. First, in the section on Conducting Hot Work:

 

Second, in the section on Sulphur Stick use:

 

Third, in the Hot Work Permit itself, we modified the existing question on flammable atmospheres:

 

Control Group #2: The Operating & MI Procedures

All procedures that involve oil draining, ammonia charging and ammonia purging already point to the LEO (Line & Equipment Opening a.k.a. Line Break) written procedure. This makes our job a bit easier here, since we only have to modify our LEO rather than the dozens of procedures that might include this type of work.

We modified the traditional LEO “General Precautions section to place a check for Hot Work during an existing requirement to canvas the area for personnel that may be affected by the LEO:

 

In the more advanced, two-step “Pre-Plan and Permit” version of our LEO, we modified the “Pre-Plan Template” to include a warning:

 

In both versions of the LEO permit itself, we added an explicit check:

 

Closing Thoughts

This one small RAGAGEP change points to a single hazard – a hazard that we’re now trying to control in six different ways. Notice that we’ve made all these changes so they are popping up throughout the program:

  • In preparing policies for the associated work;
  • In the course of preparing for the work itself;
  • In the course of conducting the potentially hazardous operations.

This is critical because if we want to get the best “bang for our buck” in Process Safety, the safety portion has to be integrated into our actual processes on multiple levels.

Obviously, we’ll have to train on these changes to ensure that they’ll be effective. It’s quite possible that, after implementation, we’ll identify additional ways to prevent the hazard from being realized and will need to make further changes.

« Older posts Newer posts »

Contact Us

© 2025 RC&E Chill – Industrial Refrigeration and Process Safety / Risk Management

Theme by Anders Noren — Up ↑