Safety Bulletin on P-Series Valves

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.

Ammonia Process Safety below 10,000 pounds

One of the most frequent misconceptions we’ve been dealing with in our industry is a belief that being below the PSM/RMP threshold means you are in some sort of wild-west no-man’s-land where there are no rules. Previously we’ve dealt with that issue in a post called “General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?” But that post was really written to people that were considering lowering their NH3 inventory to avoid regulation.

We thought it would be useful to put together an article that dealt with those systems that were already under the PSM/RMP threshold so they better understood the Safety & Regulatory landscape. To that end, we’ve put the information in a executive level 3-page pdf that is easy to email: Ammonia Process Safety below 10k

Email or call us today to have RC&E assist you with all your PSM/RM Program needs! info@RCE-Chill.com    (888) 357-COOL (2665)

OSHA increases vigilance on Heat Stress

OSHA has announced that they will be ramping up enforcement of their Heat Stress initiative under the General Duty clause.

US Department of Labor announces enhanced, expanded measures to protect workers from hazards of extreme heat, indoors and out
Part of an interagency Biden-Harris administration effort to protect workers, communities

WASHINGTON – To combat the hazards associated with extreme heat exposure – both indoors and outdoors – the White House today announced enhanced and expanded efforts the U.S. Department of Labor is taking to address heat-related illnesses.

…OSHA Area Directors across the nation will institute the following:

  • Prioritize inspections of heat-related complaints, referrals and employer-reported illnesses and initiate an onsite investigation where possible.
  • Instruct compliance safety and health officers, during their travels to job sites, to conduct an intervention (providing the agency’s heat poster/wallet card, discuss the importance of easy access to cool water, cooling areas and acclimatization) or opening an inspection when they observe employees performing strenuous work in hot conditions.
  • Expand the scope of other inspections to address heat-related hazards where worksite conditions or other evidence indicates these hazards may be present.

In October 2021, OSHA will take a significant step toward a federal heat standard to ensure protections in workplaces across the country by issuing an Advance Notice of Proposed Rulemaking on heat injury and illness prevention in outdoor and indoor work settings. The advance notice will initiate a comment period allowing OSHA to gather diverse perspectives and technical expertise on topics including heat stress thresholds, heat acclimatization planning, exposure monitoring, and strategies to protect workers.

The agency is also working to establish a National Emphasis Program on heat hazard cases, which will target high-risk industries and focus agency resources and staff time on heat inspections. The 2022 National Emphasis Program will build on the existing Regional Emphasis Program for Heat Illnesses in OSHA’s Region VI, which covers Arkansas, Louisiana, New Mexico, Oklahoma and Texas.

 

 

 

 

 

 

It’s important to ensure you have a properly implemented Heat Stress program including:

  • Establishing a written policy regarding Heat Stress
  • Provided appropriate resources to implement the policy
  • Training all your employees on the policy

 

Source: DOL on Twitter and at their Website

 

Updated IIAR 2-2021 Standard Released

IIAR 2 – 2021 Standard for Design of Safe Closed-Circuit Ammonia Refrigeration Systems has been released by the IIAR and is now available for purchase on their website

The updated standard has several new requirements which resulted in some changes in the PSM/RMP program templates. Here are some of the highlights:

  1. The definitions file was updated with new IIAR 2 definitions. Added in-document headings to skip around the document easily.
  2. The PHA Checklist Template was updated to the new IIAR 2:
    • Added a note that “Provisions for plugs or caps required under IIAR 2 5.9.3.3” on all oil draining plug/cap questions.
    • Added a note that “IIAR 2-2021 5.12.2 requires a check valve during charging” in relevant Charging SOP section.
    • Added a question on Provisions for Pumpout per IIAR 2-2021 5.12.6 on PV1 subsection and all Equipment Subsections.
    • Added/Modified questions on RC1 section about low ambient temperature, and VFD resonance.
    • Added a question on EV2 (Liquid Heat Exchanger) equipment subsection regarding secondary coolant side pressure ratings.
    • Added a question on MR.C Checklist for Classified Space signage.
    • Added a question on PV1 (Piping & Valves) on new MOPD & MSSPD requirements for valves leading to atmosphere.
    • Added a question on PV1 (Piping & Valves) on requirements for unique identification for Emergency Shutoff valves.
    • Modified existing .PSV equipment sub-subsections to include IIAR 2 2021 15.2.6 requirement that liquid relieving reliefs relieve back into the system.
    • Added a note that IIAR 2 2021 13.2.3.1.1 limits carbon steel tubing and carbon steel compression fittings to valve sensing pilots, compressors, compressor packages, and packaged systems to all small-bore piping / tubing questions.
    • Updated MR.C section for new requirements regarding NH3 detection.
    • Updated various checklists (VENT, DET, PSV, DT) to match current IIAR 2-2021 text.
    • Added a new equipment subsection NMR.C for IIAR 2 Equipment located outside of Machinery rooms.
    • Added a new equipment subsection PKG.C for IIAR 2 Packaged Systems and Equipment.
    • Added a new equipment subsection IAC.C for IIAR 2 Instrumentation Controls.
  3. Updated “Contractor Door Sign” to meet new IIAR 2 – 2021 [5.14.1.1] information standards and some ASHRAE 15 – 2019 [11.2.1] standards.

Comments about the changes and the required steps to implement the document changes are present in the “Change Log and Reference” document at 08/02/21.

…Read on further in this post if you want to know about the changes in the new IIAR 2…

 

Continue reading

Justifying the Ammonia delivery?

The issue: A facility with an ammonia refrigeration system notes that their HPR level is rather low, and they are considering ordering some ammonia to get back to the levels they “used to have.” The thinking is that they need to add to the ammonia charge to make up for ammonia that was lost over the years.

Before you go too far, a good question to ask is: Did I lose ammonia? Or is it just somewhere else in my system?

 

What if you didn’t lose it?

Did you add equipment without your MOC addressing if this required an inventory adjustment? Did you change recirculator vessel levels which make the HPR look low even though the ammonia is still out in the system? Has someone been mucking with the HXV’s or TXV’s, so you are “brining” coils? These are common issues, but the most likely culprit is seasonal variation.

If it’s August in Texas, it’s likely that your system is running about as hard as it will ever run. That means that the NH3 isn’t just hanging out in your vessels, but out in the various heat exchangers (and their piping) doing its job. The “good old boy” method of testing this was to wait until the cool of the night, shut down the liquid feed to your “load,” and check the vessel levels after the NH3 came back.

A more “modern” method is to use an inventory spreadsheet and adjust the levels in the heat exchangers to reflect the summer load. The intricacies of doing either of these are better dealt with in the real world rather than a blog-post, so let’s assume you have already checked this and you actually do need ammonia. (Note: if you need assistance with either of the above, we can certainly assist you, just give us a call)

 

Ok, maybe we did lose it!

If you look into the situation and find out that you actually do need ammonia, there are a few considerations you should think of BEFORE you order that truck and start preparing for delivery.

  • Figure out how much. Use an inventory spreadsheet (or have an engineer do it for you) to figure out how much ammonia you need to get back to your “normal” level.
  • Review your charging SOP with the refrigeration team to make sure you are all on the same page. This isn’t something you should be doing often so take this opportunity to review, validate, and TRAIN on this procedure.
  • Document where you think that ammonia went! For most facilities this is just calculating your “leak” rate. This is your “justification” that you are replacing lost ammonia, not adding to your intended inventory level.

 

Justifying the charge

Assuming you didn’t have some sort of incident that clearly explains why you need ammonia, we should figure out how to justify the amount we’re adding. Most losses are easily justified by establishing a “loss rate” and comparing it to accepted norms. This acceptable loss would be caused by normal maintenance, auto-purgers, and fugitive emissions.

In my opinion, anything less than 5% is good. 2-3% is excellent. For what it’s worth, the IIAR has stated that up to 10% loss a year is “reasonable.”

A loss rate of 3% or less a year can easily be explained from normal maintenance, auto-purgers, and fugitive emissions.

This is easier to explain with a worked example from a friend. In this case, their inventory level is supposed to be 5,800lbs. When they updated their inventory sheet to reflect the actual conditions at the facility, they saw a calculated current charge of 5,000lbs reflecting an 800 pound loss. That loss occurred since their last charge 5 years ago.

This percentage is easily explainable from maintenance and other fugitive emissions, and it’s also quite reasonable.

If you take the time to figure out the math above, and then document your calculations to justify your NH3 charge, it helps avoid unpleasant assumptions on the part of the EPA and OSHA in any future inspections.

If an auditor comes in and sees an ammonia delivery receipt, a documented rationale why the ammonia was needed, the SDS of the chemical charged, and you have a compliant charging procedure, it would be very unlikely that the charging process would be questioned further.

Of course, if your math shows a high leak rate, then you had better get an incident investigation going and figure out what’s wrong!

 

P.S. – To assist in this effort, Scott updated the Ammonia Inventory example template has been updated to help automate this process. Just enter the old value, newly measured value, and time (in months) since last charging and you have a 1-page report on the % loss per year. We hope this helps. The file can be located at: \ PSM-RMP Program Templates \ 03 – Process Safety Information \ Optional Resources \

PHA Synergy: How to get more out of the PHA process

According to 1910.119(e) and 40CFR68.67(a) the purpose of a PHA is to “…identify, evaluate, and control the hazards involved in the process.” Since the mid-90’s the refrigeration industry has done this mainly through the IIAR’s “What-If” methodology as suggested in their Compliance Guidelines materials.

There have been many revisions of this material over the years, but they all have the same thing in common as you use them: You can see how each question / item:

  • Poses a failure scenario (sort of a lesson someone else has already learned)
  • Prods you to solve the issue through an existing RAGAGEP

For example, a question might ask something like “What if plugs, caps, or blind flanges are missing on purge or drain valves?” This should prod you to recall that both IIAR 2 and IIAR 4 require that these things be plugged, capped, etc. This should also prod you to ask how you are addressing this requirement in your Process Safety Program.

The issue we always came across is that you must KNOW or MEMORIZE what the RAGAGEP says in a very complete way, or you miss the connection between the “What If” scenario and the RAGAGEP. This is nearly impossible because it seems like RAGAGEP is multiplying at an alarming rate. Furthermore, this (at least two day) process often feels like a futile effort at figuring out what the “What-If” scenario questions are really getting at.

To improve this years ago, I started adding two things to the IIAR standard questions:

  1. References to the IIAR standards where appropriate. (For example, in our plug question, reference IIAR 2-2021 13.3.2.6 & IIAR 4-2020 10.4.5.4)
  2. Explicit checklists that allow you to compare your system to appropriate RAGAGEP outside of the “What If” scenarios.

 

It’s very easy to lose sight of evolving RAGAGEP over time. These checklists allow you to perform a forensic examination of your system compared to current RAGAGEP. In addition to the issue of improving RAGAGEP compliance, we also face other challenges.

  1. It is common to show up to perform a PHA and find the client lacks critical Process Safety Information and PSM elements & procedures making a compliant PHA extremely difficult or impossible.
  2. Incident Investigations are often in a state of disarray or incomplete making their inclusion in the PHA difficult at best, and almost meaningless at worst.
  3. IIAR 9 now requires an evaluation against its minimum requirements for all NH3 refrigeration systems at least every five years.
  4. In some regions the EPA has an almost absurd number of questions they “like” to see in your Facility Siting sections.
  5. The Emergency Action Plan is a critical safeguard in your program, and it is usually missing some basic items that aren’t apparent until you try and use it in an emergency.
  6. Finally, the IIAR has standards on Installation, Commissioning, and Decommissioning that are often overlooked.

 

This again leads us back to checklists. I created them for basic PSI & PSM items, Incident Investigations, IIAR 9, Facility Siting, EAP, IIAR 4, IIAR 6, and IIAR 8. Here’s what that looks like:

As you can see, that’s fairly comprehensive, but it’s also a lot more work! To adjust to all this, we usually perform PHA’s in a two-step process.

Step 1: Weeks in advance, we give the client the relevant checklists and have them fill them out to the best of their ability.

Step 2*: Once we’re on-site, we go over the checklists they’ve worked on to answer any questions, address discrepancies, etc. THEN we move on to the “What If” scenarios.

* Of course, if the client wants, we can always book another two or three days of our time helping them on-site with Step 1.

 

The result of this longer, more comprehensive process is:

  • A nearly point-by-point check of the facility (and their Process Safety program) against common RAGAGEP from a HAZARD perspective rather than a compliance one.
  • A much better understanding of the “What If” scenario questions when we get to them after the checklists.
  • Cleaner, more systemic recommendations that point to specific hazards and the RAGAGEP that most effectively addresses them.
  • At the end of the PHA process, facility team members have a much clearer understanding of where the requirements and recommendations are coming from.

You can learn more about our PHA offerings here. Email or call us today to have RC&E assist you with all your PSM/RM Program needs! info@RCE-Chill.com    (888) 357-COOL (2665)

Happy 7/17!

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!

U.S. Department of Labor Announces Annual Adjustments to OSHA Civil Penalties

WASHINGTON, DC – The U.S. Department of Labor has announced adjustments to Occupational Safety and Health Administration (OSHA) civil penalty amounts based on cost-of-living adjustments for 2021.

In 2015, Congress passed the Federal Civil Penalties Inflation Adjustment Act Improvements Act to advance the effectiveness of civil monetary penalties and to maintain their deterrent effect. Under the Act, agencies are required to publish “catch-up” rules that adjust the level of civil monetary penalties, and make subsequent annual adjustments for inflation no later than January 15 of each year.

OSHA’s maximum penalties for serious and other-than-serious violations will increase from $13,494 per violation to $13,653 per violation. The maximum penalty for willful or repeated violations will increase from $134,937 per violation to $136,532 per violation.

Visit the OSHA Penalties page for more information. The Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2021 final rule is effective January 15, 2021, and the increased penalty levels apply to any penalties assessed after January 15, 2021.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.

The mission of the Department of Labor is to foster, promote, and develop the welfare of the wage earners, job seekers, and retirees of the United States; improve working conditions; advance opportunities for profitable employment; and assure work-related benefits and rights.

While I’m sure the next few years are going to be very interesting from a regulatory standpoint, this is just he annual change to reflect inflation.

Link to full press release.

The 2020 Christmas Update

Merry Christmas to our Ammonia Refrigeration Process Safety community!

 

Well, this year has been interesting, eh? The hits keep coming it seems, and it was no different to those of us in the Process Safety field. Behind the scenes, we’ve been working on a fairly major set of improvements to the PSM system. Originally scheduled for August, we’ve finally managed to push it across the finish line just in time for the Holidays!

Significant improvements were made to the core of the system (The SOPs and ITPMRs) through an unprecedented amount of end-user feedback. Remember, this system relies on the feedback of operators, technicians, service personnel, and Process Safety professionals to improve.

All updated documents have the 122520 date-code, but here’s a run-down:

  • Minor updates to definitions file
  • All element written plans:
    • Where it was appropriate, did a little harmonization with the newest IIAR Process Safety Management & Risk Management Program templates. (There isn’t really anything they cover we don’t, but there are some places we harmonized the phrasing where we cover the same ground)
    • Ensured all element Written Plans refer to the ROSOP QA – Document Quality Control section in the Document Management
    • Minor editing / formatting improvements
  • Minor change to Operator Training element to ensure that Initial Training on Incident Investigation includes a review of recent and routinely recurring incidents.
  • Improvements to the II element written plan’s “Incident Investigation Process Flowchart”
  • SOPs
    • Minor changes to the Implementation Policy: Review and Annual Certification to harmonize with the IIAR guidance
    • Annual SOP Certification letter improved to correlate with the SOP element Written Plan more closely
    • The SOP element Written Plan Implementation Policy: SOP Authoring / Generation section now provides “Best Practices” standard language for warnings, step comments, step instructions, etc.
    • ALL SOP Templates now:
      • Use the “Best Practices” language.
      • Include better language tying them to the ITPMRs
      • Reference ROSOP-PPE in the Safety considerations section
      • Additional Equipment Considerations added to harmonize with the IIAR guidance
    • ROSOP PPE slightly improved with reference to LEO
    • ROSOP LOTO improved with improved language from end-users
    • Minor updates to ROSOP QA – Document Quality Control section.
    • ROSOP LEO streamlined and simplified with a good amount of end-user feedback
    • New ROSOP ITPM based on significant end-user operator input and feedback (See MI section below)
  • MI / ITPMRs
    • All ITPMRs now provided as PDF forms as well as Word documents
    • All ITPMRs have improved references including to the new ROSOP ITPM
    • All ITPMRs now have a space to record task hours
    • All frequency ITPMRs are now in a single document. For example, previously we would have a 30-day, 90-day, and 365-day ITPMR for condensers. Now we have a single ITPMR for condensers with all the items and you simply use the applicable sections. This allowed each step in the ITPMRs to have its own unique step code. This is important because….
    • A new SOP was created called ROSOP ITPM which includes additional information for less-skilled operators and technicians. This new ROSOP also is used as a repository of best-practices and collected knowledge from field operators. Relevant guidance from applicable IIAR standards was also included directly in the SOP where we thought it useful to those performing the MI work. A group of contractor service technicians and end-user operators contributed to the creation of this SOP and We FULLY expect this SOP to grow and improve as we get even more field use and operator feedback.

 

To implement:

  • Written Plans: Follow the Implementation Policy: Managing Procedure / Document Changes. These should be straight-forward.
  • Definitions file: Replace with the new one
    1. For the new PPE and LOTO templates, either adopt them as-is or incorporate their changes to your existing PPE & LEO SOPs
    2. For all your equipment SOPs, consider updating them to the new language during your next scheduled revision / team review.
    3. For the NEW ROSOP-ITPM and PSSRs see the MI section below
  • MI: Replace the existing ITPMRs with the new ones, providing training that when the CMMS (or other scheduling system) calls for a frequency based ITPMR, just use the equipment specific ITPMR and fill it out to the appropriate frequency.
  • Provide training on the new ROSOP ITPM. Please collect feedback for improvements so we can all improve its performance.

Updated IIAR 4-2020 and IIAR 8-2020 standards released

IIAR 4-2020 Installation of Closed-Circuit Ammonia Refrigeration Systems and IIAR 8-2020 Decommissioning of Closed-Circuit Ammonia Refrigeration Systems have been released by the IIAR and are now available for purchase on their website. IIAR 8 didn’t change much, but this was a very significant change to the existing IIAR 4 standard.

In SHORT, here’s what you need to know as an end-user:

  1. For current/future projects that involve the installation, startup, and commissioning of new equipment, use the “IIAR 4 APP-B Checklist Tracking Log Template” to manage adherence to IIAR 4 before, during, and after the installation. Once this tracking log has been completed, you can document the final status in the PHA .ISC.APPB section of the related project PHA. (The tracking log is in \PHA\PHA Study Template\Optional Resources\)
  2. Ensure future PHA’s (including project PHA’s) comply with the requirements of IIAR 4 by using the existing equipment specific .ISC section and the new .ISC.C checklist section.

 

The long version follows…
Continue reading

« Older posts