Category: General Interest (Page 1 of 3)

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

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

 

Public Review Announcement

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

 

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

 

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

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

Happy 7/17!

Today is Ammonia (7/17) Day! 

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

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

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

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

  • Show gratitude to your mentors
  • Become a mentor

 

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

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

 

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

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

 

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

Happy 7/17!

7/17 Day is this coming Sunday! 

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

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

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

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

  • Show gratitude to your mentors
  • Become a mentor

 

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

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

 

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

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

 

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

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

Public Review Announcement

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

 

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

 

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

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

Link: Access IIAR 1 Draft & Comment forms

Link: Access IIAR 3 Draft & Comment forms

Can long Lead Times impact Process Safety?


“Time Waits for No one…”

The Issue at hand

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

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

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

 

Current Lead Time estimates

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

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

 

How can this affect Process Safety?

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

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

 

What should I do?

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

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

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

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

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! [email protected]    (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 \

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!

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