Category: PSM Templates (Page 1 of 3)

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

Powered Industrial Trucks in Machine Rooms

Powered Industrial Trucks (PIT) in Machine Rooms are a known struck-by hazard.  What most people don’t realize is how serious the results of a PIT impact in a Machinery Room can be.

For example, a forklift / scissor lift impact that shears a 3″ TSS (ThermoSyphon Supply) or HPL (High Pressure Liquid) operating at a typical head pressure of 160PSIG results in a release rate of over 18,500 pounds per minute.

Many facilities attempt to establish a ban on PIT in their machinery rooms, but while the needs for PIT in machine rooms are very limited, there are situations where they are necessary. An outright ban won’t likely survive prolonged contact with reality.

To address this issue in a PHA, we usually recommend a Written Machine Room PIT policy as an administrative control. For years we’ve discussed the content of that policy informally with people. Recently a PSM coordinator shared her written policy & permit with us and after some alterations and formatting, we’re adding it to the SOP Templates section.

Front of the Permit:

Back of the Permit with additional explanations:

 

As always, you can find this on the Google Shared template drive.

Trump EPA goes LIVE with new RMP rule: Is this finally the end of the saga?

The story so far…

Dec 2016: Outgoing Obama EPA releases changes to the RMP rule on the way out the door.

Apr 2017: Incoming Trump EPA puts the RMP rule changes on hold.

Jun 2017: Trump EPA further delays the RMP rule changes.

May 2018: Trump EPA proposes new RMP rule changes, reversing Obama changes.

Aug 2018: DC District Court reverses Trump Rule and re-instates Obama rule essentially making it the existing rule with compliance dates in the past. Trump EPA is basically told that it can change the rules, but it needs to follow different procedures to do that. Trump admin appeals and the rule changes are put on hold.

Sep 2018: Trump admin loses appeals. Obama RMP rule changes are officially LIVE. Trump EPA announces that they will follow the different procedures and change the rule the right way. (Not-so-secretly, the entire EPA is told NOT to enforce the new rule, but out of an abundance of caution, most RMP adherents implement the changes anyway. After all, it IS the law.)

Dec 2019: Trump EPA officially posts the new rule and places it in the CFR making it LIVE on 12/19/19. (See links at the end of the post)

 

So, where do we stand now?

Ok, we’ve got a new RMP rule. It appears to have gone through the correct rulemaking process. It’s been published in the Federal Register making it the law of the land.

 

So, what do we do now?

Well, let’s be honest; the Trump administration IS GOING TO GET SUED over this. What happens then? Who knows!? If you follow the courts in modern America, you know there is very little that can be accurately forecasted.

What we do know is that we have a new rule. The new rule appears to have been done correctly with sound documentation as to the reasoning for the changes. In my opinion, the new rule will LIKELY hold up in court. Even if it doesn’t, it is highly unlikely the EPA could get away with fining / citing people for not following a court-reinstated rule under such a cloud of confusion.

In any case, the new rule is easier to follow and makes more sense than the Obama EPA rule changes did. It reverts the majority of the RMP rule to match the PSM rule where they SHARE jurisdiction. The only substantive changes are to the EPA-specific areas where the EPA alone holds jurisdiction.

 

Ok, so how do I comply with this new rule?

If you do use our template system, I’ve got some good news for you! This is where using a set of open-sourced, professionally curated templates really shines. ALMOST ALL THE WORK has been done FOR YOU!

  • To improve your understanding of the new rule, read how we changed the program to meet the new requirements. This will help you to train your colleagues on them.
  • Replace existing copies of the affected Written Plans / Forms, taking a moment to look at the changes between the older versions and the new ones.
    1. Implement new EAP-C form.
    2. Modify the MI-EL1 EAP/ERP line to reflect the new text.
  • Train all Responsible Persons and affected management on the new policies.

Note: Estimated time for the above is about 2-4 hours depend on how well you know your PSM/RMP program.

 

On the other hand, If you don’t use our template system, you’re going to have to re-create the work I’ve already done:

  • Skip to the end of this article to get the links to the new information.
  • Read the 83-page Federal Register notice and make a series of notes about the new requirements. You can probably skip the 109 footnotes for now.
  • Compare those new requirements to the version of the RMP rule your program is CURRENLY written to comply with; whether that’s the pre-Obama, Obama, or Trump proposed version.
  • Starting at the beginning of your program, read through each of your Element Written Plans and see what changes have to be made. Refer to your notes from the first step. (You may wish to read how we changed our program to meet the new requirements)
  • Update / alter your program to meet these new requirements.
  • Train on these new changes

Note: Estimated time for the above is about 40-80 hours depend on how well you know your PSM/RMP program and the EPA RMP rule.

 

Template Program changes in detail

Please note, where not specifically shown below all affected Element Written Plans had their CFR section updated to the current 12/19/19 CFR.

Element What Changed Changes to Program Templates
01 – RMP
  1. A few definitions were deleted
  2. Some compliance dates and RMP references were changed
  3. Various Program 2 Changes
  4. Public meetings changes
  5. RMP Filing changes regarding 3rd party compliance audits, public meetings, etc.
  6. Removed significant amounts of publicly available information
  1. As our definition file isn’t limited to EPA sources, no changes were made to the template program documents.
  2. Previously there were sections about the Obama-era law that had a 2021 date tag – these sections were either deleted (because they were removed) or the date tag was removed.
  3. The element written plans are designed around Program 3, so no changes were made in them however all relevant CFR sections were updated.
  4. Updated the Element Written Plan to address these issues
  5. Updated the CFR to reflect the changes.
  6. Updated the Element Written Plan to address these issues
02 – EP N/A None
03 – PSI
  1. Removed the explicit requirement to keep PSI up to date.
  1. While we updated the CFR text, this is sort of implicit in the MOC/PSSR program and the very nature of PSM, so no changes made to the Element Written Plan.
04 – PHA
  1. Removed a nebulous requirement to look for “any other potential failure scenarios”
  2. Removed a section on alternative risk management for chemical / petro plants.
  1. While we updated the CFR text, this is sort of implicit in the idea of a PHA, so no changes were made in the Element Written Plan.
  2. These changes did not cover the NH3 refrigeration industry, so no changes were needed in the Element Written Plan.
  3. Since the explicit PSI “up to date” requirement was removed from the PSI section, it was removed from the PSI checklist in the PHA What-If checklists.
05 – SOP N/A None
06 – OT
  1. Removed an explicit requirement that “supervisors with process operational responsibilities” were covered under this program.
  1. We believe that operators under this element are defined by their function not their title / job position, so no changes were needed in the Element Written Plan.
07 – CQ N/A None
08 – MI No changes to RMP requirements
  1. The MI-EL1 section covering recurring PSM tasks in EAP/ERP was updated to remove the 2021 date codes. While the 10yr Field Exercise frequency is now just a suggestion (rather than a mandate) we’ve kept it in as a good practice.
09 – HW N/A None
10 – MOC / PSSR No changes to RMP requirements
  1. The procedural section “Implementation Policy: Managing Equipment / Facility Changes and using form MOC-1” includes a chart on possible changes to RMP-required information based on an MOC. The reference to “public information” has been removed from this chart.
11 – II
  1. Removed explicit requirements for incident location, time, all relevant facts, chronological order, amount released, number of injuries, etc.
  2. Removed a requirement that Incident Investigations be completed within a year
  1. While we removed these requirements from the CFR section, we believe they are still important for Incident Investigations and they’re already required by relevant RAGAGEP, so no changes were made to the Element Written Plan, the investigation instructions, or the Form-IIR Incident Investigation form.
  2. While we can’t imagine this wouldn’t occur naturally in a functioning process safety program, we removed the requirement. The program – as written – already suggests interim reports when investigations are lagging.
12 – EPR
  1. Lots of changes here: Modified information sharing requirements with responders, modified frequency of field exercises, modified scope of field and tabletop exercises, documentation requirements, compliance dates, etc.
  1. These changes were all incorporated in the Element Written Plan.
  2. To improve program performance, a new form was created “EAP-C Local Authority Coordination Record.” This form was also included in the Element Written Plan.
13 – CA
  1. Removed requirements for 3rd party audits
  1. These changes were all incorporated in the Element Written Plan.
14 – TS
  1. Modified text in the “CBI” section to reflect new wording in the updated rule.
  1. While it’s been changed in the CFR text, it requires no change to the Element Written Plans.

Item-by-Item changes:

  • Reference\EPA Reference\ has been updated with a PDF of the Register Notice.
  • Reference\CFR – Text of Federal Rules\ has been updated with a complete and formatted CFR reflecting the new changes.
  • The various element affected template directories have been updated with Element Written Plans that incorporate the new CFR text AND modified policies to comply with the rule changes
    • 01 – EPA RMP
      • Element Written Plan – REPLACE
    • 03 – Process Safety Information
      • Element Written Plan – REPLACE
    • 04 – Process Hazard Analysis
      • Element Written Plan – REPLACE
      • PHA Worksheet Template – REPLACE
    • 06 – Operator Training
      • Element Written Plan – REPLACE
    • 08 – Mechanical Integrity
      • MI-EL1 Form updated. You may just wish to modify the EAP/ERP line to reflect the new text rather than re-create the form.
    • 10 – Management of Change and PSSR
      • Element Written Plan – REPLACE
    • 11 – Incident Investigation
      • Element Written Plan – REPLACE
    • 12 – Emergency Planning and Response
      • Element Written Plan – REPLACE
      • NEW Form EAP-C – Implement
    • 13 – Compliance Audits
      • Element Written Plan – REPLACE
      • Optional Combined PSM RMP Compliance Self-Audit Checklist – REPLACE
    • 14 – Trade Secrets
      • Element Written Plan – REPLACE

 

EPA links for new information:

  • Updated CFR (aka “law”) from eCFR: link (37 Pages)
  • Federal Register Notice including reasoning for changes: link (83 Pages)

New Year, “New” SOP Format

The spirit of Christmas may be behind us, but the spirit of Continuous Improvement never leaves us alone. (for better or worse, lol)

After months of minor changes and revisions off-line, the 2020 SOP templates have been released. Please note: These are IMPROVEMENTS, not compliance or safety-critical changes. As such, there is no need to go back and change your existing SOPs. We would, however, suggest you use these new formats as you implement new SOPs. Of course, it’s possible, you may want to take advantage of some of the features of these new SOP templates, and you’re welcome to convert to them if you have the time.

Changes to ALL SOP Templates:

  1. Moved “Covered Equipment” to “Objective” section which eliminates Document Info section.
  2. Moved “Related Documents” to “Objective” which eliminates Related Documents section.
  3. Removed “SOP Objective” from first section as the objective is repetitive and explained clearly in the Written Plan. (It’s the first text box of the SOP so it’s fairly obvious what the function is!)
  4. Made Safety Warning triangle smaller and made the warning RED. This change (among others) frees up a bit of room for the Safety, Health, Environmental and Equipment Considerations section
  5. Moved the Operator Requirements concerning authorization to the top of the Safety, Health, Environmental and Equipment Considerations section thus eliminating the Operator Requirements section. Also provided a callout to the operator to check their OT1 to ensure they’re qualified to perform the procedure.
  6. Modified the Operating Phase flowchart section layout to take up less space.
  7. Minimized the left-hand column which shows what “Section” you are in to 1” width to take up minimal space. Centered the section text.
  8. Placed Headings between sections. This required splitting up the various Operating Phase / Procedural sections but makes navigation much easier if being used in WORD or PDF format.
  9. Added complementary color to enlarged text “body” sections of Operating Phase / Procedural Sections.
  10. Valve / Component List given a header. Sub-header appropriately colored.

Why did we make those format changes?

  1. Those changes yield a slightly shorter SOP format (average 1 page loss per SOP)
  2. These are collections of various suggestions we’ve received over the past year from end-users.
  3. The resulting SOPs are much more visually appealing, especially on tablets.
  4. The resulting SOPs are much easier to navigate on tablets, which alot of users are implementing for their technicians.

 

Additional changes were made to some other SOP templates:

  1. HPRTSR: Updated the System Charging procedural section based on user feedback.
  2. HPR: Added a Cylinder Charging procedural section for those users that want that option.
  3. LEO: Traditional Permit LEO was simplified and now only has “Existing SOP,” “With Drain Valve,” and “Without Drain Valve” sections. The previous 4 possibilities was confusing to some and this one seems to be easier to understand.

Dealing with non-standard (non-routine) work in your Process Safety program

Occasionally we come across an issue we’ve customarily addressed, but never documented. Put another way: We realize we have a policy – even if an informal one – on how to deal with certain situations, but we’ve never turned that policy into a formal, written one.

It’s incredibly common to have these informal policies in smaller departments, or when a task is rare. You can usually identify them after-the-fact when you are told “That’s just the way we do things here. Everybody knows that.”

When we find these items in our Covered Processes, we should endeavor to document them. Today I’d like to talk about a big one: What do we do when the existing written procedures don’t match with the conditions or situations we are facing in our work. What written guidance are you providing to your Process Operators and Technicians on how to deal with this situation?

Every functioning Operations / Maintenance department has a policy – even if an informal, undocumented one – on how they deal with this issue.  

For years I’ve relied on the text in the SOP Written Plan concerning Temporary Operations:

The ammonia system is not operated in any temporary modes without a written SOP. If a component requires maintenance or replacement, that portion of the system is isolated and removed from service through a written SOP. Other Temporary Operations are handled through the MOC element which will ensure supervisory oversight. Temporary Operation SOPs are often via a written modification of an existing SOP in the form of an addendum.

This worked well, but it was a little bit obscure and (understandably) only thought to apply to SOPs themselves. That needed to change. What we’ve done to our system today, is formalized and documented guidance on how to deal with these non-standard / non-routine situations.

A new policy was placed in the RMP Management System Written Plan…

To ensure integration of this policy, the following text was added to the Operating Procedures (Implementation Policy: Using an SOP – Performing a Procedure, and Implementation Policy: Operating Phases, Temporary Operations) and Mechanical Integrity (Implementation Policy: Mechanical Integrity Procedures or MIPs) element Written Plans: “The Implementation Policy: Non-Standard Work. Addressing Conditions / Situations outside of existing Procedures found in the RMP Written Plan should be used when site/equipment/system Conditions or Situations are found to be different than those anticipated in the exiting written procedures.”

Are you handling non-standard / non-routine work well in your Process Safety program? If you are, and have a better idea, we’re always open to improvements. If you aren’t handling it well, perhaps you can implement the example above? 


For Inside-Baseball type people: This chart was inspired by the API RECOMMENDED PRACTICE 2201 Safe Hot Tapping Practices in the Petroleum and Petrochemical Industries, Chapter 4, Section 4.3.1, Figure 3—Example Decision Process for Authorizing Hot Tapping. Other than genericizing that flowchart to cover all types of work, I also made two large changes:

  • Routed the post “change conditions” step back to the start so we re-evaluate the existing procedure considering changed conditions/situations rather than short-circuiting back to the Management step.
  • Rewrote the flow/wording so that Condition Changes are preferred over mere procedural changes. The thinking was that we should prefer more engineering-type changes over administrative ones, where possible.

 

Hot Work – NFPA 51B–2019 and Magic Rooms

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?

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.

IIAR 2 2014 Addendum A

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 7-2019 Update

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

Introducing: ANSI/IIAR 7-2019Developing 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.

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