IIAR Bulletin No. 109 - Overview and Tips · Ammonia Refrigeration (IIAR) ¾IIAR is an organization that serves those who use industrial refrigeration technology through the promotion

Risk Management Professionals

Risk Managem ent ProfessionalsRMMMP


IIAR Bulletin 109 Overview and Tips

Colin Scholtz, PEGeorge Manuhu

Risk Management Professionals949/282-0123

www.RMPCorp.com






Key TopicsBackgroundRegulatory Overview– CalARP/PSM/RMP– IIAR

B-109 Safety Inspections– Inspection Time Management Tips & Inspection

Frequency– Inspection Checklists– Common Equipment Deficiencies

Question and Answer Period




• Key Services– Process Safety & Risk Management

Engineering– Process Hazard Analysis (PHA)

• What-If? Studies• Hazard & Operability (HAZOP)

Studies• Layer of Protection Analysis

(LOPA)• Safety Integrity Level (SIL)

Assessment• SIL Verification

– Process Safety Management (PSM)– Risk Management Program (RMP)– California Accidental Release

Prevention (CalARP) Program– Safety & Environmental Management

System (SEMS)– Safety Case– Emergency Response Plan

Development & Emergency Preparedness Training (NIMS-Compatible)

– Risk-Graph and Bow-tie Analysis– QRA Services – FTA & ETA

• Background– Services to the Process

Industries, Utilities, & Government Since 1995

– International Work with Focus in US

• Qualifications– Extensive Experience in Key

Service Areas– Specialists in Risk-Based

Applications – Team Members have Performed Risk-Based Applications for Two Decades

– Proficient at Integrating our Engineering, Safety, Security, and Emergency Response Backgrounds to Address a Wide Variety of Applications

• Locations– Headquarters: Orange County, CA– Houston ♦ Walnut Creek ♦ Austin





August 31, 2013 Ammonia leak at a Shanghai cold storage facility resulting in 15 deaths and 26 injuries http://www.reuters.com/article/2013/08/31/us-china-accident-ammonia-idUSBRE97U04420130831

September 11, 2013 Ammonia leak at U.S. wine company resulted in one death https://www.osha.gov/pls/imis/accidentsearch.accident_detail?id=201496809)

Recent Incidents




Safety is no Accident!

Image from https://www.osha.gov/SLTC/etools/ammonia_refrigeration/emergency/




REGULATORY OVERVIEW




Regulatory ProgramsFor California facilities, any facility having a hazardous substance over the California Accidental Release Prevention (CalARP) threshold quantities must submit to the Administering Agency and implement an Risk Management Program

Any facility having a hazardous substance over the Environmental Protection Agencies (EPA) Risk Management Plan (RMP) threshold quantities must submit to the EPA and implement an Risk Management Program

In addition, any facility having a hazardous substance over the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) threshold quantities must implement a Process Safety Management Program




Regulatory Purpose

Document that personnel are safely operating and maintaining a process that utilizes a highly hazardous materialEnsure management are dedicating minimum resources needed to prevent accidental releases– Training– Equipment and Maintenance– Personnel




What the Regulation SaysPSM Says - 29 CFR 1910.119 (equivalent RMP & Cal ARP regulations, 40 CFR §68.73 & 19 CCR § 2760.5)

(j)(4) Inspection and testing.(j)(4)(i) Inspections and tests shall be performed on process equipment.(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.(j)(4)(iv) The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.(j)(5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.




International Institute of Ammonia Refrigeration (IIAR)IIAR is an organization that serves those who use industrial refrigeration technology through the promotion of the safe use of ammonia and other natural refrigerantsEstablished standards and best practices that represent a minimum safety criteria for the ammonia refrigeration industry




What are the IIAR Bulletins?

The International Institute of Ammonia Refrigeration (IIAR) issues their Bulletins as informative documents written as best practice guidelines where no other standard or guidance exists. A partial list of bulletins include:

B-107 Suggested Safety & Operating Procedures for Ammonia Plant Tie-insB-108 Water Contamination in Ammonia Refrigeration SystemsB-109 Minimum Safety Criteria for a Safe Ammonia Refrigeration SystemB-110 Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigeration SystemsB-111 Ammonia Machinery Room Ventilation B-112 Ammonia Machinery Room Design




B-109 SAFETY INSPECTIONS




Bulletin 109 (B-109) Overview

The Bulletin 109 (B-109) provides guidance on minimum safety criteria for a safe ammonia refrigeration system

These criteria are intended to be applied during annual and five-year safety inspections and audits, which are referred to as B-109 Audits




Three Key Types of Bulletin 109 Inspections

Annually – Visual inspections done by refrigeration staff

Every 5th Year – Inspection of the system by someone knowledgeable of refrigeration Good Engineering Practices

Non-Destructive Testing – There is no set frequency for this form of inspection but it is expected that some level of this will be done in conjunction with visual inspections




Inspections are not PM’sTo ensure that refrigeration equipment is operated in a safe manner and that ongoing maintenance of the equipment is done in accordance with manufacturer’s guidelines and industry best practices

Annual Visual Inspections are a separate maintenance activity The purpose of this activity is take a thorough look at each component to see if there is anything that needs to be addressed that wasn’t covered during the PM’s




Annual InspectionInspections should be conducted annually as part of a facilities PMEach facility should have an appointed representative responsible for the compliance with all refrigeration safety requirementsSmaller facilities could pick a week and get it done all at onceLarge facilities could schedule inspections to occur on an ongoing basisAll equipment and safety systems should be inspected separate from the regularly-scheduled PM’s at least once per calendar year




5th Year Inspection

A more thorough inspection of an ammonia refrigeration system should be conducted by a competent ammonia refrigeration system engineer or other authority every five years

The facility could assign someone familiar with the process to work with the inspector to ensure that nothing is missed

The facility could require a review of inspection findings and recommendations to insure accuracy and completeness

The facility could require the inspector deliver the report at a formal review meeting




Non-Destructive Testing

Non-Destructive Testing is typically done as a follow-up to visual inspection concerns

Should be a regular part of your PMTry to avoid any type of inspection that puts a hole in your insulationObservation of equipment should include visual and auditory clues Count vibration analysis, oil analysis and ammonia quality testing as part of your ongoing NDT program




B-109 Safety Inspections

CompressorsEvaporative condensersHeat exchangersPressure vesselsAir-cooling evaporatorsRefrigerant pumps

Piping systemsVentilation systemsPressure-relief devicesGeneral system safety requirements

The IIAR establishes guidelines and checklists for inspecting the following systems:




B-109 SAFETY INSPECTION TIPS




Managing Your Time

It is critical that the inspection be conducted in a manner that optimizes the time spent doing the inspection

Page 1 – General Equipment InformationPage 2 – Inspection Checklist

Page 1 should be part of your Process Safety Information documentation

Filled out when the equipment was originally installed.Only updated when there is an MOC that effects that componentSave time, don’t fill it out annually




B-109 Checklist




How Many Inspections

Sometimes, one component will require multiple B-109 inspections

Compressors SkidsCompressorPressure VesselHeat Exchanger

This needs to be kept in mind when developing your Annual Visual Inspection Program

To save time and effort, all of the relevant inspections should be done at one time




Keep in Mind

Ammonia is not corrosive; so typically any corrosion will be on the outside of the systemDamage mechanisms include: failed insulation/vapor barrier, rust, and thermal cycling Corrosion and wall thickness are a major concern because we do not want the ammonia pressure to cause a rupture




Water Contamination Water contamination within the ammonia refrigeration system can potentially result in:

Changes in pump operationChanges to piping pressure dropReduction in evaporator performance Lower compressor capacity & increased power consumptionChemical changes in compressor oil Corrosion of process equipment and piping




Ammonia Quality Analysis

Anhydrous Ammonia is meant to have very little water in it, with a minimum purity of 99.95%

Ammonia has a high affinity for water, when water finds its way into your system it will wreak havoc

Ammonia samples should be pulled from all recirculators in a system for analysis




Oil Analysis

Are you doing it?

Where are you pulling your samples from?

Just pulling compressor samples is not adequate

Samples should be pulled from all oil draining points, especially from the coldest parts of the system




What These Samples Will Tell You

The oil that has made it from the compressor to an oil draining point has passed through a lot of pipe to get there

On its journey, it has done a few things:

Coated the inside of the piping, thus further protecting it from corrosionPicked up any debris that it came in contact with

In these samples, you are looking for rust, water and metallic flakes




Ice

Ice poses several unique hazards to the an ammonia refrigeration system

Excessive weight can cause damage Ice where it is not expected is bad Ice that goes through Freeze-Thaw cycles, should be dealt with first. Corrosion may occur at any locations that experience cycles




Signs of Potential Corrosion

Tears or breaks in the vapor barrierMicrobial growth Rust/PittingDiscoloration of insulation (due to moisture or condensation)Foreign substances in your oil samples (water, rust, metal flakes)




B-109 INSPECTION DEFICIENCIES




General SafetyTesting of the safety systems should be done when it will not affect operationsAre main shut off valves prominently identified and accessible? Are main shutoff valves accessible from outside of the machinery room? Appropriate equipment/piping markers should be in place to describe the unit, direction of flow, physical state, pressure, etc... (guidance is give in IIAR B-114)




General SafetyThe following questions, a), b) and c), should be filled out separately for every vessel

a) Gauges and valves installed at all vessel, equipment, and controls?b) Are all gauges and others sensors in good working condition? c) Are all accumulators and intercoolers equipped with high level float switches which sound a high liquid alarm level ?-Do they shut down the compressors when high liquid level is detected?




Piping

Piping inspections are probably the most challenging to do The challenges are:

How to be thoroughHow to breakdown the areas to be inspectedHow to properly document the inspectionsHow to document where deficiencies are

Each facility must come up with a plan




Piping

Things to look for: Corrosion Issues (algae, rust, thermal cycling, etc...) Ensure that pipes are adequately braced to prevent unwanted movementLook for corrosion where insulation has been removed to perform ultra sonic testing




Vessels

When it comes to corrosion, piping and vessels have a lot of the same issues to look for

Safety relief valves for vessels should be set to relieve below the vessel maximum allowable pressureSwitches and indicators in a usable condition so that required components can be seen




Condensers

Dirt/Algae buildup are potential sources of corrosion issues.Ensure that there is adequate support/bracing of system componentsAppropriate information is available to support the known design parameters of the equipment




Evaporators

Corrosion Issues Loose/missing nuts for fan guardsMissing fan guardsLoose/missing nuts for supporting structures (i.e. seismic bracing, etc.)

.




Compressors

Compressors “should” be safe from water corrosion Having the appropriate suction and oil pressure gauges Listen to them (while wearing hearing protection of course). If they are making a sound that does not seem to be normal there could be an issue




Heat Exchangers

Verify that the system is operating within its operating limitsEnsure that the safety relief valves are properly set Be aware of ice and investigate the possibility of ice damage

.




Ventilation

Ensure that the ventilation fans are sufficient to adequately ventilate the room in the event of an emergency situationInstall a sign on each compressor room warning a possible entrant that the room contains ammoniaEnsure that emergency ventilation is controlled by an ammonia detector or means are achieved to confirm that the emergency ventilation system runs as required




Relief ValvesThe Relief Valve sheet is a double check for all of the SRV questions on the Vessel and Heat Exchanger sheets

1. Is the right valve on the componenta) Operating pressure below the

components MAWPb) Proper discharge flow rate (verify

with calculations, PSI)2. Is its manufacturers seal wire still

attached3. Is the replacement tag in place or is

there another means of ensuring that the replacement date is known

4. Are all of the SRV’s less than 5 years old

5. Is the SRV piped to safely dischargea) 15’ from the nearest standing areab) 20’ from any makeup air source




Pumps

Ensure that the pump is anchored securely in placeEnsure that the pump is free of excessive vibrationsEnsure that the pump suction and discharge gauges function properly




Deficiencies

Do not neglect the deficiencies

You do the inspection to find things that need to be fixed. Don’t fill out the sheets and identify issues and not develop an action plan to resolve them

Resolve deficiencies in a “timely manner” (less than a year)

Document deficiencies on a log sheet and document steps to resolution and a timeline

Identified and unresolved deficiencies set you up for possible regulatory fines




Recap

• Safety is not a event but an ongoing process and should be a living part of your operations

• Be aware of the signs of corrosion• The paper work is part of the process • Your five year inspections should be done by

someone that you trust • Review your findings to make sure that they

accurately represent your facility, and are something that you can live with




Questions?

Colin Scholtz, [email protected]

George [email protected]

(877)532-0806



Documents

IIAR Bulletin No. 109 - Overview and Tips · Ammonia Refrigeration (IIAR) ¾IIAR is an organization that serves those who use industrial refrigeration technology through the promotion