BY PETER JORDAN, MBD RISK MANAGEMENT SERVICES, INC.

The Occupational Safety and Health Administration’s Process Safety Management (PSM) standard (29 CFR 1910.119) was issued as a final rule in 1992. The Environmental Protection Agency’s Risk Management Program (RM Program) regulation (40 CFR 68.79) was issued as a final rule in 1994.

Since both these regulations are relatively “mature”, one would think that most of the procedures and practices needed to comply with their requirements are well known and relatively straightforward. But to this day, there are certain requirements which facilities routinely struggle to comply with. One of these is the requirement that employers must document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP.)

There are often two issues which facilities struggle with when attempting to document that their ammonia refrigeration equipment complies with RAGAGEP. First, what “good engineering practices” are they expected to comply with? Should they comply with the good engineering practices which were in place when equipment in the system was initially installed? Or should they comply with current practices under the assumption that they are no longer “grandfathered?”

OSHA and EPA regulators have also struggled with this difficulty. I am aware of PSM and RM Program audits conducted by regulators where they attempted to apply the latest IIAR standards, such as ANSI/IIAR 2-2014, to existing ammonia refrigeration systems which were installed prior to 2014. Worse, I have been involved in audits where the regulators tried to apply good engineering practices applicable to other industries – such as American Petroleum Institute (API) standards — to ammonia refrigeration systems. Needless to say, those audits have not gone well.

In 2014, IIAR and OSHA representatives met to discuss issues related to RAGAGEP. One of the key items on the agenda was how existing facilities would be affected by updated codes and standards. During the meeting, it was agreed that existing facilities wouldn’t be expected to immediately implement the new codes and standards.

The OSHA representatives did indicate, however, that they would expect an evaluation to determine which new codes and standards should be implemented, especially when there are new safety hazards or controls that have been identified by the industry. The OSHA representatives also indicated they would look favorably if a new standard was developed which defined the minimum requirements that all facilities should comply with.

In 2015, the IIAR Standards Committee established a subcommittee led by Eric Johnston to develop a standard which provides the minimum RAGAGEP applicable to existing closed-circuit ammonia refrigeration systems. This standard, which is designated by BSR/IIAR 9-201X (IIAR 9), is currently being finalized as part of the ANSI public review process. Once finalized, it is anticipated that the proposed standard will help companies ascertain whether their existing systems should be updated to reflect new requirements from updated codes and standards, thus helping determine what equipment should or should not be “grandfathered” for these systems.

Twice in 2018, I have been asked by clients to conduct an evaluation of existing ammonia refrigeration systems to determine if these systems comply with industry codes and standards. One of these clients is located in South America and the other client is located in the United States. My proposal to each facility included the following scope of work:

An evaluation of the ammonia refrigeration system will be conducted to determine if the equipment is designed, constructed, and operated in accordance with IIAR standards. The purpose of this evaluation will be to document any gaps between the operation of the ammonia refrigeration system and the IIAR standards. The primary document which would be used during this evaluation is BSR/IIAR 9-201x, IIAR’s draft Standard for Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for Existing Closed-Circuit Ammonia Refrigeration Systems.

We chose to use the draft version of IIAR 9 for the evaluation conducted in South America because (1) the equipment was installed in stages and we did not wish to use multiple versions of ANSI/IIAR 2 to conduct the evaluation and (2) we were not able to identify any local building, fire, mechanical or electrical codes which would take precedence over IIAR 9.

We chose to use the draft version of IIAR 9 for the evaluation conducted in the United States based on discussions with the local regulatory authority. Fortunately, the local regulatory authority was familiar with IIAR 9 and stated that they would be comfortable with the results if we used IIAR 9.

In both cases, we acknowledged that we were taking a risk because IIAR 9 only exists in draft form; changes will be made before IIAR 9 is finalized. For the facility in South America, I will most likely make a return visit during which we will review the progress made in addressing the gaps identified during the evaluation and address differences between the draft version of IIAR 9 and the finalized version. For the facility in the United States, the evaluation would have to be updated at a later date once IIAR 9 is finalized, most likely when the next Process Hazard Analysis study is conducted at the facility.

The method used to conduct the evaluation was relatively straightforward. First, I prepared a Microsoft Word® table with four columns: (1) BSR/IIAR 9-201X Requirements, (2) Existing System, (3) Gaps Identified, and (4) Method Used to Address Gaps.

8.3.12.2, Part 1: A clearly identified control switch for emergency ventilation with a tamper-resistant cover shall be located outside the machinery room and adjacent to the designated principal machinery room door.

There is no “On/Auto” control switch for the emergency ventilation system located at the main entrance to the main machinery room.

An “On/Auto” control switch needs to be installed at the main entrance to the machinery room.

Install a clearly identified “On/Auto” control switch for the emergency ventilation system with a tamper-resistant cover outside the main (west) entrance to the main machinery room. The control switch must not have an “Off” position.

The next step of the evaluation was to obtain documents related to the facility’s ammonia refrigeration system. I requested the following documents for each facility. Where documentation was unavailable, we either prepared the documentation on-site or made a recommendation during the evaluation to develop the documentation at a later date.

• Block flow diagram(s);
• Piping and instrumentation diagrams (P&IDs);
• Inventory calculations used to estimate the amount of ammonia in the refrigeration system;
• A list of pressure relief valves, along with sizing calculations related to pressure relief valves and pressure relief headers;
• A description of the ventilation system in the machinery room, along with sizing calculations for the ventilation equipment;
• Load calculations for the ammonia refrigeration equipment; • Written operating procedures describing the steps used to start and shut down the ammonia refrigeration equipment;
• A description of the ammonia detectors, including the location of the detectors, the set point for the detectors, and the actions taken if the ammonia concentration exceeds the setpoints;
• A description of any emergency stop button (E-stop), including the location of these buttons and the actions taken if a stop button is pressed;
• Manufacturer’s data sheets and installation manuals for ammonia refrigeration equipment.

The on-site portion of the evaluation involved additional document reviews, equipment inspections and discussions with facility personnel. Approximately two days were spent at each facility conducting the evaluation. In each case, additional time was spent at the facility on other activities. In each case, I prepared an evaluation report which contained the completed evaluation table and a list of recommendations.

The type of recommendations identified during the evaluation were similar to those which would have been identified during a Process Hazard Analysis study. For example, there were recommendations to:

• Upgrade the ammonia detection systems;
• Install and/or modify emergency shutdown systems;
• Upgrade the machinery room ventilation systems;
• Upgrade the pressure relief systems;
• Install additional eyewash/safety showers;
• Upgrade the labeling and signage.

A significant amount of time and effort will be required to finalized IIAR 9. And there may be some within the ammonia refrigeration industry who may not fully appreciate IIAR 9. But my clients and I are happy with the evaluations we conducted using the draft version of IIAR 9. The advantage of conducting the evaluation is that each facility now has a document which can be used to demonstrate compliance with RAGAGEP. If/when these facilities are audited by a regulatory authority, these documents may prove to be invaluable.