IIAR

The 2015 editions of the International codes, including the International Mechanical Code (IMC) and the International Fire Code (IFC), have been completed and will be published later this year. A number of changes to these codes are of interest to IIAR members. However, it’s also important to mention several proposed changes that would have negatively impacted the ammonia refrigeration industry but are not included in the 2015 codes because IIAR successfully opposed them.

APPROVED PROPOSALS

Below are the significant changes affecting ammonia refrigeration that were approved for inclusion in the 2015 IMC and IFC. All of these are considered as positive by IIAR. The changes are shown in “legislative format,” meaning text shown as underlined is being added and text shown with a strike-out overlay is being deleted.

Proposal M184-12 (clarifies 30 air changes per hour as the required ventilation rate for ammonia systems):

1106.3 Ammonia room ventilation.

Ventilation systems in ammonia machinery rooms shall be operated continuously at the emergency ventilation rate specified in determined in accordance with Section 1105.6.3.2.

Exceptions:

1. Machinery rooms equipped with a vapor detector that will automatically start the ventilation system at the emergency ventilation rate specified in determined in accordance with Section 1105.6.3.2, and that will actuate an alarm at a detection level not to exceed 1,000 ppm; or
2. Machinery rooms conforming to the Class 1, Division 2, hazardous location classification requirements of NFPA 70.

Proposal F77-13 (permits tamper-resistant covers, such as plastic cover boxes, in lieu of break-glass style covers for ventilation system and equipment shutdown emergency controls, which is already allowed by IFC Section 606.9.1):

606.9.2 (also IMC 1106.5.2) Ventilation system. A clearly identified switch of the break-glass type or with an approved tamper-resistant cover shall provide on-only control of the machinery room ventilation fans.

Proposal F78-13 (establishes that emergency pressure control systems, EPCS, are only required for refrigeration systems that are permanently installed, as opposed to those that are portable or temporary):

606.10 Emergency pressure control system. Permanently installed refrigeration systems containing more than 6.6 pounds (3 kg) of flammable, toxic or highly toxic refrigerant or ammonia shall be provided with an emergency pressure control system in accordance with Sections 606.10.1 and 606.10.2.

Proposal F79-13 (restructures provisions for termination of overpressure relief piping for clarity and allows use of internal venting of overpressure from one part of a system to another as an alternative to atmospheric discharge options in this section because 606.12 will now only apply to systems that are designed to discharge to atmosphere):

606.12 Discharge and termination of pressure relief devices and purge systems. Pressure relief devices, fusible plugs and purge systems discharging to the atmosphere from for refrigeration systems containing more than 6.6 pounds (3 kg) of flammable, toxic or highly toxic refrigerants or ammonia shall be provided with an approved discharge system as required by comply with Sections 606.12.1 606.12.2, 606.12.2 606.12.3 and 606.12.3 606.12.4.

606.12.1 Fusible plugs and rupture members. Discharge piping and devices connected to the discharge side of a fusible plug or rupture member shall have provisions to prevent plugging the pipe in the event of the fusible plug or rupture member functions.

606.12.1 606.12.2 Flammable refrigerants. Systems containing more than 6.6 pounds (3 kg) of flammable refrigerants having a density equal to or greater than the density of air shall discharge vapor to the atmosphere only through an approved treatment system in accordance with Section 606.12.54 or a flaring system in accordance with Section 606.12.5 606.12.6. Systems containing more than 6.6 pounds (3 kg) of flammable refrigerants having a density less than the density of air shall be permitted to discharge vapor to the atmosphere provided that the point of discharge is located outside of the structure at not less than 15 feet (4572 mm) above the adjoining grade level and not less than 20 feet (6096 mm) from any window, ventilation opening or exit.

606.12.2 606.12.3 Toxic and highly toxic refrigerants. Systems containing more than 6.6 pounds (3 kg) of toxic or highly toxic refrigerants shall discharge vapor to the atmosphere only through an approved treatment system in accordance with Section 606.12.4 606.12.5 or a flaring system in accordance with Section 606.12.5 606.12.6.

606.12.3 606.12.4 Ammonia refrigerant. Systems containing more than 6.6 pounds (3 kg) of ammonia refrigerant shall discharge vapor to the atmosphere through an approved treatment system in accordance with Section 606.12.4 606.12.5, a flaring system in accordance with Section 606.12.5 606.12.6, or through an approved ammonia diffusion system in accordance with Section 606.12.6 606.12.7, or by other approved means.

Exceptions:

1. Ammonia/water absorption systems containing less than 22 pounds (10 kg) of ammonia and for which the ammonia circuit is located entirely outdoors.
2. When the fire code official determines, on review of an engineering analysis prepared in accordance with Section 104.7.2, that a fire, health or environmental hazard would not result from discharging ammonia directly to the atmosphere.

Proposal F80-13 (adopts IIAR 2, IIAR 7 and ASHRAE 15 as a mandatory referenced standard in the IFC):

606.12.1 (new) Standards. Refrigeration systems and the buildings in which such systems are installed shall be in accordance with ASHRAE 15.

606.12.1.1 Ammonia Refrigeration. Refrigeration systems using ammonia refrigerant and the buildings in which such systems are installed shall comply with IIAR-2 for system design and installation and IIAR-7 for operating procedures

Chapter 80 (mandatory reference standards):

ASHRAE 15-2013

IIAR-2-2014

IIAR-7-2013

Proposal F81-13 (places “discharge to atmosphere” on a par with other permissible methods of emergency pressure relief venting, rather than having water tanks or other treatment systems serve as the default requirement for relief vent discharge, with atmospheric release shown as a subordinate second exception):

606.12.3 Ammonia refrigerant. Systems containing more than 6.6 pounds (3 kg) of ammonia refrigerant shall discharge vapor to the atmosphere in accordance with one of the following methods: through an approved treatment system in accordance with Section 606.12.4, a flaring system in accordance with Section 606.12.5, or through an approved ammonia diffusion system in accordance with Section 606.12.6, or by other approved means.

Exceptions:

1.  Ammonia/water absorption systems containing less than 22 pounds (10 kg) of ammonia and for which the ammonia circuit is located entirely outdoors.

   Directly to atmosphere when the fire code official determines, on review of an engineering analysis prepared in accordance with Section 104.7.2, that a fire, health or environmental hazard would not result from atmospheric discharging of ammonia directly to the atmosphere

2. Through an approved treatment system in accordance with Section 606.12.4
3. Through a flaring system in accordance with Section 606.12.5 4.
4. Through an approved ammonia diffusion system in accordance with Section 606.12.6 5.
5. By other approved means.

REJECTED PROPOSALS

IIAR’s advocacy work in the model code arena involves more than just submitting and supporting proposals that would benefit the ammonia refrigeration industry. Opposing proposals that are unnecessary or that unfairly burden ammonia refrigeration is an equally important part of what we do. With this in mind, the following is a summary of proposals to the 2015 International codes that were opposed by IIAR and were rejected:

Proposal ADM34-13 (disapproved) – This was a proposal submitted by a California fire service group to add a special fire code permit requirement, applicable every time a refrigeration system regulated by the fire code, which includes all ammonia systems, is installed or modified. Although the proposal was well intentioned, with the stated purpose of wanting the special permit to give fire officials a means to ensure that their regulations are being enforced, IIAR opposed the change because mechanical code permits should already provide for this through internal coordination among fire and mechanical code enforcing agencies. If the mechanical code enforcing agency isn’t cooperating with the fire code enforcing agency to ensure that all applicable code requirements are being enforced, this indicates an administrative failure in the jurisdiction that shouldn’t be solved by requiring the installer or service company to get duplicate permits. Based on IIAR’s opposition, the proposal was disapproved at ICC’s final action hearing.

Proposal F51-13 (disapproved) – This proposal was submitted by a California fire service group to add a requirement for constructions documents (plans, calculations, etc.) to be submitted to the fire code official for review and approval prior to installation or modification of any building system regulated by IFC Chapter 6, including all ammonia refrigeration systems. Like ADM34, this proposal may have been well intentioned, but it too would have added an unnecessary administrative burden on installers and service companies to submit duplicate plans and await approval of the fire code official prior to commencing work. Using a code requirement as a means of addressing a jurisdiction’s internal failure to coordinate enforcement is not appropriate from IIAR’s perspective, and based on IIAR’s opposition, the proposal was disapproved by ICC’s Fire Code Development Committee.

Proposal F76-13 (disapproved) – This proposal was similar to others in recent years that added a requirement to secure refrigerant access ports that are located outdoors with locking, tamper-resistant caps or an equivalent security method. The intent of these requirements is to inhibit refrigerant “huffing,” by individuals seeking intoxication. This has never been an issue with ammonia systems for obvious reasons, but IIAR didn’t previously oppose the requirement because ammonia refrigeration system access ports are typically secured to be only be accessible to authorized personnel. Nevertheless, IIAR opposed this particular change because it added a requirement for alarms to be provided on hatches and doors leading to controlled areas with refrigerant access ports. While this might have been appropriate for some situations, it is clearly unnecessary at facilities with ammonia refrigeration systems. Based on opposition by IIAR and Target Corporation, the proposal was disapproved at ICC’s final action hearing.

Proposal F179-13 (disapproved) – This proposal by the alarm industry would have created a new category of alarm systems in the International Fire Code called “emergency alarms.” The intent was to gather all alarm requirements, other than those that are fire or security related, from various sections of the IFC and govern this equipment with standardized administrative and technical requirements. IIAR had several concerns with this proposal. Most notable was a requirement mandating that emergency alarm control units be listed by a testing laboratory or approved by the fire code official, who might insist on a UL or similar listing as a condition of approval. Currently, ammonia leak detection systems, which may be integrated with a programmable logic controller, are not listed, and the proposal did not specify a standard on which such listings would be based. Currently, no specific standard exists for this purpose.

IIAR’s continued success in advocating the ammonia refrigeration industry’s interest is largely attributed to the many dedicated member volunteers who serve on the IIAR Code Committee and IIAR Standards Committee and assist in identifying and formulating positions on code proposals of interest to the ammonia refrigeration industry. IIAR members are indebted to these individuals for the work they do on the industry’s behalf.

Look for a report on the outcome of many changes of interest in the Uniform Mechanical Code and the NFPA Fire Code 2015 editions in an upcoming Condenser column. Final hearings for these documents are still several months away, but preliminary results indicate more good news is headed IIAR’s way.