understanding recognized and generally accepted good
TRANSCRIPT
UnderstandingRecognizedandGenerallyAcceptedGoodEngineeringPractices(RAGAGEP)fortheAmmoniaIndustry
Daniel DettmersIndustrial Refrigeration ConsortiumUniversity of Wisconsin‐Madison
Overview…• Explain IIAR Standard 9: Standard for Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for Existing Closed‐Circuit Ammonia Refrigeration Systems• Not…I’m not that smart, people
• Examine the RAGAGEP Landscape• Codes – alphabet soup: IMC, UMC, CMC• International Institute of Ammonia Refrigeration (IIAR) Standards • American Society of Mechanical Engineers (ASME) Code• American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE) Standard
• Common gaps• Adherence
Whattheheckis“RAGAGEP”?• An acronym derived from requirements in the process safety
information portion of PSM where it states all equipment in PSM-covered process must comply with:
Recognized And Generally Accepted
Good Engineering Practices
• For PSM, RAGAGEP is required both in PSI & MI
RAGAGEPlandscape• Regulations mandatory requirements & issued by Federal, State or local governments
• Codes establishes minimum requirements• Standards documents consensus design and/or operating practices
• Guidelines documents recommended or best practices• Corporate Engineering Standards• Data Sheets or White Papers
Codes&standardsrelevanttoammoniarefrigerationsystems
• Codes• California Mechanical Code (CMC)• Uniform Mechanical Code (UMC)• International Mechanical Code (IMC)
• IIAR• IIAR 1, IIAR 2, IIAR 3, IIAR 4,IIAR 5, IIAR 7, IIAR 8
• ASME• B&PV Code (Pressure vessels)• B31.5 (Refrigeration Piping)
• ASHRAE• Standard 15, Standard 34
• Other State & Local Codes
PSMandRAGAGEPProcess Safety Information – 1910.119(d)(3)
• (ii): Employers must document that all equipment in PSM‐covered processes complies with RAGAGEP;
• (iii): Where the codes, standards, or practices used in the design and construction of existing equipment are no longer in general use, the employer must determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner
This requirement also appears in RMP – Program 3 facilities §68.65(d)(2) & (3).
PSMandRAGAGEPMechanical Integrity – 1910.119(j)(4)
• (ii): Inspections and tests are performed on process equipment subject to the standard's mechanical integrity requirements in accordance with RAGAGEP; and
• (iii): Inspection and test frequency follows manufacturer's recommendations and good engineering practice, and more frequently if indicated by operating experience.
This requirement also appears in RMP – Program 3 facilities §68.73(d)(2) & (3).
“RAGAGEP”hasbeenconfusing• End‐users and regulators have not agreed what constitutes RAGAGEP• What RAGAGEP applies to my ammonia refrigeration system?
• What do I need to show compliance? Especially on a system that has had phased growth through many years.
• Fed OSHA responded by developing guidance through preparation of a “RAGAGEP Memo”
• Expect other regulators to refer to the contents of the Fed OSHA memo
OSHARAGAGEPMemo• Issued to Regional Administrators on May 11, 2016• Intended to provide clarification and direction on RAGAGEP (rescinds prior memo issued 6/5/15)
• Provided examples of RAGAGEP• Widely adopted codes (NFPA 70)• Consensus standards and recommended practice documents (ASME B31.5, IIAR 2)
• Non‐consensus documents (mfgr recommendations)• Internal standards (as appropriate)
OSHARAGAGEPMemoprovidesclarificationon“Shall”vs.“Should”“Shall”, “shall not”, “must”, “must not”, …
• Represents a mandatory minimum requirement• If an employer deviates, OSHA assumes a violation and employer will have an opportunity to explain the deviation from RAGAGEP
“Should”, “should not”, “can”, “can not”, …• Denotes a recommendation that reflects an acceptable and preferred practice
• If an employer deviates, OSHA will not presume a violation but CSHO will evaluate approach to see if it reflects RAGAGEP
(ASME B31.5‐2016)
(IIAR Bulletin 110)
OSHARAGAGEPMemoclarificationon“informative”vs.“normative”Appendices or annexes that are normativemay contain “shall” and “should”
• Employers are expected to meet the shall provisionsAppendices or annexes that are informative
• Employers should read and consider these sections, but OSHA does not expect employers to consult all of the sources that are cited in an informative section or appendix
IIAR Standard 5Appendix A: (Normative) Pressures Appendix B: (Normative) Machinery Rooms and Auxiliary Safety EquipmentAppendix C: (Normative) Leak Test, Evacuation and Dehydration Appendix D: (Informative) Pre‐Charging and Pre‐Start‐Up Check Lists Appendix E: (Informative) Purging Appendix F: (Informative) Considerations and Planning for Closed‐Circuit Ammonia Refrigerating System Tie‐Ins Appendix G: (Informative) Temperature Reduction Procedure for Newly Constructed Cold Storage Areas Appendix H: (Informative) Pressure Chart
InternationalMechanicalCode
•Current version is IMC 2015• State & local jurisdictions may adopt by reference
•Relies heavily on ASHRAE 15 and IIAR 2 for technical content on refrigeration
USMechanicalCodeCoverage
UMC
None
Minimal codes
InternationalMechanicalCode
• Scope:• Regulate the design, installation, maintenance, alterationand inspection of mechanical systems that are permanentlyinstalled and utilized to provide control of environmental conditions and related processes within buildings.
• Intent:• To provide minimum standards to safeguard life or limb, health, property and public welfare by regulating and controlling the design, construction, installation, quality of materials, location, operation and maintenance or use of mechanical systems.
InternationalMechanicalCodeMechanical Systems Covered
– Boilers, water heaters, and pressure vessels
– Refrigeration– Hydronic piping– Fuel oil piping & storage– Solar systems
– Ventilation– Exhaust systems– Duct systems– Combustion air– Chimneys and vents– Appliances and fuel burning equipment
InternationalMechanicalCode
1101.6 GeneralRefrigeration systems shall comply with the requirements of this code and, except as modified by this code, ASHRAE 15. Ammonia‐refrigerating systems shall comply with this code and, except as modified by this code, ASHRAE 15 and IIAR 2.
CaliforniaMechanicalCodeLooksSolelytoIIARforAmmoniaRefrigeration• Chapter 11 covers refrigeration systems
CMC states that ammonia refrigeration systems must comply with IIAR 2, IIAR 3, and IIAR 5
ListofIIARStandardsApplicabletoAmmoniaRefrigeration
• IIAR 1‐2017 ‐ Definitions and Terminology used in IIAR Standards• IIAR 2‐2014 ‐ Standard for Safe Design of Closed‐Circuit Ammonia Refrigeration Systems
• IIAR 3‐2017 – Ammonia Refrigeration Valves• IIAR 4‐2015 – Installation of Ammonia Refrigeration Systems• IIAR 5‐2013 ‐ Start‐up and Commissioning of Closed‐Circuit Ammonia Mechanical Refrigerating Systems
• IIAR 7‐2013 ‐ Developing Operating Procedures for Closed‐Circuit Ammonia Mechanical Refrigerating Systems
• IIAR 8‐2015 ‐ Decommissioning of Closed‐Circuit Ammonia Refrigeration Systems
IIARStandardsUnderDevelopment
• IIAR 6 – Inspection and Maintenance of Closed‐Circuit Ammonia Mechanical Refrigerating Systems
• IIAR 9 – RAGAGEP for Closed‐Circuit Ammonia Mechanical Refrigerating Systems
• IIAR CO2 ‐ Standard for Safe Design of Carbon Dioxide Refrigeration Systems
IIAR2(2014)
Standard for Safe Design of Closed‐Circuit Ammonia Refrigeration Systems
Purpose:Specifies minimum requirements for the safe design of closed‐circuit ammonia refrigeration systems.
Scope:Applies to stationary closed‐circuit refrigeration systems utilizing ammonia as the refrigerant.
IMC, UMC, CMC require ammonia systems to comply with IIAR 2.
IIAR3(2017)
Ammonia Refrigeration Valves
Purpose:to specify performance criteria for valves and strainers used in closed‐circuit ammonia refrigeration systems
This standard is generally aimed at valve manufacturers.
IIAR5(2015)
Start‐up and Commissioning of Closed‐Circuit Ammonia Mechanical Refrigerating Systems
Purpose:Specifies criteria and procedures for start‐up and commissioning of closed‐circuit ammonia mechanical refrigerating systems.
CMC requires ammonia systems to comply with IIAR 5.
ASMEBoiler&PressureVesselCode:SectionVIIIDiv.1(2015)
• Applicable to pressure vessels used for containment of pressure (internal or external)
• Covers materials, design, fabrication, examination, inspection, testing, certification
• Includes requirements for pressure relief protection
IIAR 2 requires vessels to comply with this ASME code.
ASMEB31.5(2016)
• Covers the design and construction of refrigeration piping, heat transfer components and secondary coolant piping
• The requirements of this standard must be met before startup of the system
• Covers all refrigerants, not just ammonia
IIAR 2 requires piping to comply with ASME B31.5
ASHRAE15(2016)
• Specifies safe design, construction, installation, and operation of refrigeration systems
• Establishes safeguards for life, limb, health, and property and prescribes safety requirements
• Applies to all refrigerants, not just ammonia
Oregon code calls for complying with IIAR 2 and ASHRAE 15
RAGAGEP“snowball”example‐ piping
ConsiderthenormativereferencestandardsidentifiedinIIAR2– “snowball”
HighlevelRAGAGEPforNH3 systems
Category Reference Applicability
Design
ASME Section VIII Div. 1 Refrigerant pressure vessels
ASME B31.5 Refrigerant piping and heat transfer components
IIAR 1 Definitions
IIAR 2 Ammonia system design
IIAR 3 Valves
ASCE 7Refrigerant piping and equipment structure & supports
ISEA Z358.1 Eyewash & safety showers
NFPA 70 Electrical
HighlevelRAGAGEPforNH3 systems
Category Reference Applicability
Installation & start‐up
ASME B31.5 Installation, inspection, and pressure testing of piping
IIAR 4 System installation
IIAR 5 Start‐up commissioning
IIAR 7 Operating procedures
IIAR 114* Equipment & pipe labeling
Ongoing maintenance, inspections, and tests
Equipment manufacturer’s recommendations
Equipment‐specific and modified based on plant experience
IIAR 2 Maintenance provisions
IIAR 109* & 110* Maintenance provisions
ISEA Z358.1 Maintenance provisions for eyewash and safety showers
* Guideline document
Beawareofcode&standardtraps!One Example:• Consider the following normative requirements from the International Fire Code & International Mechanical Code
(IFC 2015)
(IFC 2015)
(IMC 2015)
Beawareofcode&standardtraps!(cont.)
• IFC references IMC as a normative requirement for mechanical refrigeration systems
• IFC includes normative requirements for an emergency pressure control system (EPCS) for ammonia refrigeration systems
• IMC references IIAR 2 as a normativerequirement for ammonia refrigerant systems
• IIAR 2 does not have a normativerequirement for EPCS – only an informativeappendix
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CommondeviationsfromRAGAGEPcompliance• No RAGAGEP specified in design and specifications• No owner verification/validation of adherence to RAGAGEP
• Owner does not request or receive required supporting documentation for future regulatory compliance
• Systems or components installed but do not meet current RAGAGEP
WhatiscompliancewithRAGAGEP?
• Is a letter stating that you comply with PSM or RMP sufficient?• Do you think OSHA and EPA would agree?
• So, would a letter stating that you comply with listed RAGAGEP be sufficient?• Wouldn’t any discovered incompliance invalidate the assertion of compliance in the letter?
Howtoshowcompliance?• How do we show compliance with PSM or RMP?
• Create a program (paper)• Implement the program (practice)• Audit the program & implementation (paper + practice)
• Is RAGAGEP compliance similar?• Create a list of RAGAGEP (paper)• Implement the requirements of RAGAGEP during design, installation, startup, and ongoing operation & maintenance (practice)
• Assess against the listed RAGAGEP (paper + practice)
WhentocheckagainstRAGAGEP?
• Design• Yes
• Installation or modification• Yes
• Commissioning (start‐up)• Yes
• Ongoing operations and maintenance• Yes
IRC RAGAGEP Best Practices Workshop
October 24‐25, 2017• Overview of RAGAGEP• Overview of IIAR, ASME, ASHRAE
and other standards• Auditing for Adherence to
RAGAGEP• Commissioning and RAGAGEP
RAGAGEPchecklisttool–Whatisit?
• A tool to assist in assessing compliance with RAGAGEP
• Generates pdf or excel file of items to inspect
• Allows users to select from a database of RAGAGEP “questions” based on specified criteria
• Standard, Project phase, Location, and Equipment
• Can individually pick questions if desired
• Questions “interrogate” compliance with RAGAGEP
• Best suited for design, maintenance, and infrastructure reviews
Questions?
37
AdditionalinformationonRAGAGEP
38
IIAR2– 2014,excerpts
39
IIAR2
Table of Contents
1. Purpose, scope, applicability2. Definitions3. Reference standards4. Location of ammonia refrigeration
machinery 5. General system design requirements6. Machinery rooms7. Refrigeration equipment located in areas
other than machinery rooms
Part 1: General
Part 2: Design and Installation Considerations Affecting Construction
IIAR2– 2014
Table of Contents
8. Compressors 9. Refrigerant pumps10. Condensers11. Evaporators12. Pressure vessels13. Piping14. Packaged systems & equipment15. Overpressure protection devices16. Instrumentation & controls17. Ammonia detection and alarms
Part 3: Equipment
IIAR2– 2014Part 4 AppendicesAppendix A ‐ Explanatory materialAppendix B ‐ Ammonia characteristics and propertiesAppendix C‐Methods for calculating relief capacity for HX internal loadsAppendix D ‐ Duplicate Nameplates on Pressure VesselsAppendix E ‐Method for calculating capacity for compressor PRVAppendix F ‐ Pipe Hanger Spacing, Hanger Rod Sizing, and LoadingAppendix G ‐ Hydrostatic Pressure ReliefAppendix H ‐ Stress Corrosion CrackingAppendix I ‐ Emergency Pressure Control SystemsAppendix J ‐Machinery Room Signs Appendix K ‐ Alternative ventilation calculation methodsAppendix L ‐ Pipe, fittings, flanges, and boltingAppendix M ‐ Operational containmentAppendix N ‐ Reference and sources of references
‐ Normative requirement ‐ Informative
IIAR3– 2017Ammonia Refrigeration Valves
Scope:• Applies to shut‐off valves, control valves, check valves, ball valves, gauge valves, and strainers designed and manufactured for use in closed circuit mechanical refrigerating systems utilizing ammonia as the refrigerant.
• Includes criteria for materials of construction, pressure‐containing envelope, seat leakage, quality assurance, marking, and production testing applicable to finished products as delivered by the original manufacturer.
• Applies to actuator elements that form a part of the pressure‐containing envelope on valves.
• Applies to valves incorporating a mechanical actuating float or other mechanism exposed to the refrigerant.
• Compliance with this standard shall not be required for products manufactured prior to the publication date of this standard.
IIAR4‐ 2015Installation of Closed‐Circuit Ammonia
Refrigeration SystemsPurpose:Specifies minimum requirements for the safe installation of closed‐circuit ammonia mechanical refrigeration systems and overpressure device piping when used in conjunction with a closed‐circuit ammonia refrigeration system.
Scope:Standard for the installation of closed‐circuit ammonia mechanical refrigeration systems.Excludes: absorption systems, functionally‐equivalent replacement parts, equipment installed prior to effective date of standard.
IIAR4– 2015
Table of Contents
1. Purpose2. Scope3. Definitions4. Normative References5. General Requirements6. Compressor Installation7. Condenser Installation
8. Evaporator Installation9. Pressure Vessel Installation10. Pipe and Valve Installation11. Components and Controls
Installation12. Insulation13. Testing of Installation14. (Informative) References
and Sources of References
IIAR5‐ 2013Start‐up and Commissioning of Closed‐Circuit Ammonia Mechanical Refrigerating Systems
Purpose:Specifies criteria and procedures for start‐up and commissioning of closed‐circuit ammonia mechanical refrigerating systems.
Scope:Provides minimum requirements for safe start‐up and commissioning of closed‐circuit mechanical refrigerating systems and equipment.Unless otherwise noted, it is the responsibility of the owner or the owner’s representative to obtain or otherwise arrange for the completion of all requirements in this Standard.
IIAR5– 2013(cont.)Start‐up and Commissioning of Closed‐Circuit Ammonia
Mechanical Refrigerating Systems
Scope:2.1 This Standard provides basic minimum requirements for the safe start‐up and commissioning of completed closed‐circuit mechanical refrigerating systems utilizing ammonia as the refrigerant and to additions and modificationsmade to such systems…2.2 Start‐up and commissioning shall be performed, at a minimum, in accordance with equipment manufacturer’s instruction manuals. This standard focuses on practices that promote safety.2.3 This standard refers to those parts of a refrigerating system that are in contact with ammonia.2.4 Unless otherwise noted, it is the responsibility of the owner or the owner’s representative to obtain or otherwise arrange for the completion of all requirements in this Standard. It is permissible for the owner or the owner’s representative to delegate this responsibility by contract.
IIAR5– 2013
Contents6. Records7. Start‐Up of New Installations8. Start‐Up of Additions and
Modifications to Existing Installations
9. Sources of References
1. Purpose2. Scope3. Definitions4. References5. General Ammonia Information
IIAR5– 2013ContentsAppendix A ‐ PressuresAppendix B ‐Machinery Rooms and Auxiliary Safety EquipmentAppendix C ‐ Pressure Test, Evacuation and DehydrationAppendix D ‐ Pre‐Charging and Pre‐Start‐Up Check ListsAppendix E ‐ PurgingAppendix F ‐ Considerations and Planning for Closed‐Circuit Ammonia
Refrigerating System Tie‐InsAppendix G ‐ Temperature Reduction Procedure for Newly Constructed
Cold Storage AreasAppendix H ‐ Pressure chart
‐ Normative requirement ‐ Informative
IIAR5– 2013,excerptsDesign Records:
6.1.1 The system shall have been designed by, and installed under the supervision of, persons who by reason of knowledge, training and experience are competent for the tasks. Such persons typically include:
a. experienced refrigeration contractors, possibly in combination with a code authority, authorized inspection agency or property insurance underwriter
b. in‐house design/engineering staff of the owner or the owner’s designated representative
c. consulting engineers, acting on behalf of the owner or the owner’s designated representative
d. refrigeration equipment suppliers.
IIAR5– 2013,excerpts(cont.)Design Records:
6.2.1 A system component inventory list shall be prepared. The list shall include the major components of the ammonia refrigerating system, including: compressors, condensers, evaporators, pressure vessels, liquid ammonia pumps, piping, valves and fittings, ammonia machinery room ventilation system, and other control and safety devices.6.2.2 The inventory list shall contain a record of the maximum working pressure(s) and minimum temperatures as applicable.6.3 Records shall be kept of these tests. These tests shall be completed before the refrigeration system is charged with ammonia
IIAR5– 2013,excerptsInitial Status and Safety Provisions:
7.8.1 Before the system is charged with ammonia, it shall be verified• designed and built in accordance with the requirements of the governing edition of IIAR 2
(ref. 4.1.3)
• cleared of all …obstructions that could impede egress in…an emergency
• Emergency lighting…ventilation fans are ready for operation.
• Required first aid and safety equipment is available.
7.8.2 The owner shall ensure that eye wash and deluge shower facilities are available7.8.3 Before system is charged and put into service, it shall be confirmed that the local emergency authorities are aware that ammonia is used or is to be used at that location.
IIAR5‐ 2013Commissioning:
7.15.2 During the commissioning of the system the trained start‐up technician shall involve the persons responsible for the day‐to‐day operation of the system.7.15.3 The system shall be operated to demonstrate correct function…7.15.4 Following the training of the system operators…and there has been a period of continuous and fault free running, the refrigeration system may be handed over...
ASMEB31.5– KeyContents• Chapter 1 – Scope & Definitions• Chapter 2 – Design• Chapter 3 – Materials• Chapter 4 – Dimensional Requirements• Chapter 5 – Fabrication and Assembly• Chapter 6 – Examination, Inspection, and Testing
ASMEB31.5‐ Scope
500.1.1 Code prescribes requirements for the materials, design, fabrication, assembly, erection, test, and inspection of refrigerant, heat transfer components, and secondary coolant piping for temperatures as low as −320°F (−196°C), whether erected on the premises or factory assembled, except as specifically excluded
B31.5– Designconsiderations
• 501.5 – Dynamic Effects• Impact forces (including hydraulic shock and liquid slugging)• Wind (for exposed piping)• Earthquake (seismic forces)• Vibration• Discharge reactions
• 501.6 –Weight Effects• Live loads• Dead loads• Test loads
B31.5Designcriteriaoverview• 502.3 – Allowable Stresses & Other Stress Limits
• Table 502.3.1 establishes allowable stress valves to be used for design calculations but the code does define some modifications
Material Spec Grade Min Temp(F)
Min Tensile(ksi)
Min Yield(ksi)
Allowable Stress (ksi)
Steel pipe ASTM A106 A B 48.0 30.0 13.7
Steel pipe ASTM A106 B B 60.0 35.0 17.1
Steel pipe ASTM A333 1 ‐50 55.0 30.0 15.7
Steel pipe ASTM A333 6 ‐50 60.0 35.0 17.1
Stainless ASTM A312 304 ‐425 75.0 30.0 20.0
Stainless ASTM A312 304L ‐425 70.0 25.0 16.7
Allowable stress to 100F material temperature.
IIARInformativeReferencetoEPCS
(IIAR 2‐ 2014)