Understanding Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for the Ammonia Industry

Transcription

1 Understanding Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for the Ammonia Industry Daniel Dettmers Industrial Refrigeration Consortium University of Wisconsin Madison

2 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

3 What the heck is 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

4 RAGAGEP landscape 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

5 Codes & standards relevant to ammonia refrigeration systems 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

6 PSM and RAGAGEP Process Safety Information (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).

7 PSM and RAGAGEP Mechanical Integrity (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).

8 RAGAGEP has been confusing 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

9 OSHA RAGAGEP Memo 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)

10 OSHA RAGAGEP Memo provides clarification on 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 B ) (IIAR Bulletin 110)

11 OSHA RAGAGEP Memo clarification on informative vs. normative Appendices or annexes that are normative may contain shall and should Employers are expected to meet the shall provisions Appendices 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 5 Appendix A: (Normative) Pressures Appendix B: (Normative) Machinery Rooms and Auxiliary Safety Equipment Appendix 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

12 International Mechanical Code 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

13 US Mechanical Code Coverage None UMC Minimal codes

14 International Mechanical Code Scope: Regulate the design, installation, maintenance, alteration and inspection of mechanical systems that are permanently installed 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.

15 International Mechanical Code Mechanical Systems Covered Ventilation Exhaust systems Duct systems Combustion air Chimneys and vents Appliances and fuel burning equipment Boilers, water heaters, and pressure vessels Refrigeration Hydronic piping Fuel oil piping & storage Solar systems

16 International Mechanical Code General Refrigeration 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.

17 California Mechanical Code Looks Solely to IIAR for Ammonia Refrigeration Chapter 11 covers refrigeration systems CMC states that ammonia refrigeration systems must comply with IIAR 2, IIAR 3, and IIAR 5

18 List of IIAR Standards Applicable to Ammonia Refrigeration IIAR Definitions and Terminology used in IIAR Standards IIAR Standard for Safe Design of Closed Circuit Ammonia Refrigeration Systems IIAR Ammonia Refrigeration Valves IIAR Installation of Ammonia Refrigeration Systems IIAR Start up and Commissioning of Closed Circuit Ammonia Mechanical Refrigerating Systems IIAR Developing Operating Procedures for Closed Circuit Ammonia Mechanical Refrigerating Systems IIAR Decommissioning of Closed Circuit Ammonia Refrigeration Systems

19 IIAR Standards Under Development IIAR 6 Inspection and Maintenance of Closed Circuit Ammonia Mechanical Refrigerating Systems IIAR 9 RAGAGEP for Closed Circuit Ammonia Mechanical Refrigerating Systems IIAR CO 2 Standard for Safe Design of Carbon Dioxide Refrigeration Systems

20 IIAR 2 (2014) Purpose: IMC, UMC, CMC require ammonia systems to comply with IIAR 2. Standard for Safe Design of Closed Circuit Ammonia Refrigeration Systems Specifies minimum requirements for the safe design of closedcircuit ammonia refrigeration systems. Scope: Applies to stationary closed circuit refrigeration systems utilizing ammonia as the refrigerant.

21 IIAR 3 (2017) This standard is generally aimed at valve manufacturers. Ammonia Refrigeration Valves Purpose: to specify performance criteria for valves and strainers used in closed circuit ammonia refrigeration systems

22 IIAR 5 (2015) CMC requires ammonia systems to comply with IIAR 5. 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.

23 ASME Boiler & Pressure Vessel Code: Section VIII Div. 1 (2015) IIAR 2 requires vessels to comply with this ASME code. 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

24 ASME B31.5 (2016) IIAR 2 requires piping to comply with ASME B31.5 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

25 ASHRAE 15 (2016) Oregon code calls for complying with IIAR 2 and ASHRAE 15 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

26 RAGAGEP snowball example piping

27 Consider the normative reference standards identified in IIAR 2 snowball

28 High level RAGAGEP for NH 3 systems Design Category Reference Applicability ASME Section VIII Div. 1 ASME B31.5 IIAR 1 IIAR 2 IIAR 3 ASCE 7 ISEA Z358.1 NFPA 70 Refrigerant pressure vessels Refrigerant piping and heat transfer components Definitions Ammonia system design Valves Refrigerant piping and equipment structure & supports Eyewash & safety showers Electrical

29 High level RAGAGEP for NH 3 systems Category Reference Applicability Installation & start up Ongoing maintenance, inspections, and tests * Guideline document ASME B31.5 IIAR 4 IIAR 5 IIAR 7 IIAR 114* Equipment manufacturer s recommendations IIAR 2 IIAR 109* & 110* ISEA Z358.1 Installation, inspection, and pressure testing of piping System installation Start up commissioning Operating procedures Equipment & pipe labeling Equipment specific and modified based on plant experience Maintenance provisions Maintenance provisions Maintenance provisions for eyewash and safety showers

30 Be aware of code & standard traps! One Example: Consider the following normative requirements from the International Fire Code & International Mechanical Code (IFC 2015) (IMC 2015) (IFC 2015)

31 Be aware of code & standard traps! (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 normative requirement for ammonia refrigerant systems IIAR 2 does not have a normative requirement for EPCS only an informative appendix?

32 Common deviations from RAGAGEP compliance 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

33 What is compliance with RAGAGEP? 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?

34 How to show compliance? 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)

35 When to check against RAGAGEP? 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

36 RAGAGEP checklist tool What is it? 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

37 Questions? 37

38 Additional information on RAGAGEP 38

39 IIAR , excerpts 39

40 IIAR 2 Table of Contents 1. Purpose, scope, applicability 2. Definitions Part 1: General 3. Reference standards 4. Location of ammonia refrigeration machinery 5. General system design requirements Part 2: Design and Installation 6. Machinery rooms Considerations 7. Refrigeration equipment located in areas Affecting Construction other than machinery rooms

41 IIAR Table of Contents 8. Compressors 9. Refrigerant pumps 10. Condensers 11. Evaporators 12. Pressure vessels 13. Piping 14. Packaged systems & equipment 15. Overpressure protection devices 16. Instrumentation & controls 17. Ammonia detection and alarms Part 3: Equipment

42 IIAR Part 4 Appendices Appendix A Explanatory material Appendix B Ammonia characteristics and properties Appendix C Methods for calculating relief capacity for HX internal loads Appendix D Duplicate Nameplates on Pressure Vessels Appendix E Method for calculating capacity for compressor PRV Appendix F Pipe Hanger Spacing, Hanger Rod Sizing, and Loading Appendix G Hydrostatic Pressure Relief Appendix H Stress Corrosion Cracking Appendix I Emergency Pressure Control Systems Appendix J Machinery Room Signs Appendix K Alternative ventilation calculation methods Appendix L Pipe, fittings, flanges, and bolting Appendix M Operational containment Appendix N Reference and sources of references Normative requirement Informative

43 IIAR Ammonia 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.

44 IIAR Purpose: Installation of Closed Circuit Ammonia Refrigeration Systems Specifies minimum requirements for the safe installation of closedcircuit 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.

45 IIAR Table of Contents 1. Purpose 2. Scope 3. Definitions 4. Normative References 5. General Requirements 6. Compressor Installation 7. Condenser Installation 8. Evaporator Installation 9. Pressure Vessel Installation 10. Pipe and Valve Installation 11. Components and Controls Installation 12. Insulation 13. Testing of Installation 14. (Informative) References and Sources of References

46 IIAR Start up and Commissioning of Closed Circuit Ammonia Mechanical Refrigerating Systems Purpose: Specifies criteria and procedures for start up and commissioning of closedcircuit 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.

47 IIAR (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 modifications made 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.

48 IIAR Contents 6. Records 1. Purpose 7. Start Up of New Installations 2. Scope 8. Start Up of Additions and 3. Definitions Modifications to Existing 4. References Installations 5. General Ammonia Information 9. Sources of References

49 IIAR Contents Appendix A Pressures Appendix B Machinery Rooms and Auxiliary Safety Equipment Appendix C Pressure Test, Evacuation and Dehydration Appendix D Pre Charging and Pre Start Up Check Lists Appendix E Purging Appendix F Considerations and Planning for Closed Circuit Ammonia Refrigerating System Tie Ins Appendix G Temperature Reduction Procedure for Newly Constructed Cold Storage Areas Appendix H Pressure chart Normative requirement Informative

50 IIAR , excerpts Design Records: 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.

51 IIAR , excerpts (cont.) Design Records: 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 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

52 IIAR , excerpts Initial Status and Safety Provisions: 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 ) 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 The owner shall ensure that eye wash and deluge shower facilities are available 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.

53 IIAR Commissioning: During the commissioning of the system the trained startup technician shall involve the persons responsible for the dayto day operation of the system The system shall be operated to demonstrate correct function 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...

54 ASME B31.5 Key Contents 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

55 ASME B31.5 Scope 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

56 B31.5 Design considerations Dynamic Effects Impact forces (including hydraulic shock and liquid slugging) Wind (for exposed piping) Earthquake (seismic forces) Vibration Discharge reactions Weight Effects Live loads Dead loads Test loads

57 B31.5 Design criteria overview Allowable Stresses & Other Stress Limits Table 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 Steel pipe ASTM A106 B B Steel pipe ASTM A Steel pipe ASTM A Stainless ASTM A Stainless ASTM A L Allowable stress to 100 F material temperature.

58 IIAR Informative Reference to EPCS (IIAR )