Codes and Standards for Ammonia Systems Stewart Workman, CIRO Carter Redding, CHMM Robert Sherry Condor Earth Technologies, Inc. Jodi Smith APCCO Why Codes and Standards? Established out of lessons learned by experience Learn from the mistakes made by others – often with catastrophic results (Bhopal, TOSCO, Chevron, Gibson winery, etc.) Promotes consistency and reliability Ensures minimum safety and efficiency Federal, State, and Local Agencies and Their Programs Federal Regulators EPA – Accidental Release Prevention (ARP) or Risk Management Program OSHA – Process Safety Management (PSM) California EPA – CalARP (RMP) regulated through the CUPA Cal / OSHA - Various Safety Orders: LOTO, IIPP, Respiratory Protection, Emergency Action Plan, Emergency Response Plan, Hot Work, HazWOPER, HazCom, Eyewash/ Showers, Heat Illness, Confined Space, Unfired Pressure Vessels, Mechanical Refrigeration Emergency Planning Fire Departments CUPA – Hazardous Materials Business Plan, Consolidated Contingency Plan LEPC – Coordination with Local Emergency Response Plans HazMat Response Building Departments Eyewash / Shower ANSI – IIAR II 2008 (cont’d) Alternatives to hard plumbed units, but do they provide 15 minutes of flushing time with large amounts of water as the MSDS recommends? Alternative to having hard plumbed units in remote locations. Codes and Standards Applicable to Ammonia Refrigeration Systems ASHRAE 15-2007, 2010 ANSI / IIAR II – 2008 ASTM IIAR Bulletins (Per Cal / OSHA) Systems placed in service before March 13, 1999 shall be constructed according to the 1982 Uniform Mechanical Code, Chapters 4, 15 and 16 (8 CCR 3248(a)). Systems placed in service after March 13, 1999 and before January 1, 2008 shall be constructed according to the 1997 Uniform Mechanical Code, Chapters 2 and 11 (8 CCR 3248(b)) Systems placed in service after January 1, 2009 shall be constructed according to 2007 California Mechanical Code (8 CCR 3248(c)) NFPA 109 – IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System 110 – Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigeration Systems 111 – Ammonia Machinery Room Ventilation 114 – Identification of Ammonia Refrigeration Piping and System Components and others California Fire Code California Building Code California Mechanical Code 2010 – Chapter 11 Refrigeration ASME B31G Manual for Determining the Remaining Strength of Corroded Pipelines 70 - National Electrical Code 497A - Recommended Practice for Classification of Class I Hazardous Locations for Electrical Installations in Chemical Process Areas 8 CCR Division of Industrial Resources Section 458-Unfired Pressure Vessel Safety Orders Section 3248 – Mechanical Refrigeration Codes and Standards Applicable to Ammonia Refrigeration Systems (condensed) ASHRAE 15-2007, 2010 ANSI / IIAR II – 2008 ASTM B31.5 IIAR Bulletins California Fire Code California Building Code California Mechanical Code 2010 – Chapter 11 Refrigeration (Per Cal / OSHA) 70 - National Electrical Code 497A - Recommended Practice for Classification of Class I Hazardous Locations for Electrical Installations in Chemical Process Areas 8 CCR Division of Industrial Resources Is this “YOUR” system? What codes and standards were used here? It may work, but…. Are the same type of shortcuts done in our systems? How It All Fits Together OSHA and Cal / OSHA do not write specific standards for ammonia refrigeration, but instead rely on manufacturers' recommendations and codes and standards written by industry leaders such as ASHRAE, ANSI, and IIAR. Recognized and Generally Accepted Good Engineering Practice (RAGAGEP). Federal EPA and Cal EPA write the requirements for the ARP programs and enforce their implementation through themselves (Region 9 EPA) and the local CUPA. General Duty Clause – A fallback when specific regulations do not specify compliance requirements. This is not enforced by the CUPA but is by Region 9 EPA. How It All Fits Together (cont’d) California Mechanical Code in 2010 Revision: 1102.0 General “Except as modified by this code, refrigeration systems shall comply with ASHRAE 15. In addition, ammonia refrigeration systems shall comply with IIAR II.” Eyewash Shower ANSI – IIAR II 2008 13.3.1.4 – An eyewash and body shower unit shall be located external to the machinery room and readily accessible via an exit. NOTE: It is recommended that additional such units be located accessibly within the engine room such that no unit is further than 50 ft [15m] from any point in the room. (OSHA additionally calls for unit access to be free from obstructions and on the same level). Recommended means that a unit shall be placed in the engine room to avoid citation. 8 CCR 5162 requires that a unit be placed within 10 seconds of an exposure (injured person). Cal/OSHA figures between 4.5 and 5. 5 feet per second. ANSI 358.1-1981 requires that an eyewash should be within 3 meters (10 feet) of a strong acid or caustic. ASHRAE 15-2004, 2007, 2010 Safety Standard for Refrigeration Systems 9.7.2.1 Vessels of <3 cu. ft. internal gross volume shall have one or more pressure relief valves or fusible plugs. 9.7.2.2 Vessels ≥3 cu. ft. & <10 cu. ft. internal gross volume shall have one or more pressure relief valves. Fusible plugs will not be used. Potential Problems with Emergency Pressure Control Systems An “Emergency Pressure Control System” is an automated system. According to the 1982 UMC “shall be equipped with means for manual discharge of the refrigerant to the atmosphere. Bottom Line; T8 3248(a) does not allow the use of a Emergency Pressure Control System. 2010 California Mechanical Code Diffusion Tanks 1120.0 New requirement – Ammonia shall discharge into a tank of water that shall be used for no purpose except ammonia absorption. At least one (1) gallon (3.785 l) of fresh water shall be provided for each pound (454 g) of ammonia that will be released in one (1) hour from the largest relief device connected to the discharge pipe. Old requirement was one (1) gallon of water for each pound of ammonia in the system. ANSI – IIAR II 2008 5.4.2.1 – Anti-seize and /or lubricating compounds that contain copper shall not be used in contact with ammonia piping. 11.2.5.ii – The capacity of any dual relief assembly whose manifold (3way) valve is set to a position other than fully seated (one side open and one side closed) shall be considered zero. Pressure Relief ANSI – IIAR II 2008 11.3.3 – The discharge piping from pressure relief devices shall comply with the materials requirements of 10.2.1. (same as for rest of system). EXCEPTION: Relief Piping is permitted to be galvanized or ungalvanized ASTM A120, A53/A120, or A53 Type F. Improper Materials of Construction 11.3.6.2 – Discharge piping from pressure relief devices piped to atmosphere shall have provision for draining moisture from the piping. What’s wrong with this picture? Location is over a walkway at 8’ elevation. Pipe material? Drilled weep hole How about these? Earthquake bracing? Corrosion? Materials of Construction? ANSI – IIAR II 2008 (cont’d) New Trend APPENDIX K – informative – Emergency Pressure Control Systems. Provides a method to internally mitigate an overpressure event in a refrigeration system that is independent of other required safety features and functions prior to operation of a pressure relief device. Essentially an internal relief system that uses pressure sensors and a solenoid valve that opens a path from the discharge side to the suction side of the system that operates prior to a relief valve lifting. CMC 1122.0 Emergency Pressure Control Systems When required by the fire code, an emergency pressure control system shall be installed in accordance with applicable fire code requirements. CFC 606.10 Emergency Pressure Control Systems Required in Refrigeration systems containing more than 6.6 pounds of flammable, toxic or highly toxic refrigerant or ammonia. Appendix K – Emergency Pressure ANSI – IIAR II 2008 IIAR Bulletin 111 - Ammonia Machinery Room Ventilation and 2010 CMC §1108 1108.2 – Dedicated mechanical exhaust 1108.2.1 – Continuous ventilation of room at 0.05 inch water gauge negative pressure relative to adjacent places as calculated by Q=2610Ae√∆p 1108.2.3 – Limit the temperature rise within the refrigeration machinery room to a maximum of 104 F (40 C) as calculated by Q=∑q/1.08∆T California Mechanical Code 1107.7 Special Requirements Open flames or devices having an exposed surface exceeding 800 F are prohibited in refrigeration machinery rooms. Corrosion – How Deep is too Deep? ASTM B 31G – Manual for Determining the Remaining Strength of Corroded Pipelines. Developed for Oil and Gas Can be applied to refrigeration piping Example – 0.04 in depth flaw must be less than 0.6” long (wall thickness .109”) Ventilation Ventilation, Alarm, and Shutdown Levels 1107.4 CMC Machinery room shall have approved detectors in areas most likely to accumulate vapors. Trigger audible and visual alarms. Level not greater than the lesser of: .5 x IDLH = .5 x 300 ppm or 150 ppm or PEL = 25 ppm or 25% of LFL = 25% of 15% or 37,500 ppm 1108.2.3 CMC Limit machinery room temperature rise to maximum. 104 F maximum room temperature 1108.4 CMC Automatic ventilation purge Maintain level less than PEL: 25 ppm of machinery room (intermittent as required). Previously required continuous ventilation. 1108.5 CMC Automatic ventilation purge of machinery room (emergency purge). 1000 ppm 1109.4 CMC Manual “Break Glass” switches outside of machinery room and automatic shutdown of all machinery room electrical. 25% of Lower Flammability Limit (LFL) 25% of LFL = 25% of 15% or 37,500 ppm IIAR Bulletin 111 - Ammonia Machinery Room Ventilation and 2010 CMC 1108 (cont’d) 1108.2.4 Provide emergency purge of escaping refrigerant as calculated by Q=100√G Where: q= Btu/h of all heat producing equipment Q= air flow rate, cubic feet per minute (cfm) ∆p= pressure difference, inches of water gauge Ae= equivalent leakage area, square feet (see the building code) Agf = gross floor area, square feet ∆T= temperature difference between machinery room and supply air ( F) G= refrigerant mass in largest system, lbs IIAR Bulletin 111 - Ammonia Machinery Room Ventilation and 2010 California Mechanical Code 1108 (cont’d) 1108.5 Emergency Control of the Ventilation System 1. 2. Clearly Identified “Break Glass,” “on” only control on outside of each machinery room door. For ammonia, system shall automatically respond to detector system at no more than 1,000 ppm. Manual reset only on control system. 2010 California Mechanical Code 1109 (cont’d) 1109.4 Emergency Control 1. Clearly identified “Break Glass” type switch for “off” only control of electrically energized equipment and devices inside the machinery room shall be provided immediately adjacent to and outside of each refrigeration machinery room exit. Automatic shutdown control activation is required when the concentration of refrigerant vapor exceeds 25% of the Lower Flammability Limit (LFL). Ventilation, Alarm, and Shutdown Levels 1107.4 CMC Machinery room shall have approved detectors in areas most likely to accumulate vapors. Trigger audible and visual alarms. Level not greater than the lesser of: .5 x IDLH = .5 x 300 ppm or 150 ppm or PEL = 25 ppm or 25% of LFL = 25% of 15% or 37,500 ppm 1108.2.3 CMC Limit machinery room temperature rise to maximum. 104 F maximum room temperature 1108.4 CMC Automatic ventilation purge Maintain level less than PEL: 25 ppm of machinery room (intermittent as required). Previously required continuous ventilation. 1108.5 CMC Automatic ventilation purge of machinery room (emergency purge). 1000 ppm 1109.4 CMC Manual “Break Glass” switches outside of machinery room and automatic shutdown of all machinery room electrical. 25% of Lower Flammability Limit (LFL) 25% of LFL = 25% of 15% or 37,500 ppm New! IIAR PSM and RMP Guidelines 2012 Edition NEC electrical classification of areas outside of compressor rooms may be required. Example: Refrigerated rooms with control groups which may leak ammonia. Exceptions Rooms that have adequate ventilation and where combustibles are contained in well maintained piping and Rooms that have no ventilation but do not have flanges, valves, fittings, etc. that may be prone to leaks PSI Draft IIAR 2 Guidelines (normative) 8 Electrical Classification The areas containing refrigeration piping and equipment that are not located in machinery rooms may need to be classified for NEC purposes. Experience has shown, however, that the release of ignitable mixtures from some operations and apparatus is so infrequent that area classification is not necessary. For example, according to NEPA-497A it is not usually necessary to classify the following locations where combustible materials are processed, stored, or handled: (I) Locations that are adequately ventilated, where combustible materials are contained within suitable, well maintained, closed piping systems; and, (2) Locations that are not adequately ventilated but where piping systems are without valves, fittings, flanges, and similar accessories that may be prone to leaks. How are different codes and standards that conflict with each other interpreted? Laws & Regulations Chaptered into Code Regulations developed by agencies Performance specifications RAGAGEP from authoritative groups Regulations administered by different agencies RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) General Duty Clause What happens if we ignore the codes? Normal Org Chart (before accident) Responsible Person You are here Required Work Revised Org Chart (after accident) Required Work Questions Condor Earth Technologies, Inc. Office Locations: Merced Roseville Sonora Stockton (800) 800-0490