2020 RETA Breeze Jul-Aug

RETA BREEZE

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION JULY / AUGUST 2020

2020 NATIONAL CONFERENCE IS GOING VIRTUAL

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BREEZE

The RETA Breeze is the official publication of the Refrigerating

Engineers & Technicians Association (RETA). RETA is an international not- for-profit association whose mission is to enhance the professional development of industrial refrigeration operating and technical engineers. Don Chason Executive Editor 704-455-3551 Jim Barron Executive Director

2020 is our first ever virtual National Conference

page 12

jim@reta.com Sara Louber Senior Director, Office Operations

INSIDE THIS ISSUE

sara@reta.com Dan Reisinger Certification Manager dan@reta.com Michelle Robinson Conference Manager michelle@reta.com Dan Denton Chapter Relations Liaison ddenton@reta.com Vince Grindel Education Coordinator vince@reta.com

Message FromThe President............4 Letter FromThe President................6 Message FromThe Executive Director.............................8 Epic Fail.............................................10 Where Did My Nameplate Go? Conference Corner.............................12 2020 Is Our First Ever Virtual National Conference 2020 Virtual Conference Preview ...15 Capital Budgeting Education Corner............................16 Industrial Refrigeration 1 & 2

What is a Non-Permit Required Confined Space?...............................18 Defining Wall Thickness.................20 Acceptance Levels for Your In-Service Piping Tier Reporting & Avoiding Common Mistakes Part One..........24 Call for Nominations.......................26 Reta Testing Corner No. 20............28 Reta’s Testing And ANSI Guru Certification......................................30 Honor Roll

The information in this publication is based on the collective experience of industry engineers and technicians. Although the information is intended to be comprehensive and thorough, it is subject to change. The Refrigerating Engineers & Technicians Association expressly disclaims any warranty of fitness for a particular application, as well as all claims for compensatory, consequential or other damages arising out of or related to the uses of this publication. Publication of advertisements in Breeze , or any other RETA publication, does not constitute endorsement of any products, services or advertisers by RETA and shall not be considered or represented by advertiser as such. Copyright © 2020 Refrigerating Engineers & Technicians Association.

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION 1725 Ferry St. SW, Albany, OR 97322 Telephone: 541.497.2955 | Fax: 541.497.2966 RETA.com

RETA.com 3

2019-20 BOARD OF DIRECTORS CHAIRMAN Arlie Farley, CARO, CIRO Farley’s S.R.P., Inc. PRESIDENT Vern Sanderson, CIRO, CRST, RAI Wagner-Meinert, LLC EXECUTIVE VICE PRESIDENT Eric Teale, CARO, CRST Danfoss Industrial Refrigeration TREASURER Keith Harper, CARO Tyson Foods SECOND VICE PRESIDENT Pete Lepschat, CIRO, CRES, CRST Henningsen Cold Storage, Co. DIRECTORS Bengie Branham, CIRO Perdue Farms William Ellena Coastal Pacific Food Distributors, Inc David Gulcynski, CIRO Dot Foods Inc. Michael Hawkins Midatlantic Refrigeration, LLC Matt Hayes, CARO TJW Industrial Edward Johnson, CARO Schwans Global Supply Chain, Inc. Frank Kologinczak III Kolo Compression Jim Kovarik Gamma Graphics Bill Lape, CARO, CIRO, CRST SCS Engineers Jordan Reece, RAI Ricky Jimenez, CIRO Mericle Mechanical Inc COMMITTEE CHAIRS Gene Dumas, CARO, CIRO, CRST, RAI Nominations SCS Tracer Environmental Dave Gulcynski, CIRO , Education Dot Foods, Inc. Jim Kovarik, National Conference Gamma Graphics Lanier Technical College Raymond Urban, CARO Lineage Logistics

FROM THE DESK OF THE PRESIDENT

I hope this finds you and yours happy and healthy! As you’ve heard, the 2020 RETA Conference has gone Virtual. A letter was emailed to the membership outlining my thoughts about the situation (it is also published on page 6). It was not an easy decision, but one that was necessary. I believe that the 2021 Conference will be a little more special because of this. The virtual Conference creates many opportunities for our members that were simply not available before. I look forward to it. RETA has always been a family to me. I’ll miss seeing my family. But we will be together virtually this year. Maybe we won’t get to share as many stories, but we will experience the virtual Conference together. Shared experiences, shared history, and shared values are core to any family and our RETA family is no different. The virtual Conference will be a great opportunity for us to have a shared experience. Kind of like that time when we all went down to the pub at the 2016 conference and… (Removed by editor) I look forward to telling my grandson about the 2020 virtual Conference in the future. He’s five years old and may not remember all the good times we GREETINGS!

Vern Sanderson, RETA National President

will have during this year’s virtual Conference but he will remember some. This has created an opportunity for him as well as a lot of the members of the RETA family, to attend sessions without the time and expense of travel. The virtual Conference will make attendance more economical for our members. As great as I expect it to be, I also hope, my grandson will never experience another year without a face to face Conference. I should probably clarify, so no one misunderstands, I’m not making my grandson attend all of the sessions. I’m going to let him choose what he wants to attend. But he is like every other young refrigeration service technician, he loves big compressors!

Michael Hawkins, Membership Midatlantic Refrigeration, LLC Matt Hayes, CARO, Publications TJW Industrial Lee Pyle, CARO, Certification SCS Tracer Environmental Jim Barron, Executive Director

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So, it will be hard to keep him out of the virtual display booth. LOL It’s funny how different people remember different things about Conference. To my grandson, the RETA Conference is where stuffed alligators come from, pictures of new compressors, and the place where grandpa and grandma dress up. To my daughter, Conference is that time, when she gets new information and new thoughts on compliance in the industry (my daughter is a refrigeration compliance specialist). My technicians look forward to Conference for new tips and service tricks. My engineers want to know about the latest multi-platform valves, condenser technology, and water treatment innovations. There is something for everyone at the RETA Conference, and the virtual RETA Conference will be no different. We are trying to organize a virtual RETA rumble. For everyone who has attended and seen the chaos in person, can you imagine the chaos associated with a virtual rumble? This will be great! I’ve already heard rumors that some teams are looking at faster internet connections to give them an advantage when buzzing in. Can you imagine anyone doing that? Humm, I wonder if the internet speeds in Astatula, Florida are faster than Broughton, Ohio? I may need to check on that. You know if I could talk Tonya into unplugging Arlie’s internet connection before the first question……….. LOL The Conference Committee and RETA HQ are working very hard to make “Virtual RETA 2020” unforgettable! We hope you join us. But this Fall holds a lot more than the RETA Conference. Our committees are also hard at work. New editions of training manuals IR1 and IR2 were released recently. Many more exciting things are coming. The next issue of the Breeze will be our Conference preview edition. I’ve also

got a peek at a few of the upcoming articles, it will be great! We are seeing renewed activity from

enforcement agencies. RETA is monitoring the ever changing

environment, and as you seen a few weeks ago, we will forward information to the membership when we see issues. RETA HQ provides so much for the membership, and the elected leadership. They are working diligently to provide you the best possible service throughout these difficult times. Thank you HQ! The Executive Committee is working on the 2021 national budget. All our Board of Directors are preparing for the fall board meeting and strategic planning. It is an exciting time. Our chapter meeting attendance is rising. As more and more chapters are choosing to meet in person, we need to remain vigilant to keep the RETA family safe! I suggested a door prize for the best refrigeration mask! We have a “no fingeres or toesies” rule. If you can stretch out and touch fingers or toes, your too close. The chapters that are choosing to remain virtual for the time being can also reach out to an even larger segment of their membership. Invite those members who are too busy to drive to the meeting to attend virtually. Also consider making an archive of your virtual chapter meetings for those who are not available at the time of the meeting. RETA HQ can help with this. This is a great time to try something new with your chapter. I want to thank Gordon Roscoe for the opportunity to speak at his chapter meeting. I had a great time. Thanks Gordy! Please remain safe! Thank you for the opportunity to serve!

Vern M. Sanderson VSanderson@WMIllc,com

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LETTER FROM THE PRESIDENT Republished letter sent to the RETA membership this summer.

The Confrence has Gone Virtual I hope this communication finds you and yours happy and healthy! It is with sadness that I address the membership today. As you know our annual Conference (held continuously since 1909) is quickly approaching. This year we will not be meeting in person. Please read the rest of this message. I have decided, with the support of the National Board, to replace the Conference in Florida with a virtual Conference. I will explain the philosophy of the change later in this message, but I want to begin by explaining the financial impact of this change to our members and supporters. Every Exhibitor, Sponsor and attendee will receive a 100% refund of the monies they have paid toward this year’s Conference. This is not a credit toward future conferences, or a partial refund. There will be a 100% refund. None of our supporters or members will lose anything that they have paid to RETA. We certainly hope everyone chooses to attend our virtual Conference. Some of our Exhibitors are already preparing their online booths. Registration will begin shortly, and details are available on the RETA website www.RETA.com. RETA has prepared for this contingency for some time but the decision was not an easy one. We delayed as long as possible, hoping for the best possible outcome. Travel restrictions from employers, state regulations, national regulations, and most seriously the health risks to our attendees conspired to make a live conference almost impossible. I simply will not risk the health of our members. Personally, I believe the RETA Conference is a family reunion. I miss my family. After the long ordeal with the pandemic, I was looking forward to the comfort and companionship of my RETA family as were many of you. I always look forward to seeing everyone.

I usually hit Gene up for drink. Kenny always has a funny story. I get a big ole handshake from Jake. Dan immediately asks “So Vern, how you been?” and as family does, he really cares about the answer. Somehow, I always end up having dinner with John and Cynthia just to catch up. Georgia and Tonya always conspire to make sure Keith and I eat properly during the Conference. I will miss all of that this year. But I will get to talk with them, share memories, attend classes together, and share a joke or two. I’m just doing it virtually. I’m sure you have many questions; My guarantee to you is that all of your questions will be answered shortly as the professionals at RETA HQ role out “Virtual RETA 2020”. But I want to mention 2021 briefly. As I said last October when you entrusted me with the President’s gavel, RETA is the voice of the Refrigeration Industry. It is time to invite our cousins to the reunion. We are working with other industry organizations to encourage their members to attend our 2021 Conference. We have extended our hands to our brothers and sisters in the commercial refrigeration industry. We want them with us. We face many of the same struggles. Our industry will overcome these struggles together as a family. I believe our children will look back on 2020 as a year of hardships, but out of these tribulations will emerge a stronger RETA and a stronger refrigeration Industry. We will make history together! I hope to see everyone online and in person soon. May you and yours be blessed!

Vern M. Sanderson Privileged to be your 2020 RETA National President!

RETA.com 6

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FROM THE EXECUTIVE DIRECTOR

Hello all, I’m sitting here quarantined to my house after a two week trip to visit an elderly relative. Oregon has strict guidelines regarding social distancing, wearing masks, and businesses having a max capacity so I was not worried about traveling out of state until we made a side trip to Old Faithful in Yellowstone. The parking lots were completely packed, and no one was wearing a face covering of any sort so in our best interests, we didn’t end up stopping to see Old Faithful. I noticed that most places during our trip had no guidelines or protection for others. Protecting others is what I have done most of my life. I protected the United States of America and our way of life by serving in the military. I protected the people around me, my family, friends and coworkers for as long as I can remember with safe work practices. This is something I will always do until my dying breath. I will also protect my RETA Family with all that I am, by doing the right things for the right reasons. We as leadership have had to make decisions based on protecting all of you. As you have all heard, we will not be having an in-person Conference this year. We have converted to a virtual Conference for the protection, safety, and well- being of all.

I would ask for all RETA members to support this decision and to please be apart of this virtual Conference. RETA needs your support through these challenging times. We are offering the same topics virtually so you will still receive the same dynamic content. There will be virtual booths for our vendors so that all attendees can sponsorships available to get your name out there. There will be other goodies and surprises for attendees, and we are looking forward to everyone’s continued involvement with this year’s Conference. We have worked diligently with ANSI to offer Online Proctoring (OLP). It has now been approved which means you may take a RETA exam at a location that is not an official test center. There are rules and requirements so please speak with the Certification department at RETA HQ by emailing certification@reta.com and they can assist you with the process. The Education department hasn’t slowed down a bit and they are knee-deep in the review process for several RETA books. RETA HQ office remains staffed and continues to assist our members however possible. continue to interact with the exhibitors. We also have some

RETA Executive Director Jim Barron

I will miss shaking your hand or giving you a hug, and mostly I will miss our conversations. We will all miss seeing your faces in person at Conference; however, we won’t forget what you look like and can’t wait to see you next year.

Thank you all and God Bless, Jim Barron Executive Director

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EPIC FAIL

WHERE DID MY NAMEPLATE GO?

inspector will require that this nameplate be replaced. Second, the key lies in the traceability. If the facility has the original manufacturer’s data sheet and, preferably, the original drawing as well, then traceability is fairly easy and approval for installing a replacement nameplate is fairly easy. The real issue come to bear when the documentation for the vessel cannot be obtained, whether because the original nameplate was lost after it became detached, or because the vessel was not registered with the National Board and the manufacturer is long since out of business. When this happens, it becomes very difficult and expensive to have a professional engineer re-certify an existing vessel in order for a new nameplate to be fabricated and attached.

This story starts with a nameplate that was originally tack welded to the pressure vessel as was often done back “in the day.” Over time, water worked its way underneath the nameplate and began to corrode the vessel. In an effort to deal with this, the facility removed the nameplate in order to clean up the corrosion and stop it by painting the vessel. For a time, this nameplate was lost, until the facility maintenance manager was cleaning out a drawer in his desk and he happened upon it. Realizing that it needed to stay with the vessel, he had it secured near the vessel using wire. An admirable thought, but it is an epic fail. First, the National Board Inspection Code states that: “When the stamping on a pressure-retaining item becomes indistinct or the nameplate is lost, illegible, or detached, but traceability to the original pressure-retaining item is still possible, the Inspector shall instruct the owner or user to have the nameplate or stamped data replaced.” First off, an

Let’s say that the manufacturer’s documentation for the vessel is available. Should this be the case, a new nameplate can be fabricated and applied by someone holding an R

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stamp from the National Board. The application of the new nameplate must be witnessed by a National Board commissioned inspector. All of this costs money. Here’s the rub. The National Board Inspection Code states that: “Permission from the Jurisdiction is not required for the reattachment of nameplates that are partially attached. So, if a nameplate is still partially attached, as in the photo below, it can be reattached using rivets or screws by facility personnel and it does not need to be inspected by a National Board commission inspector. So, it pays to inspect the nameplates of your vessels, particularly if they are hidden under insulation. Because once they fall off completely, the real problems start. In addition, it pays to identify corrosion before it leads to material loss so that it may be cleaned up and arrested before it affects the safe working pressure of the vessel. If you have photos of an Epic Fail please pass them on to nh3isB2L@gmail.com. Bill Lape is Project Director for SCS Engineers. Bill is a Certified Industrial Refrigeration Operator, a Certified Refrigeration Service Technician, and a member of the National Board of Directors of the Refrigerating Engineers and Technicians Association.

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CONFERENCE CORNER

2020 IS OUR FIRST EVER VIRTUAL NATIONAL CONFERENCE Michelle Robinson, Conference Manager

W ell…2020, has given everyone a run for their money! People having to work from home, children are distance learning, the elderly staying at home while groceries, and children’s birthday parties have turned into birthday drive-by parades instead. However, I must say my 11-year- old granddaughter Khloe had a birthday parade in April and at first she was pretty bummed, but afterwards she said it was the best birthday party ever! With that said, we’ve all had to make changes to keep family, co- workers, and the community safe and healthy, some of which include using new innovations which have had great results, such as my granddaughter’s birthday parade. family and friends run their errands and provide their

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So, without further ado, in light of COVID-19 and with respect to the health and safety of all involved, we are excited to announce our first ever virtual National Conference. Thanks to innovative technology, this can’t-miss event will offer dedicated exhibit hall hours, virtual branded booths, and networking opportunities. RETA has hosted the National Conference for 110 years and the tradition continues as a virtual event. New Format — Same Dates! The event takes place as originally scheduled from October 27th–29th, 2020. Transitioning the RETA National Conference to a virtual event has reduced RETA’s overhead costs for the event, so we are passing the savings along to you. REGISTRATION IS NOW OPEN and the fee has been reduced from $825 to $275 for RETA members if registered by September 30th and $300 after October 1st. The fee for non-members is $375 if registered by September 30th, or $400 after October 1st. Register at https://reta. com/page/2020-conference-home. The exhibitor fee has also been lowered from $2,045 to $1,000 for standard booths and premium booths have decreased in price from $7,920 to $1,250. If you would like to sponsor and/or exhibit please call me at 541- 497-2955 or I can be reach by email at Michelle@reta.com

$825

$275

Reduced price for RETA members if registered by September 30th

$7,920

$2,045

$1,250

$1,000

standard

premium

Exhibitor fee is lowered to a special new price.

Our Virtual Conference has an all-encompassing program helping all attendees, at any level of experience and position, grow within the refrigeration industry.

RETA.com 13

We have several educational topics and there is something for everyone regardless of experience and position.

The following Manufacturing Sessions will be presented twice during our Virtual Conference and are worth 1.5 PHD upon completion. Canned Pump Rebuild How to Prevent False Alarms in Gas Detection Systems with Live Calibration Lesson Pressure Relief Valve Options/Applications Please note: participation and poll answering is required for completion to receive PDH.

The following technical topics will be presented 3 times during our Virtual Conference and are worth 1 PDH upon completion. Introduction to 6 CFR 27, The Chemical Facility Anti-Terrorism Standard Getting the Maximum Benefit fromYour Incident Investigation Program and Procedures Compliance Audits: Ensuring the Viability of a Living Program FY Budgeting Process-Capital Budgeting Critical Tasks for an Emergency Action Plan Evaluating an Evaporative Condenser to Determine if it is a Permit-Required Confined Space Daily Rounds, What Are They Really, AndWhy Are They Important? FSMA Compliance and Energy Savings with an Effective Building Envelope How Do I Cavitate Thee? Let Me Count the Ways Refrigeration Pressure Vessels: Design Considerations for an Evolving Industry Vessels Operating at Temperatures Colder than the MDMT Stamped on the Nameplate The Side Port: A Compressor’s Little Helper IIAR Suite of Standards Update

Hope to see you on our Virtual Platform in October. Thank you and stay safe and healthy!

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2020 VIRTUAL CONFERENCE PREVIEW

“A very insightful paper. Loooonnnngggggg overdue. Many people are thrust into a role where they need to manage or even develop a maintenance budget with little or no formal training. Ray’s whitepaper shine light on a subject that everyone in our industry must deal with. Of course plant or corporate managers must deal with budgets. But Operators must as well.” technician carrying a pipe three blocks to the maintenance shop, because the facility was out of Sawzall blades and they budget wouldn’t allow them to purchase more until next quarter. But somehow, they could afford the extra labor. It took over two hours to haul the pipe to the maintenance shop, cut a 20”piece and haul the remainder of the pipe back to storage.” “It’s important that everyone involved in the budget process understands how it is constructed. Only through understanding and working together can a budget be executed well.” “I can say I have a better understanding of the budget process. It also took out some of “I remember frommy own experience, a maintenance the mystery of the capital or operating costs question.” “Ray is a great presenter, I appreciate someone who can dissect a difficult subject and make it fun. This will be a great presentation!”

What reviewers have to say:

CAPITAL BUDGETING Author: Ray Urban Continuing Education Credit: 1 PDH

I n today’s fast business, we are constantly working within boundaries. As a young engineer, I continuously found myself explaining why my monthly expenditures were over the prescribed budget. Not knowing where or how this tight restraint was developed I was just told to stay within the numbers. As I have moved up in seniority and into management I am now the one developing these financial guidelines. The budget is an operating tool to assist in the managing of funds. It is a written guideline and a projection of a facilities operating cost. The maintenance budget is to include but not limited to building, material handling equipment,

refrigeration, sanitation and lawn care. In everyday life as an adult we manage a bank account, checking account and savings account. This presentation will discuss common issues and share some hard learned lessons, and share some ideas on how to solve them. It centers on planning and executing a workingmaintenance budget. Hopefully, you can take some of these and apply them to your current role. This previewwas compiled by Vern Sanderson in conjunction with the author, Ray Urban. We would appreciate your feedback after the presentation. Please be as detailed as possible in your comments.

From the Author:

RETA.com 15

EDUCATION CORNER

With Summer in full swing, 2020 has proven to be a memorable year. One for the history books. I hope everyone is SAFE and WELL and enjoying life as much as possible. I want to let everyone in on a couple bits of information. First off, the NEW and IMPROVED 2020 Revision of INDUSTRIAL REFRIGERATION ONE is in RETA’s online bookstore. A huge amount of work went into fixing and upgrading and raising the bar. And a NEW and IMPROVED 2020 Revision of Industrial Refrigeration TWO has been presented to the Board for their approval. More as things develop.

NEW AND IMPROVED

Industrial Refrigeration 1 & 2

Vince Grindel, Education Coordinator

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RETA.com 17 Innovation based. Employee owned. Expect more.

What is a Non-Permit Required Confined Space? “Non-permit confined space” means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.

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M-series Reciprocating Compressor

All servicing procedures are to be performed and all energy is to be locked out and/or blocked before entry is allowed into a non-permit confined space area. If any ventilation is present, it will be locked in the“on”position as long as entrant remains in the tank. A“buddy system”may still apply (if deemed appropriate and given the circumstances) whereby one employee remains on the outside to assist the employee on the inside of the tank. A non-permit checklist will be utilized by all employees entering a confined space that does not require a formal permit and air monitoring will be performed prior to and during entry. If conditions of the confined space changes, the entrant will be instructed and so trained to immediately evacuate the confined space. Employees must be trained on proper usage of air monitoring equipment prior to being authorized to take readings. All confined spaces are to be considered PERMIT REQUIRED CONFINED SPACES unless declassified. At no time should a confined space be considered a NON- PERMIT CONFINED SPACE without being declassified. Air monitoring must still be performed, and the non-permit checklist completed any time a NON-PERMIT CONFINED space is entered. Cutting or welding inside a tank or silo affects the atmosphere inside and therefore voids the non-permit reclassification. Welding stainless steel inside a tank or silo can lead to exposure to hexavalent chromium fumes. You must have adequate supplied air ventilation inside the tank or silo when welding. Cutting and welding work may not be done inside a tank or silo without obtaining the proper“HotWork”permit.

KNOWN FOR RELIABILITY

Minimizes internal heating of the intake gas New valve structure with improved durability and extended overhaul intervals of up to 16,000 hours based on RPM Great for high pressure applications and a wide range of operating conditions Easy replacement of consumable components Multiple configurations available for drive type and refrigerant compatibility

A PERMIT REQUIRED CONFINED SPACE may be reclassified as NON-PERMIT REQUIRED CONFINED SPACE only once the potential hazards have been eliminated and are not present after several tests and entries have been performed. A NON-PERMIT REQUIRED CONFINED SPACE CHECKLIST will be required in order to ensure that the potential hazards are not present. Additionally, air monitoring will be required prior to entry and throughout the entry despite the reclassification as Non- Permit Required in order tomonitor for changing conditions.

info@mayekawausa.com | 615-773-2859 www.mayekawausa.com

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DEFINING WALL THICKNESS ACCEPTANCE LEVELS FOR YOUR IN-SERVICE PIPING

Jim Kovarik, VP NDT Technology, Gamma Graphics Services (GGS)

T he piping in your ‘deficiency’. Implementing a baseline for your organization that defines specific action at different severity levels of piping deterioration, and what those levels are, is a necessary inclusion for operating within the parameters of PSM and RMP requirements. system covers a large footprint of the equipment that is susceptible to

OSHA’s Process Safety Management of Highly

or in a safe and timely manner when necessary means are taken to assure safe operation.” EPA’s Risk Management Plan Rule (40 CFR 68, defined by Section 112(r) of the Clean Air Act Amendments) has adopted the OSHA PSM standard as its prevention program for processes in Program [Level] 3.

Hazardous Chemicals Standard (29 CFR 1910.119)(j)(5) requires “The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before further use

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the pipe metal. Piping with moisture in the insulation becomes corroded and eats away the metal on the pipe surface, thinning the pipe wall. The rate at which corrosion thins pipe wall in an ammonia refrigeration system is not calculable. Variables such as pressure, velocity, acidity and the amount of moisture (and its rate of expansion) are not controlled. ‘Corrosion rates’are only valid for erosion/ corrosion occurring internally in piping systems; ammonia is not a corrosive chemical to carbon steel or stainless steel piping. Therefore, piping used in closed- circuit ammonia refrigeration systems is generally not susceptible to internal corrosion, and the application of corrosion rates are invalid. Thresholds and decisions to take action to maintain or replace piping must be based on current pipe wall thickness values and not anticipated rates of deterioration.

12.5% under-tolerance on new pipe wall thickness. As an example, a Schedule 40, 3-inch pipe nozzle has a nominal wall thickness of 0.216 inch, so the actual wall thickness on a nozzle or pipe shell would be acceptable down to manufacturing was not as efficient, and methods built-in a margin of error to meet the allowable tolerance limits. This resulted in piping that regularly measures 20-30% thicker than normal. If your system or parts of your systemwere installed before 2000, you have piping with a wall thickness significantly thicker than nominal values. If a section of pipe manufactured before 2000 was reported wih a 50%measured ‘loss’ (depth of pit versus nominal), your piping wall thickness could actually be at 80% of nominal, not 50%. This method of reporting will result in unnecessary replacements and inaccurate pipe wall thickness values. Replacements will result in the installation of newly manufactured piping with wall thickness values less than that of the in-service pitted piping that was replaced. The value that should be the focus of determining the fitness of your piping, as well as the value your thresholds are defined by –must be the remaining pipewall thickness. 0.189 inch straight from the mill. Further, prior to 1990 – 2000, pipe

50%

80%

‘Percentage Loss’ versus ‘Percentage Remaining’

Pitting corrosion is the most common form of corrosion found in refrigeration systems. Pitting is usually a slow process causing isolated, scattered pits over an area. Left unaddressed, pitting corrosion will continue to deteriorate the pipe wall and could result in a leak. Pitting can be measured. However, measuring the pit does not provide accurate wall thickness or loss measurements due to variables such as pipe age and allowable manufacturing tolerances. Wall loss and percentage of wall loss values, an estimation that is made against nominal values (not allowable pipe wall thickness values) do not provide an accurate measurement of remaining pipe wall thickness. ASTM specifications for seamless pipe manufacturing standards permit a

Necessary Fitness Data The baseline for determining acceptable pipe wall thickness values are pipe size and schedule, and standard pressure values. While pipe wall thickness measurements are key, if the pipe size and schedule are incorrect, the acceptance criteria is void.

Corrosion Under Insulation The damage mechanism that thins pipe wall in ammonia refrigeration systems is Corrosion Under Insulation (CUI). Water or condensation breaches the vapor barrier and rests in the insulation against the surface of

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It is strongly recommended that the testing method you employ also measures to confirm the size and schedule of your piping, rather than relying solely on your P&IDs or assumptions. Non-destructive testing should be applied on insulated and uninsulated piping in areas where CUI and damage is likely to occur, as well as areas identified as suspect as a result of a Mechanical Integrity inspection. The testing method you choose (or combination of methods) should be able to provide you with the following data to appropriately determine if the piping meets your tolerance criteria: 1. Pipe wall thickness measurement 2. Pipe size and schedule Presence of corrosion and locations with concealed wet insulation attribute to maintenance and replacement decision- making to arrest the thinning of affected pipe in your system. However, these conditions do not play a role in determining if the pipe is acceptable to remain in service. Areas where pipe wall thickness measurements in your system are reported as less than nominal, or are at your defined thresholds, can then be appropriately categorized by severity.

recommending that owners take a more stringent approach in developing pipe wall thickness operating thresholds for their systems. The Conservative Approach For companies that intend to implement a more stringent level of acceptance criteria, as recommended by IIAR and applied by corporations that maintain best practices, the table, In-Service PipeWall Thickness Thresholds for Ammonia Refrigeration Piping Systems, includes the same metrics as the ANSI/IIAR 6 Standard Table A.11.1.1.3.1 with recommended, more prudent threshold values that are generally acceptable for maintaining a sound system. Download the table by visiting https://inspectpipe.com/ ndt-resources/pwtal/. *Please note the values in the tables only apply to the pressure envelope of the pipe. They do not take into account other types of loading whichmay increase the remainingminimumalert and replacement thickness values.

Minimum Requirements ANSI/IIAR Standard 6-2019 Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems offers an informative (suggested but not binding) consideration to define acceptable limits for pipe wall thickness to meet PSM and RMP requirements. Table A.11.1.1.3.1 of the Standard provides minimum remaining pipe wall thickness values to determine repair or replacement conditions of carbon steel piping. The values offered by the table in the standard are the very lowest possible tolerance levels before running to failure. For this reason, the Standard also states in referencing the table:

“Owners typically use or are encouraged to use more

conservative “Alert Thickness” and “Replacement Thickness” values,”

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Helping you keep it cool for over 30 years! Helping you keep it cool for over 30 years!

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Tier II Reporting & Avoiding Common Mistakes Part One By: Travis Weber, SCS Engineers

T he Emergency Planning and Community-Right-to-Know Act (EPCRA) was enacted by Congress to assist local communities in protecting public health by requiring facilities to file an annual EPCRA Tier II Report, identifying hazardous chemical inventories maintained at the facility. Submitting Tier II Reports allows the local emergency personnel to be aware of the chemicals that are present within facilities in their jurisdiction, and prepare for and respond to chemical emergencies. The annual federal deadline for submitting

When it comes to managing compliance for an ammonia

compliance task, being familiar with the background of the regulation is helpful in understanding what is going to need to be done at your facility in order to achieve full compliance. This article is intended to familiarize the reader with the requirements for reporting under EPCRA and describe some of the most common mistakes that are made when reporting.

refrigeration facility, there are no shortage of tasks that demand your attention. If you were to rank your compliance tasks based upon their difficulty or time demand, EPCRA Tier II Reporting is not likely to rank high on your list. However, the danger is that it will be overlooked altogether, or it will not be given enough priority to ensure accurate completion. As with any

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• Local Emergency Planning Committee (LEPC), and The fire department having jurisdiction over the facility. EPCRA Tier II reporting is a federal regulation administered by the EPA, which has laid out the basic requirements of EPCRA, including the March 1st deadline. However, the State Emergency Response Commission (SERC) carries out EPCRA implementation at the state level. So, while the basic requirements may remain the same, each state may have additional requirements, including different submittal deadlines. The steps and methods of reporting that are necessary to complete your Tier II Report are going to be dependent upon the guidelines and requirements of the state in which the facility resides. • It is extremely important to verify the method of submittal that is required within your state. Some states require that Tier II forms be submitted electronically, while other states may require hard copy submittals. Still others require both digital and printed submissions. If your state accepts digital Tier II Submittals, it is important to confirm if the digital submission is automatically distributed to all three required recipients (SERC, LEPC, and Fire Department). Some states may require online submittals to the SERC, but require printed submittals to the LEPC, and local fire department. States such as California, Louisiana, and Pennsylvania, among others, have developed their own online reporting systems while others utilize common reporting software. For example, the EPA has developed a free Tier II submittal software“Tier2 Submit”, which allows the user to create a digital file to be uploaded to state reporting sites. The Tier2 Submit software can also be used to generate a PDF

file for printing and hard copy submittals. Some states are requiring that Tier2 Submit be used, while other states do not accept Tier2 Submit files at all. If a state has developed their own online reporting system, they will not typically accept other forms of submission. The EPA website provides a synopsis of Tier II reporting procedures and special requirements for each state, as well as contact information for the offices and personnel responsible for Tier II administration. Most SERCs provide specific instructions to clarify reporting requirements within their respective state. Utilize these resources to ensure that your Tier II Report is meeting the necessary reporting requirements, as well as utilizing the proper submittal format for your state.

It is extremely important to verify the method of submittal that is required within your state.

When it comes to Tier II Reporting, we know that an accurate report and full compliance is the desired destination, but it is always a good idea to have accurate directions before beginning any journey. Spending some time to ensure you have a clear understanding of your states Tier II Reporting requirements and methods of submittal is a great place to start. The next article will highlight the most common mistakes that are made when preparing and submitting Tier II reports. Travis Weber is a Staff Professional for SCS Engineers: Tracer Environmental Services. Travis is a Certified Assistant Refrigeration Operator.

Tier II Reports is March 1st (more to come on this deadline). Facilities are required to report any chemicals, which are included within the OSHA Hazard Communication Standard (29 CFR 1910.1200). A list of EHSs and their TPQs can be found at 40 CFR 355, Appendix A. The EPA has compiled a“List of Lists”which provides a consolidated list of chemicals which are subject to EPCRA Tier II reporting along with their Threshold Planning Quantities (TPQ). The TPQ is the amount of chemical kept on site above which you must file a Tier II. It is important to note that ammonia has a Tier II reporting threshold of 500 pounds. Each facility maintaining chemical inventories as described above is required to submit an annual Tier II Report to the following agencies: • State Emergency Response Commission (SERC),

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Call for Nominations There is still time to get your nomination in before the Virtual Conference this October.

Identify who that special RETA person is in your area and jot down some reasons you think they should be honored. Send this nomination and the supporting documentation to the Executive Director Jim Barron by email to jim@reta.com or submit it online at www.reta.com/ nominations. Nominations must be received by September 4th, 2020 in order to give the awards committee adequate time to consider the nominations.

The following awards are named in honor of past RETA members who exemplified a specific strength that benefitted the RETA membership and our industry either through teaching, leadership, or service.

Guy R. King Memorial Award Recognizes outstanding job performances in education and training of members nationally and locally. Elliott R. Hallowell Award Honors the member whose record of service to RETA for the current year merits special recognition and reward. Venneman Award Recognizes an outstanding RETA member for a career marked by leadership and service to the profession and the organization. Felix Anderson Award Recognizes two individuals who have worked behind the scenes at the Chapter level and who are not on the National Board.

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