2021 RETA Breeze Jan-Feb

RETA BREEZE

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION JANUARY / FEBRUARY 2021

Emergency Release Reporting Requirements

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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

Emergency Release Reporting Requirements for Anhydrous Ammonia Refrigeration Faci l ities page 20

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 FromThe Executive Director.......... 6 Job Opportunity RSCS Is Hiring ...................................... 7 Epic Fails Lipstick On A Pig .................................. 8 2021 RETA National Conference Call For Abstracts And More ................. 10 Message From Don Tragethon....... 12 RETA Online Proctored (OLP) Testing Option . ................................ 15 The Shade Tree Mechanic Volume XLVII .................................... 16

Education Corner. .......................... 18 Chapter Meetings . ............................19 Emergency Release Reporting Requirements for Anhydrous Ammonia Refrigeration Facilities . ...................... 20 National Board Report .................... 24 RETA Testing Corner No. 23......... 28 RETA’s credentialing exams and activities 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 © 2021 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

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2020-21 BOARD OF DIRECTORS CHAIRMAN Vern Sanderson, CIRO, CRST, RAI Wagner-Meinert, LLC PRESIDENT Eric Teale, CARO, CRST Danfoss Industrial Refrigeration EXECUTIVE VICE PRESIDENT Keith Harper, CARO Tyson Foods Inc TREASURER Pete Lepschat, CIRO, CRES, CRST Lineage Logistics SECOND VICE PRESIDENT Bengie Branham, CIRO Perdue Farms DIRECTORS Alan Gervais, CARO, CIRO Western Precooling Systems Bill Lape, CARO, CIRO, CRST SCS Engineers David Gulcynski, CIRO Dot Foods Inc. Debbie Koske Calibration Technologies, Inc Edward Johnson, CARO Schwans Global Supply Chain, Inc. Jeremy Murfin AC & R Specialists Jim Kovarik Gamma Graphics Jordan Reece, RAI Lanier Technical College Michael Hawkins Midatlantic Refrigeration, LLC Raymond Urban, CARO Lineage Logistics Ricky Jimenez, CIRO Mericle Mechanical Inc William Ellena Coastal Pacific Food Distributors, Inc COMMITTEE CHAIRS Dascha Whitmore, Marketing Dave Gulcynski, CIRO , Education Dot Foods, Inc. Jim Kovarik, National Conference Gamma Graphics Lee Pyle, CARO, Certification SCS Tracer Environmental Matt Hayes, CARO, Publications TJW Industrial Michael Hawkins, Membership Midatlantic Refrigeration, LLC Jim Barron, Executive Director

FROM THE DESK OF THE PRESIDENT

The unknown of 2021 is on the top of a lot minds these days. I know for me, the closing months of 2020 and the beginning of 2021 have been especially hard dealing with the unknown. I am reminded of a poem by DavidWhyte, The Old Interior Angel. A youthful David was exploring the Himalayas and took a solo side trip where he encounters a bridge over a chasm that was in such a state of disrepair that passage across it looked like certain death. Dismayed and defeated he sat in fear for over an hour until an old mountain woman appeared seemingly out of nowhere, kindly greeted him with a “Namaste”, nimbly moved across the bridge, and disappeared into the distance. David just needed someone to show him compassion and the way to move forward. As we continue into 2021, I am proud to tell you that the RETA Staff and Volunteers have been working hard for you. The Certification Committee just wrapped up the ANSI Annual Application Process and the Education Committee is working hard to get more Virtual Training opportunities available as well as continuing work reviewing, updating, and revising RETA’s Books. The Conference Committee is already deep into the planning for the 2021 RETA National Conference in

Schaumburg, IL and has just called for White Paper Abstracts. The Publications Committee is starting to translate articles into Spanish and recruit new authors for the Breeze and Technical Report. The Membership Committee is restarting its COVID delayed International Membership and Membership Benefit efforts, and the Marketing Committee is finishing up volunteer recruitment. We have some exciting things in the works for 2021 and I am grateful to have all the RETA Family on the journey. “Around here, however, we don’t look backwards for very long, we keep moving forward, opening new doors and doing new things because we are curious and curiosity keeps leading us down new paths.” ~Walt Disney. Namaste Eric Teale, RETA National President

(I greet the God in you.) Eric W. Teale, P.E., CRST National President

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FROM THE EXECUTIVE DIRECTOR

Hello All, Happy New Year everybody! 2020 is a year for RETA’s history books. We started the year strong and on track but then in March everything went sideways due to COVID. RETA HQ has been diligent in regard to changing and keeping up with the virus and regulations. We are keeping RETA strong with chapter Zoom meetings and our committees are doing amazing work. The RETA Board of Directors have been amazing in their work running the Association. We just completed our ANSI/ ANAB annual certification surveillance and submitted it for approval. We had our hopefully one and only virtual conference and we are looking forward to seeing everyone in person at RETA 2021. Our membership is dipping slightly but we are holding strong. Thank you RETAmembers for sticking with us through this rough time. RETA HQ is currently down four employees so please be patient with us as we move through these difficult times. Let’s get the COVID-19 virus under control and eradicated and then we can get back to doing what we do best, Industrial Refrigeration. We need to keep training and we need to keep temperature in our

refrigerated spaces. By doing so we help to keep our food safe and ready for delivery. We must continue to help support each other like the Ammonia Safety Day Coalition that RETA, IIAR, GCCA and ASTI are partners in. This coalition is there to support and train people in our industry through safety days, regional conferences, the annual conference and RETA chapter meetings. We will help each other in regard to natural refrigerants safety and operations training. This is work in progress and there is more information to come in the next few months. We do not know what our future holds, however we are planning our 112th Annual Conference in Schaumburg, Illinois November 9-11 to proceed as an in-person event. The Conference Committee has been diligently planning a fantastic event and we are expecting and hoping that the virus will be under control by November. On a personal note, I would have to say that I truly understand how RETA has made it through a great depression, two world wars, Korea, Vietnam, 9/11, and now COVID-19. It was done only through the quality people we have as members and our desire to support the industrial

RETA Executive Director Jim Barron

refrigeration industry. We have the best people in the world in RETA and it shows every day. So, with that being said I will say thank you from the bottom of my heart for supporting RETA and have a Blessed New Year. Jim Barron

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EPIC FAIL

HIGH PRESSURE RECEIVER

HIGH PRESSURE LIQUID VALVE

LIPSTICK ON A PIG

Look, I get it. If a regulator walks in the front door, send your maintenance guys out the back door with a bucket of paint. We’ve all been there and done that. We want to make the system look shiny and as new as we can get so that the regulator might cut us some slack. However, the issue is what happens when we don’t remove the lipstick, so to speak, and clean up the dirt (in this case, corrosion) underneath. Imagine what a celebrity would look like if they never washed off the makeup that they applied each day. Now take a look around your system. Do any of your pipes or valves, or even vessels, look like those above?

IIAR 6 requires that piping (including valves) and pressure vessels be inspected annually for indications of degradation of the protective coating (i.e., paint). The facility is also required to inspect metal surfaces of piping and vessels annually for pitting or surface damage. If pitting or surface damage is noted, then the remaining wall thickness must be measured. For 11.1.1 *Where pitting, surface damage, general corrosion, or a combination thereof, is visually observed on a metal surface of the piping, deficient areas shall be further evaluated per Sections 11.1.1.1 – 11.1.1.3. Okay, we’ve identified this corrosion or damage. Now what? 11.1.1.1 *Where pitting, surface damage, general corrosion, or a combination thereof, has materially reduced the remaining pipe wall thickness, the piping remaining wall thickness shall be measured using appropriate techniques. Here is where mechanical pit gauges or non- destructive testing (NDT) methods come into play. They are the “appropriate techniques.” piping, the standard states (with my comments in red):

HOT GAS LINE

11.1.1.2 *Where pitting, surface damage, general corrosion, or a combination thereof, has not materially reduced the remaining pipe wall thickness, the piping metal surface shall be cleaned and recoated to arrest further deterioration. Even though the surface hasn’t been materially reduced, we can’t just leave it. We need to clean it up and paint it. 11.1.1.3 Where pitting, surface damage, general corrosion, or a combination thereof, has materially reduced the remaining pipe wall thickness beyond the owner’s established acceptance criteria, the piping shall be evaluated to determine suitability for continued operation. Back to those NDT techniques. But this time, we need some “acceptance criteria.” What does that mean? 11.1.1.3.1 *Where the owner does not have established acceptance criteria for pipe wall thickness from the original design or subsequent calculations, the owner or owner’s

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condition. We know that there is corrosion under there, but it will take more sophisticated NDT techniques to determine the condition. The recommendation of A.11.1.1.2 is what really drive the point home that you cannot leave pipes in the condition pictured above. While visual observation tells you that the pipe has suffered some corrosion. You cannot identify the extent of that corrosion without resorting to non-destructive testing techniques such as ultrasonic thickness measurement or radiometric profiling. Without knowing the extent of the corrosion, it would be unsafe to take a wire brush to the pipe in order to clean it up. It is far better to keep up with your pipe inspections and painting. Identifying light, general corrosion, that has not yet impacted the material thickness, is essential as that is the time to take a wire brush to the pipe, clean any re-paint the pipe (or valve). For vessels, IIAR 6, has some additional acceptance criteria: 10.1.1.1.2 *Where pitting, surface damage, general corrosion, or a combination thereof, has materially reduced the vessel wall allowance, the owner shall proceed in a timely manner with an analysis or using the following criteria to determine suitability for corrosion, the depth of the corrosion shall not exceed 25% of the original wall thickness. 2. Isolated pits may be disregarded provided their depth is not more than 50% of the required wall thickness of the pressure vessel thickness beyond its permitted corrosion continued operation: 1. For line or crevice remaining paint and corrosion off of it, and

designated representative shall establish a replacement thickness that shall not be less than the calculated thickness for pressure containment in accordance with the code or standard in which the component is designed at its design pressure. Here’s how we create acceptance criteria. Time to get an engineer involved. 11.1.1.3.2 Where a pipe is determined to be at or below the owner’s established replacement thickness, the owner shall immediately isolate the pipe from service and proceed with a plan for its replacement or decommissioning (for decommissioning, see ANSI/ IIAR 8) T ime to spend money. Appendix A of IIAR 6 offers some clarification for the normative, or required, language above. A.11.1.1 Pitting implies corrosion. Pitting corrosion is the formation of holes in an otherwise relatively unattacked surface. Pitting is usually a slow process causing isolated, scattered pits over a small area that does not substantially weaken the piping. It could however, eventually cause a leak. Pitting can be measured with a pit gauge or other qualifying technique. General corrosion implies surface rust and/or oxidation staining which, by itself, has not materially reduced the remaining wall thickness. A.11.1.1.1 Surface damage to piping is considered to have materially reduced the wall thickness when the surface damage exceeds the owner’s established acceptance criteria (see Section 11.1.1.3). A.11.1.1.2 Where visual inspection cannot fully determine the condition of the piping, then additional nondestructive testing (NDT) is recommended. Remember that paint that we slapped on the pipe, valve, or vessel? Well, we can’t visually determine it’s

(exclusive of any corrosion allowance), provided the total area of the pits does not exceed 7 sq. in. (4500 sq. mm) within any 8 in. (200 mm) diameter circle, and provided the sum of their dimensions along any straight line within that circle does not exceed 2 in. (50 mm). 3. For a corroded area of considerable size, the thickness along the most critical plane of such area may be averaged over a length not exceeding 10 in. (250 mm). The thickness at the thinnest point shall be not less than 75% of the required wall thickness. If the vessel is deemed to be suitable for continued operation using the criteria above, then it may be cleaned and re-painted. If the vessel proves to be unsuitable for continued operation using the criteria above, then the options

are to re-rate the vessel to a lower design pressure (assuming that this is feasible given process conditions), have the vessel repaired by someone holding an ASME “R” stamp, take the vessel out of the system, or replace the vessel. All of these options are fairly expensive. Much more than a couple of wire brushes and a bucket of paint. So, if you are putting “lipstick on that pig,” be sure to go back quickly and clean it up and repaint it. 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

2021 RETA NATIONAL CONFERENCE

Michelle Robinson, RETA Conference Manager Call for Abstracts and More

C urrently, we have our Call for Abstract out and the deadline has been extended to March 8, 2021. Please submit your abstract online at www.reta. com/page/2021-conference-abstract. We are seeking the following Abstract topic categories: • Management • Compliance • Operations • Engineering • COVID-19 Safety (emphasis on lessons

I hope everyone had a Happy and Safe New Year! RETA’S Conference Committee and I are in full swing and meeting goals for a great upcoming IN PERSON 2021 RETA National Conference on November 9-11, 2021 at the Renaissance Schaumburg

learned in 2020. Such as but not limited to best practices, contingency planning, and/or emergency preparedness, and infrastructure changes.) RETA’s Conference Committee and I will be meeting this month for our 4th time and are making great progress toward our upcoming Conference. We are working diligently on “What’s in it for you” and are focusing on benefits of interest such as updating our website to get you information as soon as possible. We are also finalizing quality time in the Exhibit Hall, Hands on Sessions, Workshops, WiNR (Women in Natural Refrigeration) and Events.

Convention Center in Schaumburg, Illinois.

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We are finalizing our Sponsorship Brochure and Email Advertising Sponsorships and in the process of sending Exhibitor Commitments and Booth Selections to prior exhibitors. Please be on the lookout for an email with that information which have several new sponsorship opportunities including email advertiser sponsorships. If you have not sponsored or been an exhibitor at a previous RETA National Conference and would like more information, please call me any time at 541-497-2955 or email me at michelle@reta.com. Lastly, please SAVE THE DATE for pre-conference activities. Saturday- Monday, November 6-8th, we will have the Review Courses which include the Train the Trainer Course and the CARO, CIRO, CRST, CRES Review Courses. Please note there is a separate fee to register for a review course. Sunday, November 7th, we will have a Chapter Leaders Reception from 5pm-6pm and a Welcome Reception for Exhibitors and Sponsors from 6pm-8pm. Monday, November 7th, we will have Workshops from 8am-5pm, at no additional cost. Monday will also have TopGolf offsite from 1pm-4pm for an additional fee and a WiNR (Women in Natural Refrigeration) Happy Hour Networking event from 4:30pm-6pm. We will end the day on Monday with the evening out and the RETA After Hours Lounge. The RETA National Conference provides a unique gathering of networking, learning, and fun into a single platform. I hope you are making plans to join us in November. If you have any question or need any clarification, please do not hesitate to November 9-11, 2021 and remember to come early for

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MESSAGE FROM DON TRAGETHON I was invited to write a message about the importance of the association, the volunteers, the staff, and board of directors. I want to take this opportunity to discuss the importance of the association and return to celebrate the volunteers, staff, and board of directors. “Celebrate” you say? Yes, more to follow.

What makes the association important? RETA is important because of the work that goes in to meeting the mission statement. RETA’s mission is to enhance the professional development of operating and technical engineers. The people that operate and maintain refrigeration systems are essential to the quality of life for everyone that receives their food from the grocery store or a restaurant. Having access to training and instruction for the safe and effective operation of systems is important to the ones who do the work. RETA is continually working to improve the instructional materials presented in a variety of ways. The certification program serves as the best confirmation of the operator’s understanding of the theory and practices for the technical level being tested.

Another aspect of RETA’s importance is the opportunity provided for people to meet and get to know others. This is done by participating in chapter meetings, taking training classes, or attending conference. Recently my chapter hosted a 30 hour CIRO review course. We met after hours, from six until eight-thirty for twelve nights. The sessions were presented over Zoom. By the time we got to the third session everyone (34 people) were getting comfortable with one another and participated easily answering questions I pose – and more importantly, asking me for clarification about what was being presented. So, here we are, students from Central Coast of California, Northern California, Southern California, the Central Valley of California, and an operator from Fargo, North Dakota. The range of

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QA & “ ” student experience was two years up to above 35 years in the industry. See what I mean about the opportunity? People with varying experiences and tenure getting together to prepare to take an important examination would not have had the

opportunity to learn from one-another if the association did not have a chapter that chose to offer the review session. The students were great about asking meaningful questions during the class. I am going to share a question that came after the last session. A few times during the course I described myself as an old guy who likes to talk about refrigeration. My student wrote: “Going to refer the subject after a quote (old guy reference) from your last session. So I remember answering a question about defrost etc…. The answer was 105 PSIG (hot gas feed into coil) to 75PSIG (back pressure regulator) So at the plant I operate in we keep hot gas infeed at 110 and 60PSI back pressure regulator. Would you be able to tell me if this is wrong? And if so why? Reason I ask is because of the amount of operators we have. They tend to clash when it comes to that, “their settings” One operator of 20 years wants a 120/95 and the other wants a 110/60 and me personally tend to stick around 90/70. But is the 105/75 optimal?”

Brian,

(thermal conductivity of aluminum compared to steel) and the usual thickness of the wall.

Your question gave me pause to think about why certain settings are decided on. Looking back at what we covered over the four weeks of January I can touch on a few topics that we can investigate: – we need to know what the evaporators are made of, especially those that had higher operating pressure values. If the units were steel tubes and hot-dip galvanized fins they would probably operate at a higher pressure because of the thermal conductivity and thickness of the walls of the heat transfer surface. Some older evaporators were made of schedule 40 pipe which is quite thick in heat transfer terms. - It was said that the greater the temperature differential, the faster heat energy would flow. The higher the pressure, the more dense (lbs per minute) would be delivered into the coil. - The time required for injection of hot gas would vary from an aluminum surface

- The defrost relief characteristics would need to be looked at. In the first several minutes of injection there is a significant amount of condensate formed. As the condensate is relieved back to the engine room in the low pressure suction or mid-pressure suction there is a bit of flash gas formed in that return line. As less and less gas is condensed and if the defrost system is a simple regulator (A4A) function set to maintain a pressure, regardless of the refrigerant passing through it being liquid or vapor, it can be that the hp gas injected basically drops a bit in pressure and escapes as an expanding high volume vapor into the lower pressure suction line. This sends a false loading to the engine room that the compressors have to deal with - The settings that the controls are set to typically have to work every time, regardless of humidity and ambient conditions. So, when a set of parameters

RETA.com 13

is found that “works” consistently there would be a reluctance to investigate any tuning up. If reducing the evaporator pressure and the supply pressure is tried — things may happen. - Say that the supply pressure is dropped from 110 to 90. This means there are fewer BTU’s per pound or per cubic foot of vapor provided the evaporator. That can have the result of needing to extend the defrosting time – which could cancel any gains of “efficiency” by dropping the supply pressure. - Same sort of consideration for the defrosting pressure. My training (factory recommended settings) from the mid-1980’s was to set the defrost regulator at 90 psig. We did not have supply pressure control on the inject side of the circuit (kind of dicey – now that we know about hydraulic shock events). So – the rule of thumb was to defrost at 60°F. That was fine for a 33°F vegetable cooler – freezer plants that tried to operate like that in their -20 freezers would put up a fog from the evaporator being defrosted. The fog would get drawn to the closest evaporators still in refrigeration and rapidly ice up as the fog condensed and froze to the surface. If I worked there at your plant, I would generate a written table of the operating parameters including the timed observations of how long of a pump-down is needed before injection starts, how long injection lasts, the depressurize time, the drying time for the surface, etc. The operating pressures would affect the density of the gas and how many BTUs is in the flow of the gas on a per-minute basis. Material of construction would be noted for the evaporators, including wall thickness the distance from the prime surface of the evaporator tubes to the edges of the fins. Some recent evaporators

have sheet type fins where the furthest distance from the prime surface is over 1-1/4” - that is a long way to have to conduct heat energy, especially if the room environment is freezer conditions and not vegetable holding conditions. The goal is to clear the evaporator surface as swiftly as possible AND have a graceful entry and exit from defrost conditions. If the pipes and evaporator do not sway when refrigeration is restored following defrost, that is a good thing. If they go bump in the night – closer examination is needed. It could be that everyone is “right” regarding their preference for control settings. The type of defrost configuration comes into play too. Evaporators that use a ‘float drainer’ device to hold flow back from the evaporator to the engine room – until it is passing liquid – will reduce that false loading effect seen in systems that have a regulator passing refrigerant of any form – at a prescribed pressure. See – there is no easy answer for what is optimum. I would say that a study of all the factors surrounding defrost and evaporator design could lead to a consideration to reduce a defrost operating pressure. The consequences, or effect from the change, would need to be evaluated. If defrost time is extend 15 minutes because the defrost temperature was reduced – was anything improved in the first place? Guess what – our conversation here is going to be incorporated into a RETA Breeze article. I’ve been asked by HQ to write an article that expresses the value of association to members. The existence of the association set up the opportunity for us to meet and to learn from one another. The review course gave the opportunity to open the discussion of the numerical

factors involved in operating a system. The conversational exchange (Q/A) during class allowed for further opportunity for students to ‘get it’ and to consider their own operations. I won’t be mentioning names or companies – just that a student followed up on the comment of the instructor and asked the deeper question about why different operators would have differing opinions about the right settings for defrosting. Understanding why a certain set of parameters is selected for an operational purpose is as important as those values being right for the conditions at the time. By understanding what is happening in the system – a system upset in the making may be recognized and resolved before a bad thing takes place. I hope this helps – I’d love to see your reference table of evaporators, materials of construction, operating parameters, and what would be predicted if a control setting were changed from one value to another. Taking such a step would certainly give defensibility for the requirements of a management of change. I like to have a 15psi differential between the controlled supply gas pressure and the condensing pressure in the evaporator. So, 85/70 is a value set I look for. This is for evaporators with aluminum surfaces. The 15 psid gives pretty steady flow both in the going in and coming out valves. This also means that the pipe diameter and distances run are favorable as well. Much to consider when evaluating these operational conditions. To me, the importance of the association is that the association exists, and the staff and volunteer leadership understand the mission and work tomeet the mission with each contact with a member, or non-member.

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RETA ONLINE PROCTORED (OLP) TESTING OPTION

RETA expanded its test delivery options to allow candidates to take CARO, CIRO and CRST online with a personal computer and an external webcam. Online Proctored (OLP) testing will expand access to these RETA exams. Access to OLP testing begins by completing the application process for CARO, CIRO or CRST and paying all required fees. Candidates will also need to submit the application for Online Proctored (OLP) testing with their CARO, CIRO or CRST application. Most RETA OLP candidates will take their test at home on a personal computer with an external plug-and-play USB webcam.

OLP exams must meet some test security requirements that are not needed in centers that give RETA’s onsite in person proctored tests. RETA OLP exams require these additional security steps. Facial recognition software matches the candidate’s image during registration to another on the day of the test. A government-issued photo ID such as a driver’s license also is required and is compared to these facial recognition images. No paper is allowed during the test. Notes and formulas must be entered on-screen. No breaks are permitted. Leaving the test area for any reason ends an OLP exam. Candidates who are uncomfortable with these added security requirements may

prefer to take onsite proctored exams in a RETA test center where they are available. RETA’s OLP testing meets the same ANSI 17024 Standards for test security as its onsite-proctored tests. RETA worked with its test delivery vendor, Kryterion, to assure that all ANSI 17024 Standards are met in RETA OLP testing to maintain its ANSI accreditation. Further information about Online Proctored (OLP) Testing is available in the CARO, CIRO and CRST application handbooks and the application for Online Proctored (OLP) Testing. These documents can be found on the RETA website under the Certification tab You may also contact certification@reta.com for more information.

RETA.com 15

SERVICE

The Shade Tree Mechanic! – Volume XLVII I want to be Jimmie Johnson

Since Jimmie Johnson wrapped up his last full time season in NASCAR and all, somethin struck me with what that announcer fella said. “Jimmie has earned the right to do what he wants”. So’s I gotsta thinkin, how can I earn the right to do what I want? At my age, 7 NASCAR Cup Championships may be beyond my reach. Quite frankly I don’t want to be away from the bathroom for 5 hours. Not to mention I get nervous pulling into the church parking lot. 200 MPH at Degga, no way! I thought about hittin the lottery. But that hasn’t worked. I just figure there has to be something I can do. Then it hit me. If I can get someone else to do the things I don’t liketa do, then I will get to do the things I want. So I’m lookin for volunteers. LOL (the kids tell me that you should picture me belly laugh’n when I use this LOL thing) Well while I’mwaiting for someone to raise their hand to volunteer to do my stuff, I’m workin on a backup plan. I’m trainin my operators to do the stuff I don’t want to do anymore. For too many years, I’ve thought that I would just do all the stuff. Either because they were busy, or they didn’t know how, or I thought they wouldn’t do it right. Sometimes, I’d do stuff just so I had an excuse to avoid a meetin. (you’ve done it!) No more. If they don’t

know, I’m gonna teach them. If they do know, I’m gonna let them do it. I haven’t figured out how to get themmore time, but I’ll get there. 1st off, it’s time for someone a lot younger than me to pull and clean the mist eliminators on my condensers. I don’t climb so well anymore, but I fall better than ever. I wear all my PPE and I don’t get hurt, but dam it’s embarrassin. So this year, I’m teachin someone else how to do it. It’s not hard. Heck I learned by readin the manual (and a little trial and error). Changin relief valves on top of our big vessels. (See the fallin note above). But that’s somethin that all of my team can do. We have manifolds and I’ve taught them all at least twice how to use them. I just always did it myself. Not this year, I may supervise and I may watch, but I’m not carryin the wrench. Movin the chemical pump to a new barrel. I always feel like it’s Christmas when I open a new barrel. But there is no reason that they have to wait on me to change it. I’m gonna to let them have some fun. Anythin and everythin havin to do with offal pumps, tanks, or pipe repairs. I always did it cause I know I would smell bad when I was done and I wanted to keep the others from smellin bad. But maybe one of the other guys wouldn’t mind smellin like offal. You know, cat people should do that job. Cat’s love the smell of offal. I imagine that if

Bobby went home smellin like offal Mr. Whiskers may just think he was the best pet owner ever. May leave a mouse on his pillow or sumptin. Verifyin line breaks. I know I have a whole slew of fellas that have been doin line breaks for 10 years. It’s time to let some of them check everythin and signoff on the form for the younger guys. Dumpin out the rain gauge. I don’t know why, it’s always been me, but dang, that’s getttin to be a long walk. And to tell the truth there are days I forget what it said before I get back inside to write it down. Some of my supervisors can lead shift change meetins. I still want to be involved, but it seems crazy that they haveta tell me what happened so I can turn around and tell them and the rest of the crew the same thin 15 minutes later. I’ll find out what happened when the rest of the team does. If there’s a serious issue happenin, chances are they will have called me already. And that’s another thing. Maybe I don’t need to be the first one to go in when we have an alarm. I don’t think I have more than 3 guys who have dead started my system. Maybe I need to teach some more. Spread the calls around a little. Doin what I want don’t mean I’m going to be lazy. It just means I should think about what I want to do. Jimmie Johnson deserves to drive

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whatever he wants to drive (well, so long as it’s a Chevrolet). So what do I think I deserve to do? #1 I deserve to be the best employee I can be. I’ve worked here a long time and they have been very good to me. I want to do what they need me to do. Not that I haven’t tried to do that before. I have. But I also did some of the stuff that I should have turned over to someone else. Thangs that took time away fromwhat they needed (or thought they needed) me ta do. And another thing, I don’t always have to be that crotchety old man that stamps his feet and gets his way because he said so. Maybe I can be that old crotchety man that takes the time to teach everyone to make the right decision.

#2 I deserve to finally take the time to convince those bean counters why all of my capital projects should be approved. #3 I deserve to be able to get supper before it’s cold. And I should probably add that my ol lady deserves to only have to cook supper once per day. #4 I want to be the one to recruit new operators. I know them HR people gather resumes, that’s great. But maybe with this new so-chia-al media on my phone, I can do some talkin on the internet. Find the kids some more help. #5 I deserve to finally take the time to fix that misspelled word on the control panel. “Recievedr”. What the heck was I thinkin that night?

#6 I deserve to pass on what I’ve learned. Let’s face it I’m closer to a box than most. I want all of the trials and tribulations I’ve been through to mean something. I want that new kid to avoid some of the hardships I’ve endured. His life will be better if he doesn’t need to make the mistakes I’ve made. So I need to take the time to do some more trainin. Maybe I deserve just a little more time under the shade tree. The shade tree grows outside of the little town of Broughton, Ohio. Where everyone is always welcome, the beer is always cold, and something is always needin fixin.

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Education Corner In 2020 RETA published the long-awaited revisions of Industrial Refrigeration ONE and Industrial

In 2020 RETA published the long-awaited revisions of Industrial Refrigeration ONE and Industrial Refrigeration TWO . Both are now available in print and online at RETA.com. Basic Electricity TWO – Ladder Diagrams is in the final stages of editing and approvals. Look for it online and in the bookstore very soon. Controls ONE - Also coming soon, (as in, still in committee and making good progress) is a long-anticipated revision. Completely redesigned to help the operator make sense of controls, from what is inside the control, to how controls “think”. From the earliest days when the operator was the control system to electromechanical controls, to modern computerized AI and MMI. Look for it in the late spring. Continuing Education – (PDH hours) COVID has caused problems for those

wishing to keep their certification renewal requirements current. Chapter meetings and conference cancellations, lockdowns, and shutdowns, add to stress. Fortunately, RETA Members can earn necessary PDH credits by enrolling in the RETA online training and testing site. For further information please visit www.reta.com. On a personal note - January marks one year for me as your education coordinator. It has been my honor. Happy NewYear everyone. Each new year provides new opportunities and new challenges. Although I am not sure we can beat 2020 for “new” and“challenges” then again “opportunities”presents itself anew. Strap in, Hang on. Vince Grindel Education Coordinator

Refrigeration TWO. Both are now available in print and online at RETA.com.

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CHAPTER MEETINGS

Chapter meetings are happening somewhat cautiously or virtually, but they are indeed taking place. Meetings that used to be in person have changed to a virtual format. Many meeting platforms are used including ZOOM, GoToMeeting, and Skype. If you need to earn Professional Development Hours and/or have a desire to learn new and innovative ideas, you are encouraged to visit www.reta.com and check out the Chapter & Event calendar for meetings and other events. Meetings and events are open to all RETA members regardless of Chapter affiliation, but seats are generally limited. As a RETA member benefit it’s a great way to obtain education without travel, traffic, meals, or COVID restrictions. Don’t detour if a different Chapter is hosting the meeting , grab a seat and a bowl of popcorn and enjoy the presentation.

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EMERGENCY RELEASE REPORTING REQUIREMENTS FOR ANHYDROUS AMMONIA REFRIGERATION FACILITIES.

T HIS article will try to clarify these requirements and offer some guidance for compliance with these regulations. The two primary regulations that govern release reporting are the Emergency Planning and Community Right to Know Act, otherwise known as EPCRA, and the Comprehensive Environmental Response, Compensation, & Liability Act, otherwise known as CERCLA. EPCRA was passed in 1986, as part of the Title III Superfund Amendments and Reauthorization Act (SARA) in response to concerns that were raised by the methylisocyanate release in Bhopal, India, that killed several thousand people. These concerns centered on the potential safety and environmental hazards that could result from the storage and handling of toxic chemicals. It includes requirements for annual reporting (EPCRA Section 312) of the

Most facilities that utilize anhydrous ammonia for their refrigerant are aware that they must report emergency releases of anhydrous ammonia to various regulatory agencies. However, they are often confused as to the specific requirements to which they are subject.

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locations and the amount of hazardous chemicals present at your facility during the previous calendar year to state and local emergency officials. These requirements, known as Tier II submissions, were detailed in an article in the Breeze last year. It also includes annual requirements for reporting releases and usage (EPCRA Section 313) of toxic chemicals at your facility during the previous calendar year to state and local emergency officials. These requirements, known as Form R submissions, are outside the scope of this article. The section of EPCRA that this article will focus on is Section 304, which details the emergency notification requirements upon discovering a reportable release of toxic chemicals. Before we look at the EPCRA reporting requirements, it is important to discuss CERCLA. CERCLA, otherwise known as Superfund, was enacted by Congress in late 1980. The law allowed the Federal Government to tax chemical and petroleum facilities as a result of chemical releases to provide funding for cleaning up abandoned or uncontrolled hazardous waste sites. It was passed in response to the national attention received when toxic waste dumps such as Love Canal and Valley of the Drums came regulations, CERCLA also includes provisions for emergency response to hazardous chemical releases. With the passage of SARA, CERCLA was amended to align with the newly created EPCRA regulations regarding emergency notification of releases. So, what is required for emergency notification of chemical releases? First, the facility needs to identify any chemicals that they use or store on-site and determine if they are listed under EPCRA and CERCLA. These lists of chemicals are found in Appendix A or B of 40 CFR part 355 for EPCRA and in Table 302.4 in 40 CFR Part 302 for CERCLA. Ammonia is listed in both regulations as having to light. In addition to the compensation and liability

The facility needs to identify any chemicals that they use or store on-site and determine if they are listed under EPCRA and CERCLA.

Response Center (1-800-424-8802; in Washington, DC 202-267-2675; the facsimile number is 202-267-1322).” Section 355.33 under EPCRA states that the release of a reportable quantity (RQ) of an EHS or CERCLA hazardous substance within any 24-hour period triggers the emergency release notification requirements. So, the 100 pound release is actually a rate of 100 pounds in 24 hours under both regulations. Now that we know the release rate that triggers the emergency notification, we have to determine whom we have to notify and within what time frame. CERCLA is clear. If 100 pounds or more of anhydrous ammonia is released within 24 hours, then the National Response Center (NRC) must be notified (800-424- 8802) immediately upon becoming

a reportable quantity of 100 pounds. Note that the threshold planning quantity of 500 pounds for ammonia under the EPCRA regulation sets the threshold for submitting Tier I & Tier II information. Now that we have the threshold quantity for reporting releases, we have to determine if this is the total released, or within a certain time frame. Section 302.6(a) under CERCLA states that “Any person in charge of a vessel or an offshore or an onshore facility shall, as soon as he or she has knowledge of any release (other than a federally permitted release or application of a pesticide) of a hazardous substance from such vessel or facility in a quantity equal to or exceeding the reportable quantity determined by this part in any 24-hour period, immediately notify the National

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aware of the release. The challenge is coming to grips with the word “immediately.” While there is no definition of immediately in the regulations, it has been determined through litigation that immediately is accepted as “within 15 minutes of becoming aware of the release.” Under EPCRA, if the RQ of ammonia is exceeded, then the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) for the facility location must be notified. Section 355.43(a) states, “You must provide the required emergency release notification information described under §355.40(a), immediately.” Note that the EPCRA regulation also uses the term “immediately.” The challenge to the EPCRA rule is that the creation and administration of the SERCs and LEPCs were delegated to the states. What this means is that each state has differing requirements for notification. Some even have lower thresholds for notification. For instance, the state of California requires that the Local Emergency Response Agency, often the local Fire Department or 911, the Local Unified Programs Agency, or UPA, and the California Governor’s Office of Emergency Services be notified of all significant spills or threatened releases of hazardous materials. It is up to a facility in California to work with their UPA to determine specifically what releases need to be reported at the local level. In Minnesota, notifications are made to 911 if there is danger to life or property and all reportable spills (MN uses the Federal threshold of 100 pounds in 24 hours) must be reported to the Minnesota Duty Officer. In Massachusetts, the threshold for reporting an ammonia release is 10 pounds released in 24 hours. If this threshold is exceeded, then the facility must notify 911 and the Massachusetts Department of Environmental Protection. These examples serve to reinforce the need to perform some legwork and

... it has been determined through litigation that immediately is accepted as “within 15 minutes of becoming aware of the release.”

develop proper reporting procedures BEFORE a release occurs. So, how does one determine if the release has exceeded the threshold? Often, this is extremely difficult, and with the immediate notification requirement, there is no time to measure parameters and perform calculations. Many facilities choose to report ALL releases of ammonia to the regulatory agencies. While this will ensure that no fines will be levied for not reporting required releases, it will potentially increase regulatory scrutiny. Often, facilities will choose to create criteria to minimize over reporting of small releases that do not meet the threshold, but ensure that virtually all reportable releases are reported properly. For example, the following criteria could be used to cover the Federal threshold for reporting:

• Is there a measured PPM over IDLH or PPE limits, whichever is lower (around the filter cartridge) • Is there a pool or spray of liquid NH3? • Is there a visual vapor cloud of NH3? (Note that wisps from a valve packing do not constitute a cloud) • Did a safety relief valve lift, releasing NH3 to atmosphere? (This is often the most likely cause of the public reporting a smell of ammonia, and if is often very difficult to gauge the release amount unless someone was standing in view of the safety relief valve when it lifted.) • Did the leak of NH3 occur in a condenser? (This type of release is usually well over 100 pounds but it is often difficult, if not impossible to determine a rate of release.)

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