2022 RETA Breeze March-April

RETA BREEZE

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION MARCH / APRIL 2022

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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 jim@reta.com Sara Louber Senior Director, Office Operations sara@reta.com Stephanie Date Marketing & Events Manager stephanie@reta.com Dan Denton Chapter Relations Liaison ddenton@reta.com Vince Grindel Education Coordinator vince@reta.com 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 © 2022 Refrigerating Engineers & Technicians Association.

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INSIDE THIS ISSUE

Message FromThe President........... 4 Call For Nominations....................... 6 Cyber-Security In Automated Industrial Systems .......... 8 The Shade Tree Mechanic volume XLIX ....................................... 13 The Reta National Conference: Get your PDH Credits in one shot .......... 14 Education Corner. .......................... 17 Ammonia Labeling & Signage RAGAGEP Update with a Side of Epic Fails. ......................................... 19 EPA General Duty Clause Inspections 51 pounds of vapor released ................ 21

40 years ago in RETA History The 1982 Spring Conference ................ 22 Ken Williams Starting a dialogue .............................. 24 Q&A.................................................. 25 The RETA Mission & RETA Chapters................................ 26 RETA Testing Corner No. 29.......... 28 Responding to False Claims about RETA Exams Certification..................................... 30 Honor Roll

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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2021-22 BOARD OF DIRECTORS CHAIRMAN Aer Teale, CARO, CRST Lineage Logistics PRESIDENT Keith Harper, CARO Tyson Foods Inc

FROM THE DESK OF THE PRESIDENT

EXECUTIVE VICE PRESIDENT Bengie Branham, CIRO, RAI SCS Engineers TREASURER Michael Hawkins, CARO Midatlantic Refrigeration, LLC SECOND VICE PRESIDENT David Gulcynski, CIRO Dot Foods Inc. DIRECTORS Alan Gervais, CARO, CIRO Western Precooling Systems Andrew Palomar, CARO APCCO Bill Lape, CARO, CIRO, CRST SCS Engineers Debbie Koske Calibration Technologies, Inc. Edward Johnson, CARO

CONSENSUS Consensus is defined as a general agreement or accord, or an opinion held by all. When you think about it, consensus is a rare thing. Look at national politics, and it is hard to believe that we the people could agree on anything. Yet, we greatly value consensus. When we work together on teams (or boards), we strive to reach consen- sus because it is considered to be the ideal outcome. It really does feel good to get everyone together in the same place and have everyone headed in the same direction together. As the Old Testament prophet Amos said: “Can two walk together, except they be agreed?”. However, there can be a downside to consensus-building.

Keith Harper, RETA National President

Schwans Global Supply Chain, Inc. Gordon Rascoe, Jr, CIRO, CRST, RAI ConAgra Brands Jeff Lublin Kolbi Pipe Marker Co. JeremyMurfin AC & R Specialists Jim Kovarik Ricky Jimenez, CIRO Mericle Mechanical Inc Victor Dearman, Jr. Peco Foods, Inc COMMITTEE CHAIRS Certification: Lee Pyle, CARO SCS Tracer Environmental Education: Eric Girven, CIRO, CRST, RAI SCS Tracer Environmental Marketing: Dascha Whitmore Stellar Membership: Michael Hawkins, CARO Midatlantic Refrigeration, LLC National Conference: Jim Kovarik Gamma Graphics Services Publications: Ed Johnson, CARO Gamma Graphics Services Raymond Urban, CARO Lineage Logistics

Abba Eban is quoted as saying “A consensus means that everyone agrees to say collectively what no one believes individually.” The desire to achieve consensus can discourage dissent, and lead to “group think”. Even the most well-intentioned efforts at achieving consensus can stifle meaningful conversation that could lead to a more favorable outcome. Given how difficult it can be to reach consensus intentionally, how likely does it seem that it would just happen? Granted, there are things in our respective realms of experience we would probably all like and others we would try to avoid. I’m sure we would all like a raise. We might all agree that we would not be thrilled to have to go to the dentist. However, the more complex and nuanced the question posed, the less likely we are to see full consensus. For RETA’s Certification programs, we employ the services of Dr. Ron Rodgers, at the Employment Research & Development Institute. You have doubtless read some of his articles on RETA Certification in the RETA Breeze. In fact, he wrote an excellent article in the last issue of the Breeze reporting the results of the CRST Practices Survey, which was conducted in the fall of 2021. The full CRST Practices Survey Report, was presented to the RETA Board of Directors in Schaumburg, IL, and I can’t help but offer my two cents worth. The responses to a particular question caught my eye:

Schwans Global Supply Chain Executive Director: Jim Barron

There were a total of 188 Technicians, Service Managers, supervisors, and operators who responded to the survey. Every last one of them, when posed with a question about how

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RETA Certification impacted refrigeration system operations responded that it “Increased operator awareness of safety requirements”. Among these 188 respondents, who were mostly seasoned professionals, there was a consensus that RETA Certification increased awareness of safety requirements. Think about that for a second. These are opinions formed from experience and observation. Every last one of the respondents recognized something different in individuals who held RETA Certification. Something that set them apart. They were noticeably more aware of safety. They sound like the kind of people that I would prefer to work with. Wouldn’t you agree?

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Venneman Award Recognizes an outstanding RETA member for a career marked by leadership and service to the profession and the organization.

The following awards will be given out at the annual Conference in Schaumburg, Illinois this November. They are named in honor of past RETA members who exemplified a specific strength that benefitted the RETA membership and our industry either through teaching or leadership or service. Identify who that special RETA person is 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 August 31st, 2022 in order to give the awards committee adequate time to consider the nominations. CALL FOR NOMINATIONS ANNUAL AWARDS

Elliott R. Hallowell Award Honors the member whose record of service to RETA for the current year merits special recognition and reward.

Guy R. King Memorial Award

Recognizes outstanding job performances in education and training of members nationally and locally.

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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Automation and Internet control of facilities are becoming commonplace in the industrial sector; plants and grids that previously required manual oversight and teams of skilled engi- neers can now be controlled from hundreds of miles away by individuals or even automated systems. The benefits of automation and control are massive and the industrial space is quickly moving to adopt them. Errors and accidents will become ever more rare as the indus- try becomes greener, all while costs associated with industrial facilities decrease. However, there is a downside to ease of access and control – a threat that bad actors will suborn industrial facilities and the processes used to control them, just as they do other Internet-connected applications.

CYBER- SECURITY IN AUTOMATED INDUSTRIAL SYSTEMS

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Ransomware One of the largest and most dangerous classes of cybersecurity events is ransom- ware. Ransomware takes connected assets and holds them hostage by encrypting data or control systems and refusing to release the keys used to lock them unless a ransom is paid. (And, just as with most ransoms, whether or not the attacker will liberate the asset after receiving payment is question- able.) In some cases, ransomware attacks have been foiled by clever security teams exploiting flaws in the encryption methods used by attackers – or by government agencies intervening on behalf of the victims. Such defenses are unfortunately unreliable by their very nature. Cybersecurity experts recommend continu- ous read-only backups and rapid, well-tested restoration procedures to fully protect against ransomware attacks. Even if a database is encrypted by an attacker, if it can be restored using a point-in-time backup directly before the encryption event, the attacker's efforts are worthless. Similarly, compromised control systems are easily restored if a robust procedure for recovering those systems has been tested and per- formed prior to an incident. While an attacker might briefly have control, they ultimately have no leverage over the organization they are attempting to ransom. Of course, these defenses presume an infrastructure that is already highly decen- tralized across multiple geographic regions and failure zones. Backups are meaningless if attackers can alter or delete them; control system recovery requires a working copy of the control system and a reliable, well-tested procedure to restore it. Plans such as these are real requirements for connected industrial facilities, at least as much as any other on-site safety and control. Malware The vectors for ransomware are numerous; a bad PDF downloaded and opened, an unpatched operating system flaw exploited, a compromised USB connected to a running system. Because there are so many potential avenues of delivery, foiling malware in a generalized manner is extremely difficult. Nevertheless, effective anti-malware strategies exist. Reducing attack surfaces as much as possible, applying layers of security

Classes of attacks that were formerly exclusively the purview of Internet applica- tions like Facebook or Twitter could become commonplace to our industrial infrastruc- ture; ransomware attacks on oil processing facilities, spear phishing on operators of electrical grids, and malware on industrial computer systems are some examples of the risks associated with this transformation that have already occurred to multi-billion dollar companies in the industrial sector. Luckily, well-established Internet security protections already exist to mitigate these threats. The industrial space has benefited from a cautious and conservative approach to adopting new technologies, and reason- ably so – no one wants the software running electrical grids or refrigeration facilities to have defects when tried-and-true (but older) technologies enjoy the benefits of stability and wide adoption. And a crucial component of this more conservative approach was air-gapped systems. Twenty years ago, air-gapping was the final word in cybersecu- rity; unfortunately, as other sectors have now realized, unconnected systems have their own vulnerabilities. They are difficult to update and administer, and yet can still be compromised by clever attackers – and attempting to reassert control over such systems is extremely difficult (or even impossible). The future requires connection and control, and security delivered seam- lessly at industrial facilities by experts. The necessity of connected control systems, and the reality of Internet attacks against those systems, forces the industrial space to move rapidly to adopt new solutions to these new problems. Fortunately, these are solutions that already work well in other connected industries that the industrial sector can adopt. With proper training and adoption, secure systems and processes that are highly resistant to attack can be created to serve industry just as well as they do social media, finance, healthcare, and even the government itself. It behooves us to have an understanding of the risks that industrial facilities face from the rise of automation and Internet control. As mentioned, these are broadly the same risks that other sectors of the economy have had to contend with as they have moved towards automation and connection themselves; they are ransomware, malware, phishing, and lack of processes and controls.

and isolation to all outward-facing systems, and implementing real-time observability so that attacks can be perceived and reacted to in their initial stages are all crucial tools in the fight to secure systems from bad software. Of these, reducing the attack surface is one of the fundamental principles of cybersecurity. A database not accessible from the Internet is inherently more secure than one that is; an operating system with all extraneous software removed is much more desirable than a generic commercial installation. When designing systems that are intended to be connected to the Internet, it is impor- tant to consider from the very first steps what should be accessible and what should be firewalled away. Still, even inaccessible systems should be secured. Air-gapping is no guarantee of security. Layers of protection are crucially “CYBERSECURITY EXPERTS RECOMMEND CONTINUOUS READ-ONLY BACKUPS AND RAPID, WELL-TESTED RESTORATION PROCEDURES”

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important, so that the failure of one layer does not compromise the entire system. And one of those layers should certainly be robust anti-malware defense software. Previously termed "anti-virus software," these tools have evolved into a complicated and predictive suite of processes called "endpoint security" or "monitored detection and response." In lieu of simply isolating viruses, endpoint security can ensure the integrity of running processes and files, disable the most common vectors malware uses to gain control of systems, and provide real-time metrics and real-time responses to control- lers continuously monitoring systems. Observability and control are of the utmost importance to any layered security approach. In the event of total security failure, where an attacker successfully introduces malware to a running system, operators must know immediately that such a breach has occurred and have robust tools to counter it. Software controlling industrial facilities must not only alert on penetration of any layer; a knowl- edgeable security team is required to respond to suspicious events with fine-tuned controls that allow individualized responses on an extremely rapid timeframe. Phishing Protecting systems from unauthorized entry is critically important – but what about protecting systems from authorized entry? Sophisticated social media attacks are still some of the most widely-used tools to obtain access to secure systems. For example,

calling a team member and pretending to be tech support and requesting their password; or giving an operator a nefarious login portal into which they attempt to login. Tragically, even less sophisticated attacks are often successful. Most passwords are still some combination of a single English word or name and two digits (usually a birth year). A simple dictionary attack can frequently brute force a password and allow an attacker authorized entry into a system. While there are many complicated technical solutions to security, the solution for phishing is a human one. Operators require training and proper tools to defend against these attacks. Password policies requiring strong, unique passwords are a start – even better is supplying employees with password management software that enforces those policies. Multi-factor authentication is a critical tool in preventing an attacker who obtains a login from successfully using it. But nothing beats frequent security seminars with strong and simple messaging. "Never tell your password to anyone" is a maxim that cannot be repeated enough. Similarly, creating channels to report breaches and respond to them rapidly is an unfortunate necessity. A company's security team needs to be accessible and responsive. Creating open lines of communication between employees and security is an excellent first step to reporting incidents, but even people outside companies need a verifi- able and secure way to report security flaws. A simple bug bounty program can be a surprisingly effective tool to turn potential

attackers into responsible reporters, and a security incident into a closed avenue of attack.

Process and Controls Robust backups; layers of anti-malware software; an excellent security training program. What good are these strategies if they are not used? How can one say that an expensive security system is functioning properly when an employee leaves a door ajar, uses an operating system that has not been hardened properly, or receives a file with an unapproved email program? The ideal security program must prevent process failures due to a lack of documenta- tion, training, and standardization. Processes and controls are an often overlooked component of a complete security story that is as crucial as anti-mal- ware software. There are multiple security organizations and guidance frameworks that organizations can use to audit their security controls – and even better, the output of these frameworks is robust documentation and training materials that employees can use to do their jobs safely and effectively. For a company following the path of standardization and controls, a third-party auditor is a vital business partner. Being able to prove compliance, both to external clients and internal security teams, multiplies the effectiveness of an invest- ment in cybersecurity. Conversely, an

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into the future. The industrial sector is moving towards cyber-secure cloud control platforms. As companies begin to embrace these solutions it’s important to know exactly what’s important: 1. Make sure these platforms are controlled and managed via a SOC2- compliant secure development process. 2. Use secure remote access providing a secure login provider via Single Sign-On. 3. Keep all clients siloed from each other. 4. Provide control via a facility-located local dashboard in case there’s a loss of Internet connectivity or cloud downtime. 5. Make sure a server-side agent is validating control commands. 6. Create role-based access control for operators and users. Operator can have different levels of access, from“read- only” all the way to total control “admin”. 7. Log all commands from operators/users to create a chain of accountability. 8. Use full-disk encryption and encrypted communications. 9. Make sure the platform is continuously logging, metrics auditing, and alerting. Knowing how to move forward during this period can be somewhat daunting, and I hope this helps.

expensive security program without standardized processes and controls is as useless as a bank with a backdoor into its vault. Most process frameworks require vendors to be audited carefully, which is a task everyone – but especially industrial facilities – must take extremely seriously. Vendors with connections to facility controls or sensitive data can be backdoored or suborned to gain access to those resources; ensuring that vendors are strongly compli- ant with a well-known security framework that they consistently maintain is a prerequisite to a strong vendor relationship. As a starting point, at the very least, a vendor should: • Have a information security program that includes policies that, upon signing an NDA, they should be happy to disclose • Use two-factor authentication internally and provide it externally for all client- facing resources • Be SOC2 Compliant (or another equivalent framework) • Train employees annually on cybersecurity threats Evidence of these controls is a very strong indicator the vendor in question takes

security seriously enough to be trusted with industrial systems. Cybersecurity attacks – ransomware, malware, and phishing – are continuously evolving and changing. While it can be frustrating to hit a moving target, as industrial control systems become more connected and accessible, it is a target they cannot afford to miss. Happily, robust solutions and strategies to mitigate Internet attacks are already deployed in other sectors; said solutions can be easily adopted into automated industrial control systems. In the end, however, the effectiveness of these solutions is limited by how uniformly they are implemented. Proper Internet security, standardization, and control are now every bit as important as any other industrial safety tool. By looking to other sectors of the economy that have been transformed by Internet connectivity and accessibility, industrial solutions can find a path to the efficiencies promised by remote control and automated systems that are still safe and secure. Summary Within our industry, the discussion has been around the right Insurance policy. The discussion needs to shift to understanding the tools and processes needed as we move

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SERVICE

The Shade Tree Mechanic volume XLIX

Diggin’ Dirt

Now I have a first-class mess. And why? I got stuff ta do! Stuff that don’t involve two knucklehead maintenance boys. I don’t even understand why they ran their mouths. Heck they bowl together every Friday night. But now I have to play peacemaker, like that Judge Judy lady. I’m going to sit them down and explain a few (Dale) Carnegie things to them. First of all, give everyone a reputation to live up to. If you have an all-star reputation you tend to act like an all-star. If you have a reputation of being a screwup, then you probably will be a screwup. Let’s face some facts, you want to work with an all-star! Your job is easier when you work with all-stars! If stuff isn’t breaking, your life is easier. If there isn’t a lot of rework going on, your life is easier. So, give your co-work- ers a reputation to live up to. Second, “If you don’t like my work tell me. If you like my work tell someone else.” It’s an old contractor saying. It may have been on more yellow page ads than any other phrase. That means if you think I screwed up tell me. That way I can fix it now and learn how not to do it in

look better to the receptionist lady, but in the end, you look like someone who can’t be trusted. Everybody loses. Jim McMahon never had to worry about Mike Singletary tackling him when his back was turned. If I think your gonna tell everyone in the plant, every time you find a mistake in my work, I don’t want you around. You’ll can just get! So Jimmy, Bobby and I are gonna have us a sit around the shade tree and discuss all of this in great detail. Hopefully, we can mend this and get back to making things other than our relationships cold again. 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.

Watching the NASCAR race from Bristol, Tennessee last night, it struck me that NASCAR drivers aren’t the only ones who like digging up dirt. Some of the boys in the maintenance shop like digging dirt too. Take the other day for example. Jimmy was working on a refrigerant pump. We keep losing seals in this one. Well Bobby rebuilt it a month ago. Now I don’t know if Bobby rebuilt it correctly or not. It ran pretty darn good for a month. Maybe he did, maybe he didn’t. The pump is getting some age on it and maybe that ain’t help the seal life none. Regardless, when Jimmy tore it down, he found a piece of gasket. I don’t know if it was left during the rebuild or maybe if maybe it came loose and got sucked in the pump. It doesn’t matter at this point. Just fix it. Well Jimmy fixed it. Then he decided to dig a little dirt on Bobby. If Jimmy had talked with Bobby and told him about the bits of gasket, I wouldn’t have had a problem with it. I understand that there are times that things need to go to the boss man too. But hopefully, the guys get things squared away without me. But you know who he told? Everyone, everyone but Bobby and me. He even told the receptionist lady. She proceeded to tell Bobby’s girlfriend, who told Bobby. Then things got mighty uncomfortable. Bobby then proceeded to bring up everything Jimmy had done wrong since they started working together 10 years ago. But Bobby didn’t bring them up to Jimmy. Oh no! He decided to bring it up to everyone else. Including the receptionist lady, who told Jimmy.

the future. If you think I did a good job, feel free to tell my boss. It’s a great policy Bobby and Jimmy need to adopt it. Third, never make your teammate play defense. I know that sounds odd, but normally you only score on offense, so your team should always try to be on offense. When you attack a teammate and they

need to defend themselves, they are on the defensive, no one scores. You may think you

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CONFERENCE CORNER

THE RETA NATIONAL CONFERENCE: GET YOUR PDH CREDITS IN ONE SHOT By Stephanie Date, RETA Marketing & Events Manager

condensable Gasses • HowWell Do You Know Your Contractors? • Predicting the Impact of an Ammonia Release in Real Time Using ALOHA • Demystify CUI - How to Predict and Pinpoint Threat to Your Piping Engineering Topics • Ammonia Relief System Design - A Guide to the ANSI/IIAR 2-2021 Relief System Requirements • Summary of Ammonia Refrigeration Codes and Standards • De-mystifying Vacuum Cooling Additional Workshops and Courses- Preregistration is required for the following: • November 5th-7th Train the Trainer

One thing the RETA National Conference has that is hard to find anywhere else, is the opportunity to gain an abundance of PDH Credits all in one shot! Not only that, but you can also earn them in a variety of ways from traditional presentations, workshops,

have been reviewed and graded by our Technical Committee. There were many very well thought out Technical Topics, that made the grading process rigorous. I am excited to announce our Technical Topics for 2022: Compliance Topics • Optimizing Your Remote PHA Experience • ER Ventilation Proving Compliance the Right Way • Compliance Audits in a Post-Pandemic World (Recent Changes in IIAR Standards) Management Topics • Decoding Your Utility Bill & Understanding Electric Tariffs • How is the Best Way to Train My Operators? • Evaporative Condensers ITM and Monitoring Best Practices Operations Topics • Manual Purging of Excess Non-

hands-on sessions, and manufacturing sessions!

CIRO Review Course CARO Review Course CRST Review Course

• November 6th-7th CRES Review Course • November 7th Management of Change (MOC) Workshop

The Technical Topics, Hands-On Sessions, Workshops, Hot Points and Manufacturer Sessions will make this year one that is jammed packed with a lot of learning to be gained; and a lot of knowledge to be taken back to your workplace. Our “Call for Abstracts” has been closed and the technical papers submitted

• November 10th WiNR Workshop

NETWORKING AND SOCIAL EVENTS • National Car Museum Night Out

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• Welcome Reception in Exhibit Hall • WiNR Happy Hour & Networking

• RETA After Hours Lounge • Chapter Leaders Reception GUEST PROGRAM

The RETA National Conference is a fabulous opportunity to work and play. If your spouse or companion can join you in Reno (which is magical at the Peppermill Resort), you may well want to consider this very special program. Our guest program includes an exclusive schedule of events with an array of activities and off-site adventures. Schedule of guest program events can be located by visiting www.RETA.com and selecting 2022 Conference. *A spouse or companion may only attend the program as a partner of a registered attendee. During the registration process, you will be presented with the procedure for adding your spouse or companion as part of your registration. HOTEL INFORMATION Our hotel reservation site for the Peppermill Resort Spa Casino is open beginning in May 2022. You can locate the link by visiting www.RETA.com and selecting 2022 Conference. CONFERENCE REGISTRATION The 2022 National Conference registration portal will be open May 2022. You will be able to register for the Conference, Review Courses, Workshops, Guest Program, social events and more. SPONSORS & EXHIBITORS A very big thank you to all the businesses who supported our 2021 RETA National Conference. Without our Sponsors and Exhibitors support, we would not be able to provide our members and industry with the educational experience and commitment to safety in the Refrigeration Industry. 2022 Sponsorship and Exhibitor Opportunities are now available! Interested in Sponsoring or Exhibiting? It is not too late to do either or both. We have many opportunities available for the 2022 RETA National Conference. Please contact Stephanie Date at Stephanie@reta.com for more information. Exhibitor Move-in & Move-out • Move-in & Setup (November 6th-7th) • Move-out & Teardown (November 11th at 2:00pm) There is no limit to what you can take away and accomplish at this year’s 2022 RETA National Conference. See you in Reno, Nevada!

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EDUCATION CORNER

The mission of RETA is to enhance the professional development of industrial refrigeration operating and technical engineers. The goal of the Education Committee is to develop educational materials suitable to advance the mission. The foundation of RETA’s Education program is the RETA books and online training materials. In order to remain relevant, the educational materials need to be reviewed and upgraded regularly to reflect the current trends in the industry. The RETA Board of Directors has set the ambitious goal of having all materials reviewed and revised on a 5-year schedule.

Currently, • IR-1, IR-2, and BE-1 have been revised and upgraded recently. • IR-3 Plant Maintenance and Related Items - has been in committee and has recently seen the light of day. It will now undergo final review and formatting to make it ready to print. • BE-2 Ladder Diagrams - is in the final stages of edit and assembly. • Ammonia Refrigeration Compliance has been in committee and has recently seen the light of day and will now undergo final review and formatting to make it ready to print.

• Controls 1 & 2 – After years of service, Controls 1 is in the process of being modernized. Including information about improvements in the world of modern industrial refrigeration controls. Controls 2 is next. These educational materials require countless hours by dedicated RETA Members to make them“the Best They Can Be”. I want to thank them for their service. Right now, your Education Committee needs your help. If you would like to be part of improving RETA’s education materials, contact: vince@RETA.com

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AMMONIA LABELING & SIGNAGE RAGAEP Updated with a side of epic fails By Bill Lape, SCS Engineers

In my pipe and equipment labeling series that was published in the RETA Breeze in late 2019 and early 2020, we discussed ammonia refrigeration pipe and equipment labeling RAGAGEP. In Part I, I highlighted the possible choices for applicable good engineering practices that pertain to such labeling, highlighting the American Society of Mechanical Engineers (ASME) A13.1 and the International Institute of Ammonia Refrigeration (IIAR) Standard 2. In Part II, I began to delve into the details of IIAR’s Bulletin 114, and how it’s guidelines for piping labels have changed over the years. In Part III, I reviewed the pipe color guidelines in Bulletin 114, along with its guidelines for component, or equipment labeling. With the publication of IIAR2-2021, the RAGAGEP for pipe and equipment labeling has changed somewhat. IIAR2 still calls out the basic requirements for pipe labeling in Section 5.14.6. This includes the text “AMMONIA” on the label, the physical state of the ammonia in the pipe, the relative pressure level (low or high) of the ammonia in the pipe, the pipe service, which is allowed to be an abbreviation, and an arrow indicating a direction of flow. While this has not changed from the 2014 and 2014 Addendum A editions, what has changed is that Bulletin 114 has now been incorporated into IIAR2 as an informative appendix (Appendix Q). Being an informative, rather than a normative, appendix means that a facility can use several different methods to comply with Section 5.16.4. Following Appendix Q is not required, much like it was not required to follow Bulletin 114. Bear in mind that any method used to comply with Section 5.16.4 must be documented in the facility’s process safety information and the operators and the contractors that work on and operate the ammonia refrigeration system must be trained on the labeling method used by the facility. You may note that the Equalizer Line abbreviation (EQ) is not in the informative appendix. A call to Eric Smith at IIAR confirmed that this is an error in the printing and will be corrected at the next printing. The informative appendix also includes the following new line identifications:

Another change relates to the system signage requirements originally found in ASHRAE15, Section 11.2.1. ASHRAE required that the signage include the installing contractor’s name and address, the refrigerant number and the amount of refrigerant, the lubricant identity and amount, and the field test pressures applied. When ASHRAE15 deferred to IIAR2 for ammonia in 2018, IIAR2-2014, Section 5.15, took precedence. This section required that signage, or schematic drawings that were kept in a location readily accessible to trained refrigeration staff and first responders, include the following items: 1. Instructions with details and steps for shutting down the system in an emergency; 2. The name and telephone numbers of the refrigeration operating, maintenance, and management staff; emergency responders, and safety personnel; 3. The names and telephone numbers of all corporate, local, state, and federal agencies to be contacted as required in the event of a reportable incident;

4. Quantity of ammonia in the system;

Piping Description

Abbreviation

5. Type and quantity of refrigerant oil in the system; and

Flooded Liquid Supply

FLS

6. Field test pressures applied.

Flooded Liquid Return

FLR

Vent Line (Oil Pot)

VNT

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In IIAR2-2021, Section 5.14.1.1 requires that signage, or schematic drawings that are kept in a location readily accessible to trained refrigeration staff and emergency responders, include the following items: 1. Instructions with details and steps for shutting down the system in an emergency; 2. The contact information for whom to contact in an emergency;

3. Maximum intended inventory of ammonia in the system;

4. Type of refrigerant compressor oil(s);

5. Low side and high side design pressures.

Note that required contact information on the signage or in the schematic drawings has been simplified. The amount of oil in the system is no longer required, and the field test pressures have been replaced with the low side and high side design pressures. One thing that I do want to highlight is that the instructions for shutting down the system in an emergency, if done by simply pressing the emergency stop, can be detailed using the recommended emergency shutdown signage found in Appendix J of IIAR2, and they do not need to be repeated on the system signage. Be sure, however, when purchasing such signage that you make any necessary edits to it to properly reflect your system. Otherwise, you may wind up appearing in an Epic Fail column. If you choose to provide the documentation required in Section 5.14.1.1 in a location that is readily accessible, make sure that it doesn’t turn into an Epic Fail. 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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EPA GENERAL DUTY CLAUSE INSPECTIONS 51 POUNDS OF VAPOR RELEASED

This small company uses NH3 to produce and store ice. The NH3 process runs continually, but employees are not in the plant outside of normal business hours. One evening in 2016, at 10:53 PM, the city fire department was notified about a strong ammonia smell near the facility. Following their protocols, the fire department donned their HAZMAT suits and entered the facility and shut down the compressor. Firefighters remained on the scene until 5:57 AM that morning. Following a root cause analysis, they found that a housing seal on their reciprocating

compressor had failed and allowed the release. They calculated a loss of 51 pounds of vapor over a period of 196 minutes. By failing to identify and replace the seal prior to failure and allowing the process to continue to run while it was releasing NH3, the company violated the requirement of CAA 113(r)(1) for owners and operators to design and maintain a safe facility, taking such steps as necessary to prevent releases. This release did not result in any exposure injuries nor require an evacuation of the area. Someone noticed an odor and call the fire department. The exact start time of the

release was not known, but they were able to estimate the 196-minute release duration. This company was cited and paid a penalty of $40,000, which is considerable for a small company and also in 2016. How could this event been prevented? What options could this company have to notify appropriate personnel if there is a release? Do they need to have someone on premises who is qualified to shut down the system at all times? What would you have done?

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40 YEARS AGO IN RETA HISTORY THE 1982 SPRING CONFERENCE

The 1982 Spring Conference was a two-day celebration of all things RETA. In case you missed it, here are some of the highlights. The Board of Directors and office core was made up of industry greats and industry greats to be. Chuck Toogood was Chairman of the Board of Directors. His Directors were John Beckum, Bob Bossier, John Scherer, Arthur Schulte, Gordon Campell, William (Bill) Cunningham, Richard Fisher, Craig Young, Wallace Spitznagel, Joe Schauf, Beverly McCann, and William H. Knox. The officers were President James Marella, Executive Vice President Roger Mulholland, Vice President Harry Paul, Secretary Ken Andersen, Treasurer Herb Rosen, and Sargent at Arms Ellis Norton. The Spring Conference was held in and hosted by the city of Pittsburg. Spring conferences were small two-day affairs. Essentially, spring conferences were comprised of, a Board of Directors meetings, a safety day, and several meals. As usual, the event was funded by sponsors. It’s interesting to look at the products being offered at the time. FES released their screw compressor control panel. Baltimore Aircoil advertised their VX condenser. Sullair was still marketing their ammonia screw compressors, and Vilter was using their “It’s a Vilter, I presume” tagline from Sir Stanley of “Dr. Livingstone I presume” fame. RETA advertising used the tag line “Someone goofed in the engine room ……. and everybody loses”. At the time, RETA offered “Industrial Refrigeration Course 1”, as a printed book and as a cassette tape course. Industrial Refrigeration Course 2, Control Theory 1, Control Theory 2, and Basic Electricity rounded out the RETA library, Attendees gathered at the Sheridan Inn for the two-day conference. Friday April 2nd, started with an afternoon Board of Directors meeting, followed by the Board of Directors Dinner. Wives were invited to attend the dinner festivities. Following dinner was a night of merriment referred to as “Hospitality Night”. Nalco Chemical was the hospitality sponsor. Saturday opened with 15 minutes of opening ceremonies including a state of the organization speech by President Marella. The pledge of allegiance was a staple of organizational ceremonies and Mr. Marella led those in attendance in the pledge.

1982 was an exciting year in RETA history. Many things were happening in the organization, but generally, the membership considered the organization in the process of rebirth. Many changes had been made to the educational materials and the organization was on a steady path of growth and community service.

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Over 200 ice and refrigerating machines were constructed under the Boyle name. Approximately 75 in David’s lifetime.

Next was the business meeting only 45 minutes back in those days. Much as today spouse activities ran concurrent to the conference. So following the opening ceremonies, the spouse activities began. Only 3 technical sessions were presented at the spring conference. The first whitepaper was presented by Thomas Hall and Ronald Lukcic from Nalco Chemical. The presentation was on the importance of condenser water treatment. The second session was presented by Joseph Szymanski of Evapco. The topic was Designing and Operating Condensing systems to save energy and money. The third technical session was a panel discussion where attendees could pose refrigeration questions at the panel experts. The conference closed with an open bar, dinner, and evening dance. Attendees had an enjoyable weekend, thanks in no small part to the organizing committee. Led by conference chairman Mark Duffy and Mark’s wife Peggy, who chaired the spouse activities. The 1982 spring conference was considered a success. But the spring conference would eventually be dropped from the calendar. Many members were engaged in preparing their refrigeration systems for the taxing summer season and could not attend the spring conference regularly. The author, Vern M. Sanderson, is Senior Manager of PSM (and amateur recruiter) at SFC Global Supply Chain, Inc., where he eats a lot of Red Baron® pizza. The article is Vern’s personal work and does not reflect the view of SFC Global Supply Chain or any affiliated companies or brands. If you have corrections to the article or memories of the conference, please email them to Vern at Vern. Sanderson@Schwans.com. We hope you enjoyed this look at back!

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HELLO RETA FAMILY, My name is Ken Williams, I was the historian for RETA for a few years. I was a RETA board member in the late 80’s and became president in the 90’s. The last few years of the pandemic and civil unrest made me take an in-depth look at our society and the groups and people I’ve been involved with during my life. The reason I did so was after having discussions with friends, associates, my children, and my grandchildren I realized that in my mind our society has not progressed as far as some people believe. During these discussions I told my children that people form their opinions over the years by their interactions in life. We also form our biases during these interactions, and everyone has their own set of biases whether we admit it or not. After thinking about what I had conveyed to the people I knew, I had to write this article not to blame anyone, but to hope it will make you think about what I have written. Now that I have set the stage, let me present a few facts for your consideration. A few years ago one of the members and business associates of mine presented me

with a booklet. It was the National Association Practical Refrigerating

recruit or nominate others to join Committees and the Board are mostly Caucasian. The information I have put in this article is not designed to anger anyone, it is simply written in the hope that everyone will think about this and maybe some creative dialogue can begin. I hope this will also lead to more people of color getting involved in the governing body of RETA and in the refrigeration industry at-large. Please understand I am not upset with RETA but I do think it is time for me to hopefully help to start this dialogue.

Engineers (NAPRE) data book. This data book was for the members of NAPRE and in the book were tables, definitions for terms used in the industry, and information for NAPRE membership in general. The reason he felt I should view the booklet was because of a very interesting statement in the booklet on membership eligibility which he wanted me to see. That statement was “any white refrigeration engineer who has one or more years’ experience in an ice-making or refrigerating plant, and who is of good moral character is eligible to active membership.” After reading the booklet I spoke with my friend, and we discussed how far RETA had come in regard to this standpoint. He felt this was something I would be interested in since I had been on the RETA National Board of Directors and had progressed through the Chairs. Now while it’s true that RETA ‘s bylaws currently allow anyone for receive a membership regardless of race or gender, I would submit to you that there are biases which I don’t think most of our members would even discuss. To my knowledge there has been only one black person to progress through the Chairs. I don’t think it was a deliberate plan, but the other fact is that the people who normally

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By James Marrella Q A

ANSWER: What a great question and with an equally great answer! Yes they did. On January 13, 2022, the United States Occupational Safety and Health Administration (OSHA) announced that they increased their maximum monetary penalties by nearly 5%. (Ctrl+Click to follow link 2022 Annual Adjustments to OSHA Civil Penalties Occupational Safety and Health Administration) And the last time OSHA increased their penalties before that was on January 8, 2021. Yes just over a year ago. So don’t be surprise that they do it at least 2 more times (2023 and 2024) and beyond. Due to the Federal Civil Penalties Inflation Adjustment Act. (Federal Register / Vol. 86, No. 10 / Friday, January 15, 2021 / Rules and Regulations). The Inflation Adjustment Act required agencies to: (1) adjust the level of civil monetary penalties with an initial “catch-up” adjustment through an interim final rule and (2) make subsequent annual adjustments for inflation, no later than January 15 of each year. Before we get started, we need to establish some “Ground Rules” or “Mind Set”. It is very important to understand when we are addressing a given requirement set by a federal/state/local regulation is to be prepared to defend our action or better yet defend our thought (Thinking) process. We need to show that our approach is in line with the “agency in question”methodology and that it FITS our circumstance, and apply some common sense. Try not to over think the issues at hand. We need to ask a few simple questions as we maneuver through our decision process. The questions. “Does this make sense?” and “Is this new procedure overburdening your staff?”Or the most important question “Can you modify an existing procedure to fit your needs today?” With that said, I would like to add 2, simple laws of operating. Consider them “food for thought”. Marrella’s 1st and 2nd laws that influence our little “World of Industrial Refrigeration” they are as follows:

QUESTION:

DID OSHA RECENTLY INCREASE THEIR PENALTIES?

Marrella’s 1st Law: Anything complex can be broken down into simple elements.

PART 1

Marrella’s 2nd Law: Nothing is as simple as it seems.

Now, after saying all that, where do we start?

Well, I believe it is very important that we have an understanding of regulations or at the very least, know where you can get help if the need ever occurs. I would also be the first to tell you that this subject is very dry and may overwhelmed you at first. But it is still needed just the same. On this subject we will give you a general view, just enough to make you dangerous, and I strongly recommend that you review our IR4, Chapter 2 Occupational Safety and Health Administration and Environmental Protection Agency for Part 2. Question to all RETA Chapters: Do you make the Q and A part of your chapter meeting or general discussion? If you have a question or comment for Jim visit our website or he can be reached at 5720 South Austin Avenue, Chicago, Illinois, 60638.

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