2025 Jan-Feb RETA Breeze

RETA BREEZE

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION JANUARY/ FEBRUARY 2025

UH, OH… HERE COMES MORE

REGULATIONS THAT WE NEED TO WORRY ABOUT. PART 4

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

Uh, Oh… Here Comes More Regulations That We Need to Worry About. part 4

jim@reta.com Sara Louber Senior Director of Operations sara@reta.com Stephanie Date Events Manager stephanie@reta.com Scott Melton Education Coordinator scott@reta.com Samantha Ibarra Certification Coordinator samantha@reta.com Dan Denton Chapter Relations Liaison ddenton@reta.com

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INSIDE THIS ISSUE

Message from the President............. 4 From the Desk of the Executive Director.............................................. 6 Memos of Misunderstanding.......... 8 Conference Corner Happy New Year! ................................. 10 Education Corner........................... 13 Categories of Weather Barriers, Vapor Retarders, and Finishes....... 14 The Refrigeration Historian Volume XXX ....................................... 16 Congratulations to our 28th RAI! Samuel Dunlap, RAI ............................ 17

Uh, Oh... Here Comes More Regulations That We Need to Worry About. Part 4 .................................................. 18 Fine Tuning the People Machine “Simplified!”..................................... 22 The Shade Tree Mechanic Volume XLV — Slow Rollin .................. 27 RETA Testing Corner No. 46 Only CARO, CIRO and CRST Earn RETA’s Internationally Accredited Credentials ... 28 Certification Honor Roll................ 30

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 © 2025 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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2024-25 BOARD OF DIRECTORS CHAIRMAN OF THE BOARD Michael Hawkins, CARO Midatlantic Refrigeration, LLC

FROM THE DESK OF THE PRESIDENT

NATIONAL PRESIDENT David Gulcynski, CIRO, CRES Dot Foods, Inc EXECUTIVE VICE PRESIDENT Bill Lape, CARO, CIRO, CRST SCS Tracer Environmental

Hello all and I hope everyone is well! With winter closing in on spring, your National Board of Directors will start planning to meet at RETA HQ to discuss business and make decisions regarding our organization. There is plenty of good stuff in the works and I am excited about our future. I sat in on an International Committee meeting a couple weeks ago. This Commit tee is strong and is working with the Marketing Committee to get the RETA brand out to the world. During this meeting there was lots of discussion on how to make this happen. The one thing that caught my attention was a comment made by Brandon Jones, “Education is our core strength and the reason the international refrigeration community is looking at RETA”. I completely agree and our library of educational materials is where it all starts. This commit tee and RETA HQ are looking at what we need to do to make sure our educational materials are going to be ready to go out into the international market. It is a complicated task but I am confident we will get it done! While it seems like yesterday we were in Grapevine, TX for conference, Stephanie Date and the Conference Committee are already hard at work preparing for this year’s Conference is Spokane, WA. This conference will be a heavy equipment show so manufacturers and vendors will be able to bring in all the equipment they need to showcase their products. A call for topic abstracts has gone out to the general membership, so if you have an educational topic you would like to speak on at conference, contact Stephanie at HQ, she can point you in the right direction. Scott Melton, Don Tragethon and the Education Committee are busy working on an IR1 book review and re-writing the CO2 Study Course. Scott’s article in this edition of the Breeze goes into much more detail

about those projects, who is leading the charge and what is coming down the pipe from the Education Committee. Our other committees, Publications, Marketing & Certification, are active and staying busy as well. I try to sit in as many of the committee meetings I can and cannot thank the leaders, volunteers and HQ staff enough who consistently keep the work moving in a positive direction. Thank you!! I would like to announce a new committee that will start working this year, The RETA – RSES Culture Committee. Jerry Clark, Past RSES International President, has agreed to be the Committee Chair. This committee is in its infancy stage and will consist of both RSES & RETA folks. The idea behind and goals for the committee will be to develop our organizations future and blending of traditions. Both organizations are so much alike, yet each has their own individual traditions. I am excited about the results that will come from the Culture Committee and look forward to share those results as the year progresses. Once again, our organization has a bright future and I am confident we have the right people working towards that future. Thank you for reading and take care!

TREASURER Ray Urban, Jr, CARO Lineage Logistics SECOND VICE PRESIDENT Jeremy Murfin AC & R Specialists

BOARD OF DIRECTORS Jeremiah Armstrong

Brakebush Brothers Melissa Cassell General Refrigeration Dale Clinton, CIRO, CRST Stellar Brynn Cooksey Air Doctor Heating and Cooling Mike Davis Republic Refrigeration Ron Fetterley, CARO, CIRO, CRST Applied Process Cooling Corporation Jayson Goff CoolSys Brandon Jones, CARO Tyson Foods Eric Kaiser TruTech Tools, Ltd Jim Kovarik Gamma Graphics Service Jose Marchese Koldcraft Refrigeration Services Casey McConnaughy Johnson Controls Technical Services

Dave Gulcynski RETA National President

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© 2024 Johnson Controls. All rights reserved.

Mike Missall, CARO Summit Refrigeration Group Jodie Rukamp SCS Tracer Environmental Gary Struhar Retired Harrison Travis Sanden Vendo America, Inc

FROM THE DESK OF THE EXECUTIVE DIRECTOR

COMMITTEE CHAIRS Certification: Lee Pyle, CARO SCS Engineers National Conference: Jim Kovarik Gamma Graphics Services Education: Don Tragethon, CIRO, CRST, RAI Retired Publications: Vern Sanderson, CIRO, CRST, RAI Schwan’s Company Marketing: Jodie Rukamp SCS Engineers Membership: Jason Daniell, CIRO APSM As a non-profit association, RETA is governed by a board elected by its members. RETA was pleased to announce the 2024/2025 Officers and Board of Directors at the Annual Business Meeting, held at the National Conference in Grapevine, Texas. RETA board members serve a 3-year term and volunteer their time and energy to directly impact our community and association. The 16-member board and 5-member executive committee aim for both diversity of perspective and depth of expertise. There is a strength with our staggered terms and the Board is always changing. RETA Executive Director, Jim Barron congratulates and welcomes all new members to the board. We thank our outgoing members and welcome new members, as well as extend a heartfelt thanks to Directors past, present, and future for their contributions and dedication to RETA’s mission.

Hello again everyone. It seems as if I just wrote an article for the RETA Breeze yesterday; time sure does fly. We have just finished the holidays, and the new year has begun. The RETA/RSES HQ staff are busy gearing up for a new year full of projects including a new RSES book, many book reviews and a few revisions, new online training options, and planning the 2025 Conference in Spokane, Washington. We have officially brought RSES into our fold and the staff is doing a great job of acclimating to the RETA gold standard. Our certification program is the only ANAB accredited program of its kind in the world and the process is already ongoing to bring the RSES certification programs to that standard. Through our efforts, we ensure that operators and technicians are equipped with the knowledge to safely run their equipment. Both RETA and RSES are here to assist and support our membership in as many ways as we can; no job is too big or too small when we are heading in the same direction. We are a world-class Association, and we love what we do. Committees will be getting together for annual updates for policy and procedures to programs like Education, Certification, Marketing, Conference and Publications. I would like to thank all the volunteers who make all these programs happen and say, “let’s have a great year.” RETA/RSES springboard meeting will take place at HQ, April 10-12 with a full day of strategic planning for our future growth as a combined association. We are looking forward to a great year moving forward. Last, but certainly not the least of my article, is my wish for each and every one of you to have a safe, healthy and above all a happy 2025.

God Bless, Jim Barron

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ask something that forces me to respond. If you want to brief me on a situation, call me. Two-way conversation. I’m not very bright and I’ll have questions anyway. Never send me a cc memo by mail. I have to deal with it. I need to read it or file it or both. You’ve obligated me to at least 5 minutes out of my day. Don’t email me if your pissed at me. If I’ve upset you in some way via email or text, rest assured I didn’t mean to. I only piss people off in person. If you’re upset with me, call me or see me in person. Tone is next to impossible to put into an email. I will try to assume you’re not yelling at me, but I would rather not guess. Chances are I will misinterpret your email and then get pissed at you. Don’t be vague. Say what you need to say. Don’t try to be cute and don’t play guessing games. Tell me what you want. If I can give it to you I will, If I can’t give it to you I won’t. I need clear direction, if you don’t have it, that’s ok. Think about it and contact me later. No need to rush and drive me crazy now, just gather your thoughts and we can start again later. Don’t email me just to make someone else happy. I hate getting emails, sent to impress

MEMOS OF MISUNDERSTANDING

I really get excited when a new memo is sent down to maintenance. That normally means I have more scrap paper for the kids. Sometimes, it means a colorful paper air- plane depending upon the type of paper they use. Rarely does it mean that some thing exciting is going to happen to improve my life. More likely, my work life will be getting more difficult. Sometime the memo is an email, that is a little better, at least I know a tree didn’t have to die to piss me off. I’m assuming that there is always a reason to send me the memo. I just can’t figure out what it is sometimes. Sometimes, I don’t even bother to read them. You normally get a paragraph to get my attention, on a good day. So why send us the memos at all? I get that memos via paper or email, are a great way to get the information out. But please, look at the audience your sending it to. Here are the rules, I think we need to implement. Does this need to be sent? Why are you sending the communication. If

the reason has nothing to do with me, don’t send it to me. Will the situation resolve itself without a memo? I sometimes get emails that say things like “Wanted to let you know Bob will be calling you”. Bob can tell me that when he calls me. Maybe if you need to assure that Bob does contact me, you can contact Bob and say “please send me a confirmation after you have talked to Tim”. Do I need to know? Make sure I need to know. “we will be closed Christmas day”. Unless you think I would have some reason to believe you would want me to come open the plant up on Christmas. You probably don’t need to let me know. I’ve probably picked it up in a meeting already, or when I look at the schedule and notice I’m not scheduled (nor is anyone else). If I really need to know send it to me. If I don’t, respect my day. Don’t copy me. Only email me if you want me to take action. If you want me in the loop in case something bad happens later, don’t bother, I’m going to make an excuse later anyway. If you really want to make sure I’m in the loop,

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someone else. We’ve all gotten those communications which are obviously sent to satisfy someone who couldn’t bring themselves to contact me directly. Don’t be someone else’s stooge. Let them do their dirty work. Courtesy only goes so far. I love Vern, but his emails drive me crazy. “Good Morning”, “I hope my message finds you well”, “Have a great day”, and the famous “I hope you and yours are doing well”. He does it because he is a nice guy who doesn’t want his emails to be mean. But it adds time to my day because I read the fluff. While it is important to be cordial, don’t over do it. These items would be a good start. But it’s just a start. Think about your communications and what you’re trying to say. Read it back to yourself through my ears. If it sounds offensive, it is. “We must stop weed smoking in the parking lot”. Ok this sounds odd, but if you send this to me, it says you believe I’m

smoking pot in the parking lot. Do you want my helping in stopping weed smoking in the parking lot? Are you asking me to confiscate your lighter? Miscommuni cation can apply to a hundred other things. Make sure your communications are not accusatory. If your are accusing me of something be direct. “Bob, I noticed your smoking weed in the parking lot. Stop it!” “Given current construction activities, what safeguards are being contemplated to alleviate concerns?” What part of construction activities? Crane lifts, line breaks, contractor access, etc…… Be specific. What concerns? Food Safety, opera tions, sales, etc… A much better message would read something like this: “Given the scheduled crane lifts over the receiver area, what safeguards are we putting in place to assure some A-hole doesn’t drop the new condenser on my receiver?”The first sentence may prompt a book as a response, with the responder trying to cover all potential issues. In some instances, this may require the message receiver to get dozens of additional people involved to try to answer this very vague question. The

second sentence prompts a very specific, very direct response. For those who receive communications, give the sender a break, don’t assume that they are targeting you. We have all received a message sent to 50 people and we read it like, it was directed specifically to us. Give the sender the benefit of a doubt. Several years ago, a refrigeration manager turned in his notice because of a memo he received. When I heard about the situation, I met with the refrigeration Manager. My first sentence “Junior, you know the corporate guy that sent that memo has no idea who you are or what you do. There is no way he was attacking you, he doesn’t know you.” Junior decided to stay in the position. It seems like we burned the memo in the parking lot and went out for a beer. In closing, while it’s important to be careful of the communications we send, it is equally important that we be careful in how we interpret the communications we receive. Good communications are the responsibility of all of us.

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CONFERENCE CORNER

HAPPY NEW YEAR!

I hope you all had a fantastic and safe holiday season!

15-19 PDH CREDITS Juan Becerra Ernie Chavez Arnold Garcia Carol Geisler William Jago Tony Lundell Guillermo Perez Jesus Salazar Warrender, LTD. WEG 10-14 PDH CREDITS Nadia Avalos Martin Avila Joshua Bauer Justin Baxley Andrey Berezhnoy Jon Berry Austin Birch

The RETA National Conference Committee is already hard at work planning an incredible educational and fun-filled event for October 2025. Whether your primary goal is advancing your education and earning PDH credits, professional network ing, or reconnecting with fellow RETA family members, the RETA 2025 National Confer ence will be the place to be! We’re Celebrating Top PDH Recipients from RETA 2024! Our 2024 National Conference in Grapevine, Texas, was a resounding success, offering an impressive variety of technical sessions, review courses, workshops, and opportuni ties to earn Professional Development Hours (PDH) for recertification. Congratulations to everyone who earned PDH credits at the conference! All of us at RETA Headquarters are incredibly proud of your commitment to continued education. A special shoutout goes to the Top PDH Credit recipients of 2024—your dedication and hard work are truly inspiring!

Greg Blacksill Henry Bonar Dale Brumfield Jonathan Butterfield Jeff Buxton, P.E. Steven Buza David Cain John Cain Manuel Calderon Anthony Card Michael Cardoso Fernando Carlos Mark Carlyle Rodrigo Casallas David Case Mike Cassano Jim Caudill Ariadne Ceniceros Clifford Chapman

Timothy Clark Martin Collette Eric Coolbaugh Ruben Corona Kevin Cortez Mark Costilow Eddie Cuellar Sean Davie Arturo Davila MyHanh DetVo Paul Doege Alex Drennan Shawn Duffey Brian Dugie Dylan Dyke Jon Dysinger Gary Elk William Ellena Jeffery Ellis

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Scott Emmell Christopher Eschette Rogelio Esquivel-Sanchez Chris Farnum Steve Farrar Jace Fedler Ralph Fico Jose Figueroa Carrion John Flynn Cory Fowler Brad Gappa Antonio Garcia Alan Gervais Eric Girven Jacob Girven Saul Gonzalez Linares

Michael King Dustin Kinsey Scotty Knight Daniel Kruger Connor Lane David Lashlee Corrine Lawrence Paul Lee Kevin Lull Scott Markham Ana Martinez Baltazar Martinez Paul Mccollum Aaron McCormick Nigel Mercer Joshua Miller Patrick Moore Carlos Motta Dharlie Narce Roger Norton Gabriel Olivarez Flavio Pablo Diego Padilla Moler Timothy Popow Kimberly Proffitt Chad Pulliam William Purcell Mike Ralston Russell Ramos Henry Reynoso Adam Riester Taylor Rodriguez Jeff Roper Luis Ruiz Daniel Russell Cesar Salas Antonio Saldana Ruben Sanchez Raphael Pfaff Amy Pilgrim

Aaron Schmidt Refik Sekic Paul Sidhu Douglas Siegert Stephanie Smith William Smitty Danny Sobecki Scott Sommerfeld Edward St. Pierre Matthew Stachura Will Thielemann Jordan Thomas Mike Thompson CMS Brian Tiemeier Kyle Tokarz Nathan Torres Titus Torres Donald Trimble Esau Tucker Richard Turner Harry Tuttle Jeremy Walden Burt Wallace John Webb Colin Webster Ronald Whisenant Zachary Stover William Talbert Walter Teeter

PHOTO GALLERY Did you know you can go to https:// reta.com/gallery/ to view the photo gallery of our Hands-on and Technical Sessions, RETA Rumble, Exhibit Hall, Monday Night Out, Awards Night and much more from Conference?

John Gravlin Brendan Gray Mark Groman Miguel Gutierrez Jeremy Hands Richard Hartwick Jim Havel Tania Herrera Charles Holloway Jacob Hoogensen Todd Hornsby Joe House Jeffrey Hutchins Wayne Isaac Lonnie Isbell Clark Jackson Parker Jenkins Jeffrey Johnson Kevin Johnson Christopher Junker Steven Kaminski

Ryan Wiggins Steven Wilson Lloyd Wright Richard Zeisloft

Here’s to another amazing year of

learning, growth, and connection. See you at RETA 2025!

Sylis Kariah David Keith Mike Kelly

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Monday, October 20 • Exhibitor Move-In •

SAVE THE DATE! Grab your beanie hat, plaid flannel shirt and get yeti for some fun! RETA 2025 is October 20-24, 2025, in Spokane, Washington and promises to provide everyone with more opportunities to learn and earn PDH credits than ever before. Our Call for Abstracts was incredibly successful with an incredible turnout of 40+ Technical Topic submissions! Thank you to all who submitted abstracts. The Technical Program Committee is currently working to review all abstracts and decide which topics should be expanded into papers and presented at Conference. Each Technical Paper and presentation will be available to each attendee during and after RETA 2025 Conference. 2025 PRELIMINARY CONFERENCE SCHEDULE Saturday, October 18 – Monday, October 20 • CARO, CIRO, CRES, CRST, & IIAR 6 Review Courses (pre-registration required)

• • •

Exhibit Hall Open

RETA Rumble & Pub Style Quiz

Management of Change (pre-registra tion required)

RETA After Hour Lounge

Thursday, October 23 • Exhibit Hall Open •

• •

WiNR Reception

Monday Night Out at Pacific NW Wonderland (pre-registration required)

Technical Topics: Compliance, Engi neering, Management, Operations, and Hands-On Sessions

Tuesday, October 21 • Exhibitor Move-In •

• • • • •

Certification Exam Testing Chapter Leaders Reception

General Session & RETA Business Meeting

Mix n Mingle Awards Night

•

Technical Topics: Compliance, Engi neering, Management, Operations, and Hands-On Sessions

RETA After Hour Lounge

Friday, October 24 •

• • •

Certification Exam Testing

Exhibit Hall Open

Opening Exhibit Hall Reception

•

Technical Topics: Compliance, Engi neering, Management, Operations, and Hands-On Sessions

RETA After Hour Lounge

Wednesday, October 22 •

Technical Topics: Compliance, Engi neering, Management, Operations, and Hands-On Sessions

• • •

Certification Exam Testing

Big Ticket Drawing

Exhibitor Move-Out

•

Certification Exam Testing

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EDUCATION CORNER

To all members, from the Education Coordinator. Recently, some of the RETA and RSES staff were at the 2025 AHR Expo in Orlando. We were asked to give a presentation on CO2 and refrigerants. While developing the presentation I dove deep into some of the history of refrigerants. Which leads to the fact that I think many of us know there isn’t really anything new in refrigerants, just new ways to use them and different combinations of chemicals, along with the tried-and-true naturals that have been used throughout our history. CO2 is being considered by many in the industry, but once again this is not a new refrigerant, as it has been used and recognized from the beginning. However, it wasn’t until this last series of changes (Ozone Depletion Potential and Global Warming Potential being the biggest driving forces), arose that have led us to develop the equipment needed and the level of understand ing, to make CO2 a truly viable option. This leads the industry to today, where education is as or more critical than any other time in our history. This situation is also not new, much like the refriger ant topic discussed here. However, we do live in different times, and as our systems have evolved to handle refrigerants like CO2 our way of

training needs to also evolve. Most of our industry, and the world, finds making time for training difficult at best in today’s fast-moving environ ment. Combine this with the fact that we don’t have enough trained people to do the work and we will see our industry continue to head toward more difficult times. Looking at the past may help us find some answers. In the past, individuals learned a trade through an apprenticeship, thus making training a year-round affair rather than a once-a-year check the box task item…or worse, just filling the need with a person who hasn’t been trained. Technicians and operators must be made, they don’t just appear! We need to look at ways to train people while they work rather than take the few people we have away from their daily tasks; apprenticeship type pro- grams might hold some answers. This or other options not discussed in this short article won’t be easy to develop, but the alternative is to continue to complain about the fact we don’t have enough people, until it might be too late. Whatever new ideas we bring forward in development will take all of us working together for a better future- -owners, managers and workers.

Owners get their operational needs fulfilled, mangers get the technicians they need with proper training, while workers find a career path that leads to a successful future. Just like the presentation I just gave at AHR Expo, this article is not meant to give all the answers, but rather create thought to inspire dreams and drive action. This is our industry, and it is our responsibility to protect it much like a child. So let’s get busy finding the answers so we can stop fretting over the issues we face, such as the huge lack of trained individuals. RETA/RSES will continue to develop and improve its educational materials, such as what is already happening with the current review of IR-I and the re- write of the Co2 book. But we all need to start working together to answer one of the most dire needs we have in our industry today--trained operators and service techs. Refrigerants will come and go, but they aren’t worth much without trained individuals to use them. Blessings! Scott Melton

scott@reta.com 1-509-833-5258

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CATEGORIES OF WEATHER BARRIERS, VAPOR RETARDERS, AND FINISHES

metal jacketing weather barriers, which will minimize and potentially stop the condensate which tends to form on the inner surface of the metal jacket from contacting the metal portion of the jacket. Appearance Coverings are materials used over insulation systems to provide the desired color or appear ance. Hygienic Coverings are materials used to provide a smooth, cleanable, surface for use in food processing, beverage, or pharmaceutical facilities. These functions are performed by a number of different materials or material systems. In many cases, a single material can provide multiple functions (for example, a metallic jacketing -protective covering system often serves as protection from both the weather and from mechanical abuse). • •

thermal insulation, protect the insulation from the weather such as rain, snow, sleet, dew, wind, solar radiation, atmospheric contamination and mechanical damage. Vapor Retarders are materials which retard the passage of water vapor into the insulation. Mechanical Abuse Coverings are materials that protect the insulation from damage by personnel, machinery, etc. Condensate Barriers (sometimes called moisture retarders) are materials, normally used as an inner lining for

By Ron King, Past President/Consultant, National Insulation Association Most mechanical insulation systems require a protective covering or finish material. The primary reason is to protect the insulation from damage, weather, mechanical abuse, water vapor condensation, chemical attack and fire are all potential sources of damage. Additionally, appearance coverings are utilized to provide the desired aesthetics. Depending on the location and application, various terms have been used to describe these functions: • Weather Barriers are materials which, when installed on the outer surface of

•

•

•

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There is some inconsistency in the nomenclature used for these materials. The terms jacketing, lagging and facings are sometimes used interchangeably to describe the outer protective covering of an insulation system. Adding to the confusion, the term vapor retarder has evolved. Historically, the term vapor barrier was used, but this has been generally replaced with the term vapor retarder in recognition of the fact that an absolute barrier to water vapor flow is difficult, if not impossible, to achieve. Water Vapor Permeance is defined by ASTM C 168 as the time rate of water vapor transmission through unit area of flat material or construction induced by unit vapor-pressure difference between two specific surfaces, under specified temperature and humidity conditions. For protective covering or facing materials, water vapor permeance is commonly expressed in units of perms. In below ambient applications, it is important to minimize the rate of water vapor flow to the cold surface. This is normally accomplished by using vapor retarders with low permeance, insulation materials with low permeability, or both in combination. In above ambient

applications, it is often desirable to have a breather facing that allows water vapor to escape without condensing. In either case, it is important to know the perme ance of the facing materials. ASTM Test Method E 96 is used to measure the water vapor transmission properties of insulation materials. Especially in below ambient service applications, it is important to under stand all aspects of an insulation system. The exterior finish of your insulation system is your first line of defense – clari fy its purpose and investigate if you need one or more finish to protect your insulation system investment. It is not unusual, and in many cases preferred, to have a vapor retarder to minimize the rate of water vapor flow to the cold surface and one to protect the vapor retarder. Specific applications such as ammonia refrigeration have very specific specifica tions which must be followed. This article is provided by the National Insulation Association (NIA) as a RETA member service. Please visit www. insulation.org for more information related to all aspects of mechanical insulation.

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The Refrigeration Historian Volume XXX I never met Edward W. Wickey, but I believe I would have liked the man if I had.

Edward W. Wickey, though he would be known predominantly as “E.W.”, was born June 19th, 1866. The son of Andrew Wickey. He was an avid chess player from an early age. He would have a weekly match with George Lewis for over 41 years. Edward married Emma Wolkitt. Their marriage would result in four children. Mable, Edith, Edna, and Wesley. He would marry a second time to Ida. Edward was a businessman and lawyer, passing the bar on 1893. He was also a director of “The Famous Manufacturing Company” of Chicago”, a company his father had founded. He spoke to the National Conservation Commission on behalf of the Farmers’ National Congress. He was such an accomplished lawyer, that he argued before the supreme court. In 1892, Edward would file several patents, none were refrigeration related. But there are instances, though arguably rare, where non-refrigeration patents may benefit society. Edward’s did. He was considered such a local celebrity, that his travels were documented in the local newspaper. Even the rumor of his return for a visit to his family was printed. He was a personal acquaintance of President Warren Harding. In a note President Harding wrote “To E. W. Wickey with agreeable recollections of a strenuous but happy day in the Calumet district, high personal esteem and good wishes, sincerely Warren G. Harding.” They had become acquainted during meetings before President Harding’s successful presidential campaign. In fact, all four republican candidates would

make pilgrimages to meet with local businessmen before the election. Edward sponsored the Harding visit. After the election Edward would be appointed as an attorney for the United States. Such was the power of the iceman, for Edward had co-founded the Pure Ice Company of Chicago Heights in 1912. It is important to remember that in this era the iceman had tremendous power. Often, the iceman controlled a commod ity in such high demand that, the control of the supply provided political power. It took tremendous skill, a wide breadth of knowledge, and political power to rise to leadership in the Ice Association. Edward was no exception. Edward would eventually become the president of the Indiana Ice Manufac turer’s Association. Through none of the ice associations wielded the power of the Southern Ice Exchange, the Indiana association was well respected. His 1920 speech at the Michigan lce Industries Association, “What the Ice man Owes” re-enforced his place in

refrigeration history. Both as an iceman and as a humanitarian. Edward served in various roles with the Indiana Ice Manufacturer’s Association for years. As vice-president, he would offer the Defense Council, the use of Indiana ice houses to assist with the war effort. In the early days, Ice manufactures and dealers held the same power in the community as the oil barons. In Edward’s time, the world was changing and refrigeration was a vital part of that change. Edward would be called before our lord in August 1939. He was entombed at the Oak Hill cemetery in Hammond, Indiana. Information for this article included information from Ice and Refrigeration Illustrated, various newpaper articles, annual proceedings, historical notes, and articles. The information used to generate this article is believed factual. Should you have any corrections or additional information pertaining to this article please forward them to the editor.

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Sam Dunlap is a Virginia Tech graduate who has over 8 years of refrigeration experience working for Innovative Refrigeration Systems and the Industrial Refrigeration Technical College (IRTC). He has worked primarily in Process Safety Management (PSM) and Risk Management Program (RMP) roles. Samuel Dunlap also provides training in regard to the PSM/RMP programs. Sam has experience in both writing and training on standard operating procedures. Samuel is also a professional engineer in the state of Virginia and has helped in the design process of many refrigeration systems. CONGRATULATIONS TO OUR 28TH RAI! SAMUEL DUNLAP, RAI (RETA Authorized Instructor)

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UH, OH... HERE COMES MORE REGULATIONS THAT WE NEED TO WORRY ABOUT. PART 4

In the last issue of the Breeze, I provided a detailed history of the regulatory pendulum that we find ourselves riding. This month’s article will begin the process of describing the changes to 40 CFR Part 68 and providing possible means for achieving compliance. EMPLOYEE PARTICIPATION Rule Changes to 40 CFR 68.83 (EPA 40CFR68 Subpart D, 2024) There are multiple changes that have been made to 40 CFR 68.83. First, two additional requirements were added to paragraph (a). The first one instituted a requirement that written or electronic notices be distributed annually to employees and their representatives, indicating that the plan is readily available to view and how to access the information. The second one established that training must be provided as often as necessary to ensure employees and their representatives, and management involved in the ammonia refrigeration system, are informed of the details of the plan. An additional paragraph (paragraph (c)) was added that states that the owner or operator shall consult with employees

knowledgeable in the process, on addressing, correcting, resolving, documenting, and implementing recommendations and findings of process hazard analyses (PHAs), compliance audits, and incident investigations. A new paragraph (d) implements a requirement that the owner or operator establish a stop work authority. Any employee knowledgeable in the process, including their representatives, must be able to recommend to the operator in charge of the ammonia refrigeration system that it be partially or completely shut down. The qualified operator in charge must be able to partially or completely shut it down in accordance with established operating procedures based on the potential for a catastrophic release Finally, a new paragraph (e) requires that the owner or operator must develop and implement a process to allow employees and their representatives to report to either or both the owner or operator and the EPA unaddressed hazards that could lead to a catastrophic release, RMP reportable accidents that were not reported, and any other noncompliance with this part. This paragraph allows employees to report either anonymously or with attribution, but that records any

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such reports made to the owner or operator must be kept for three years. STRATEGIES FOR COMPLIANCE To comply with the changes to paragraph (a), develop an awareness flyer or training that will be used on an annual basis. Set up a recurring reminder to distribute or post the flyer or conduct the training annually. A training session is a preferred method, as it can be coupled with a quiz at the end to capture an employee’s understanding of their rights to access the information and how to do so. Be sure to update the Employee Participation program to detail how the facility is handling these new requirements for awareness. Ensure that the awareness training includes details of the new Stop Work Authority and Reporting Rights. Many facilities are likely already complying with the requirements in paragraph (c). However, it is advisable to try to schedule your recommendation review session, or PSM/RMP Team or Committee meetings in such a way that all employees who work on the ammonia refrigeration system are given the opportunity to review, and help make plans to address, open PHA, audit, or incident investigation recommendations. If the meetings cannot be scheduled to facilitate this, consider distributing the open recommendations to all refrigeration operators so that they can review them and ask questions, or make suggestions on how to address them. Update the Employee Participation program to identify how the facility is going to involve all of the employees in the addressing of recommendations. When implementing a Stop Work Authority in compliance with paragraph (d), be sure to identify which employee or employees are considered “operators in charge.” Conduct documented training with all employees who work on the ammonia refrigeration system on their rights to recommend partial or complete shutdown based on hazards that could lead to a catastrophic release. In addition, make sure that these employees understand who has the authority to shut down the system. Update the Employee Participation program to establish the

Stop Work Authority, detailing the “operators in charge,” as well as the refrigeration operators with the authority to recommend shutdowns to those “operators in charge.” For the reporting system that must be established to comply with paragraph (e), update the program to identify: 1. How the employees are to report unaddressed hazards to the facility owner or operators. 2. How the employees may report unaddressed hazards or unreported RMP accidents to the EPA. 3. That the employees may report these hazards, or unreported accidents anonymously should they choose to do so. 4. The retention time of three years for such reports to the owner or operator. The deadline to establish compliance with these changes to 40 CFR 68.83 is May 10, 2027. PROCESS HAZARD ANALYSIS Rule Changes to 40 CFR 68.67 (EPA 40CFR68 Subpart D, 2024) There have been several details added to some of the topics that the PHA must address. In addition, there are several

new topics that must be discussed and included in the PHA report. First, in the requirement to address the engineering and administrative controls applicable to the hazards of the ammonia refrigeration system and how one can affect the other, consideration of standby or emergency power systems must explicitly be included. In addition to this consideration, 40 CFR 68.67(c)(3) now includes the following requirement: “The owner or operator shall ensure monitoring equipment associated with the prevention and detection of accidental releases from covered processes has standby or backup power to provide continuous operations.” Second, when considering stationary source siting, otherwise known as facility location, 40 CFR 68.67(c)(5) now includes the requirement to include consideration of the placement of processes, equip- ment, and buildings within the facility, and hazards posed by proximate stationary sources, and accidental release consequences posed by proximity to the public and public receptors. Third, 40 CFR 68.67(c) now includes items 8-10. Item 8 requires that the PHA shall address natural hazards that could cause or exacerbate an accidental release. Item 9 requires that the PHA shall address a

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mrcc.purdue.edu/gismaps/cntytorn

• Natural Hazards – Floods msc.fema.gov/portal/home • Natural Hazards – Snowfall www.ncei.noaa.gov/access/

monitoring/snowfall-extremes/US/1 To address the requirement of evaluating the gaps between the codes and standards to which the ammonia refrigeration system was constructed and modified and the current applicable codes and standards, the first step is ensuring that the applicable codes and standards have been identified for the ammonia refrigeration system. While a lot of facilities have this information, there are many that have no idea of what they are. Once the applicable codes and standards have been identified, the next step is to do a gap analysis. In ammonia refrigeration, IIAR Standard 9 identifies the minimum safety requirements for existing systems. This standard requires that a gap analysis be conducted to evaluate the compliance of the facility’s system against its requirements. Due to a lack of clarity when the standard was first published, an Addendum A was published in 2024, which established a deadline of January 1, 2026 for conducting the gap analysis. It is important to note that if a facility’s system was constructed after the publication of IIAR9 in 2020, it does not have to do this gap analysis for the 2020 edition, but rather needs to ensure that it is fully following IIAR2-2014, Addendum A, or IIAR2-2021, whichever applied to the design and construction of the system. It is also important to note that if a facility or its parent company chooses to comply fully with each new edition of IIAR2, then IIAR9 would also not apply to their system, but they must perform a gap analysis with each new edition of IIAR2. Bear in mind that this is if the facility upgrades to be in FULL compliance with the new edition of IIAR2, which may not be possible, depending upon the changes in a particular edition. Once the chosen applicable gap analysis has been performed, step three is to review the gap analysis as part of the PHA and evaluate

safer technology and alternative risk management measures applicable to eliminating or reducing risk from process hazards. At this time, this provision only applies to NAICS code 324, Petroleum or Coal Products Manufacturing, and 325, Chemical Manufacturing. Since it does not apply to the vast majority of facilities with ammonia refrigeration systems, this paper will not address strategies for com- pliance with this provision. Item 10 requires that the PHA shall address any gaps in safety between the codes, standards, or practices to which the process was designed and constructed and the most current version of applicable codes, standards, or practices. STRATEGIES FOR COMPLIANCE The new PHA requirements have several due dates, some of which have already passed. Covered facilities were required to comply with the following provisions as of the effective date of the changes to the regulations, which was May 10, 2024: 1. Addressing the new items as part of stationary source siting 2. Addressing natural hazards that could cause or exacerbate an accidental release 3. Addressing gaps between applicable

codes and standards To comply with items one and two as quickly as possible, hold a short PHA session to address the stationary source siting by reviewing other RMP facilities close by and whether or not they can affect the facility. In this session, review the nearby public receptors, including schools, places of business, places of worship, prisons & jails, and residential neighborhoods. Finally, review a list of possible natural hazards. The following is a list of web site links that will aid the team in evaluating these new topics. • Stationary Sources cdxapps.epa.gov/olem-rmp-pds/ • Nearby public receptors – 2020 census data ejscreen.epa.gov/mapper/ geopub.epa.gov/myem/efmap/ • Natural Hazards – National Risk Index hazards.fema.gov/nri/map

•

Natural Hazards – Earthquakes /home/webmap/viewer. html?webmap =7d987ba67f4640f0869acb82ba 064228#!

•

Natural Hazards – Tornados

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HOT WORK Rule Changes to 40 CFR 68.85 (EPA 40CFR68 Subpart D, 2024)

and address hazards due to the gaps. Needless to say, complying with this require- ment will take some time if a facility has not already completed steps one and two. It is important to evaluate the hazards associated with power loss and to consider standby or emergency power systems. This should be done during the PHA session described earlier. Regarding the requirement that monitoring equipment associated with prevention and detection of accidental releases from covered processes has standby or backup power to provide continuous operation, several questions come to mind. First, what is included in this requirement? Even EPA is unclear as at least one of their inspectors has stated that the emergency ventilation system for ammonia refrigeration machinery rooms is included in this requirement. Now, it can easily be argued that the emergency ventilation system neither detects, nor prevents an ammonia release. It remains to be seen how this will play out as facilities are inspected by the various EPA regional personnel. However, it is safe to say that the ammonia detectors installed within a facility are covered under this requirement. However, it also needs to be asked what exactly is acceptable? IIAR2-212, in Section 16.1.4, states that “a means shall be provided for monitoring the concentration of an ammonia release in the event of a power failure for all systems where leak detection is required in accordance with this standard.” In Appendix A, IIAR2 clarifies its position by stating “One possible means of monitoring ammonia concentration resulting from a leak during a power failure is a portable ammonia monitoring device.” So IIAR2 allows for requiring personal ammonia detectors to be carried or worn by employees entering areas with ammonia refrigeration equipment or piping during a power failure. Is this acceptable to the EPA? When asked, the EPA pointed to the PHA. So, it is up to the PHA team to thoroughly evaluate and document the hazards during a power failure and determine if backup power in the form of batteries or generators are warranted.

It also has to be asked that if generators or battery backups are installed, how long is acceptable? They cannot be expected to operate indefinitely. One place to look is NFPA72-2022, the National Fire Alarm and Signaling Code. This code defines the amount of time that a fire alarm needs to be able to detect a fire during a power failure, as well as how long its alarm devices are required to be able to operate. It is a fairly safe position that if it is good enough for the fire alarm system, it should be good enough for ammonia detection. Regardless, any backup power installed to address this requirement must be completed by May 10, 2027. OPERATING PROCEDURES Rule Changes to 40 CFR 68.69 (EPA 40CFR68 Subpart D, 2024) There is one addition to the information that is required in the operating pro- cedures detailing the safety systems and their functions. The new requirement in the regulation states that the safety system description must include documentation when monitoring equipment associated with prevention and detection of accidental releases from covered processes is removed due to safety concerns from imminent natural hazards. STRATEGIES FOR COMPLIANCE Apparently, some chemical facilities have disabled monitoring equipment when natural hazards have approached. The easiest method to achieve compliance with statement to the Safety Systems section of each operating procedure that states: “It is company policy NOT to disable monitoring equipment in the event of notification of imminent natural hazards. If the natural hazard causes a power failure that disables the monitoring equipment, manual monitoring using handheld detection will be used as long as it is safe to return to work.” It may also be a good idea to include a list of facility specific backup power capabilities for detection either within the operating procedure itself or using a reference to a list in the Process Safety Information. this requirement without further clarification from the EPA is to add a

The new regulations add a paragraph (c) to the Hot Work program requirements that state that “the permit shall be retained for three years after the completion of the hot work operations. STRATEGIES FOR COMPLIANCE It is a simple matter to add a paragraph to the Hot Work Program, stating that “Hot Work Permits for hot work conducted on or around the ammonia refrigeration system are retained for three years following completion of the hot work operations.” However, one of the question marks is what exactly would be covered in “around.” The easy answer would be anything within 35 feet of the ammonia refrigeration system or its piping, as this is the radius defined in 29 CFR 1910.252, the fire prevention precautions standard. However, this is not always feasible, so a it could also be stated that “Permits for hot work conducted within 35 feet of the ammonia refrigeration system equipment or its piping are not retained unless the ammonia equipment or its piping cannot be protected by the use of a welding screen or blanket, and it has been positively determined that no heat can be transmitted to the ammonia refrigeration system through conduction.” Be sure to also update the hot work program to state where the completed permits are kept on file. In the next article, I will dive into the specific changes for Emergency Response, Incident Investigations, Compliance Audits, RMP Updates, and Availability of Information to the Public. Please feel free to email me with questions at NH3isB2L@gmail.com. Bill Lape is Project Director for SCS Engineers. Bill is a Certified Industrial Refrigeration Operator, a Certified Refrigeration Service Technician, and is the current Executive Vice President of the Refrigerating Engineers and Technicians Association.

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