RETA Breeze July-Aug 2024

RETA BREEZE

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION JULY/ AUGUST 2024

PERMEABILITY & PERMEANCE DO YOU KNOW THE DIFFERENCE?

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 of Operations sara@reta.com Stephanie Date Events Manager stephanie@reta.com Harry Wilkins Education Coordinator harry@reta.com Samantha Ibarra Certification Coordinator samantha@reta.com Dan Denton Chapter Relations Liaison ddenton@reta.com

WHAT YOUR SAFETY MANAGER NEEDS TO KNOW

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INSIDE THIS ISSUE

Message From the President............ 4 Call for Nominations Annual Awards ..................................... 6 What Your Safety Manager Needs To Know................................. 8 How To Get the Most out of the RETA 2024 National Conference.. 12 In Memory Of Troy William Baker......................... 16 The Shade Tree Mechanic Volume LVI - Be on the “teams” ...................... 17 Permeability & Permeance Do you know the difference? ............... 18

Uh, Oh… Here Comes More Regulations That We Need To Worry About. part 1 ........................ 20 An Operator’s Perspective of Ammonia Refrigeration................. 24 RETA Testing Corner No. 43 Earn RETA Credentials at the Annual Conference ............................... 26 Signed Up for a Review Course at Conference?................... 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 © 2024 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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2023-24 BOARD OF DIRECTORS CHAIRMAN Bengie Branham, CIRO, RAI SCS Engineers PRESIDENT Michael Hawkins, CARO Midatlantic Refrigeration, LLC EXECUTIVE VICE PRESIDENT David Gulcynski, CIRO Dot Foods Inc. TREASURER Bill Lape, CARO, CIRO, CRST SCS Engineers SECOND VICE PRESIDENT Raymond Urban, CARO Lineage Logistics DIRECTORS Melissa Cassell General Refrigeration Company Dale Clinton, CIRO Stellar Victor Dearman, Jr., CIRO, CRST Peco Foods, Inc Arlie Farley, CARO, CIRO, CRST Farley’s SRP Inc Ron Fetterley, CARO, CIRO, CRST Applied Process Cooling Corp Brandon Jones, CARO Tyson Foods, Inc Barbara Kirkpatrick Mi-Docs Jim Kovarik Gamma Graphics Services Mike Missall, CARO Summit Refrigeration Group Jeremy Murfin AC & R Specialists Andrew Palomar, CARO Stellar Gordon Rascoe, Jr, CIRO, CRST, RAI ConAgra Brands COMMITTEE CHAIRS Certification: Lee Pyle, CARO SCS Tracer Environmental Education: Eric Girven, CIRO, CRST, RAI SCS Tracer Environmental Marketing: Jodie Rukamp SCS Tracer Environmental Membership: Jason Daniell, CIRO APSM National Conference: Jim Kovarik Gamma Graphics Services Publications: Vern Sanderson,

FROM THE DESK OF THE PRESIDENT

Hello RETA Family, It’s hard to believe that at the time of this writing, we are only 10 weeks away from the 2024 National Conference in Grapevine, TX. Where did the year go?! I sincerely hope you can attend this year’s Conference; we have some terrific tech sessions and hands on workshops for you to obtain your PDH credits along with a sold out show floor. Not to mention the networking opportunities with your peers and vendors. As you recall, last year was a historic conference where we voted to merge with our RSES family and come together as one organization. This has been a monumental task, but we are making great progress. This year could be equally historic. Last year, past President Branham and Jim Barron met an individual from South Africa who is an instructor, doing training across the continent, and very interested in RETA. He has since taken the train the trainer course and plans to take the RAI test at Conference. We could have our first International RETA Authorized Instructor. Through his travels and teaching, he hopes to be able to gain enough individuals to be able to start a chapter there as well. Over the last year, we’ve had great atten dance at the virtual chapter meetings that have been hosted by our own Dan Denton of HQ. These meetings have been growing with attendees from all over the world. There was one group of 21 individuals from Sierra Leone in West Africa in attendance at one of the online meetings hosted by the Blue Ridge Chapter in Virginia. Chapter President Stacy Coogan took these individuals under her wing and educated them about RETA, who we are and what we have to offer. Stacy also set up a Zoom meeting specifically for them in July with the knowledgeable Nova-Aer Teale doing a

presentation. I was privileged to be able to attend the online meeting in August where they were presented their first PDH certificates, this group could not have been more proud or more grateful. With some help from Blue Ridge, Southeast PA, and HQ, we’re in the process of finalizing the membership applications for these 21 individuals AND in the process of helping them with the charter paperwork to start a chapter. If all goes well, I hope to be presenting the first International Chapter Charter at the National Conference Grapevine. The word is spreading around the world that RETA is the Gold Standard! What an exciting time for our terrific organization, I am so excited to see what the next chapter holds for us. RETA would not be the success it is without all the hard work and dedica tion of all our volunteers from the chapter level to the various committees. We are truly blessed to have such passionate and dedicated folks working to make RETA the great organization it is. On behalf of HQ and the Board of Directors, I cannot thank you enough. Please keep doing what you’re doing, and I look forward to seeing you in Grapevine, TX.

Thank you, Mike Hawkins, CARO RETA National President

Mike Hawkins CARO, RETA National President

CIRO, CRST, RAI Schwan’s Company Executive Director: Jim Barron

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CALL FOR NOMINATIONS - ANNUAL AWARDS

The following awards will be given out at the annual Conference in Jacksonville, Florida this November. They are named in honor of past RETA members who exemplified a specific strength that benefited 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 reta.com/ nominations. Nominations must be received by September 29th, 2023 in order to give the awards committee adequate time to consider the nominations. The following awards will be presented at the annual Conference in Grapevine, Texas this October. They are named in honor of past RETA members who exemplified a specific strength that benefited the RETA membership and our industry either through teaching or leadership or service. documentation to online at www.reta.com/ 21st, 2024 in order to give

Guy R. King Memorial Award

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

Venneman Award

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

Felix Anderson Award

Recognizes two individuals who have worked behind the scenes at the Chapter level and who are not on the national Board.

Elliott R. Hallowell Award

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

Kim Snowden Award

Honors an individual, company, or organization who promotes the furthering of women within the refrigeration industry. This could include, but is not limited to: • Individuals who have promoted women in the refrigeration industry throughout their career; • Individual women, who, by standing out and taking on leadership roles have indirectly inspired other women to pursue careers within this field; or • Companies that have encouraged and provided opportunities for women within their organization.

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WHAT YOUR SAFETY MANAGER NEEDS TO KNOW BEFORE STEPPING INTO THE ENGINE ROOM

rear or aft end of the nautical vessel. Much like today, engine rooms are typically

I guess one of the first things a safety manager needs to know before stepping into your engine room, is what the term “Engine Room” means. As a new safety manager in a food plant, this was the first question I had. Come to find out, “Engine Room” was originally a nautical term, that dates back into the early 1800s. On a ship, the engine room is the compart ment where the machinery for propulsion is located. The engine room is generally the largest physical compartment of the machinery space. The engine room is usually located near the bottom, at the

If you see a yellowish or whitish looking cloud coming your way, run, up wind…... Report it. If you smell a strong Ammonia odor, get out of the area and head up wind to fresh air….. Report it. If you feel it on your skin or in your eyes, leave the area, head up wind, get under an emergency safety shower and eye wash……. Report it. RULE #2. Don’t Touch - - - Anything. You may think that you are trying to help, but you know what? You’re not, you’re just in the way. Volunteer to help, but let the

located in the bowls of the plant. Many Safety Managers may not be

in tegrally involved with the day-to-day activities that take place in the Engine Room or the Ammonia Refrigeration System, but they need to know 3 basic Rules. I came up with these simple rules years ago, and they still hold true today. RULE #1. Ammonia can kill - See it, smell it, feel it on your skin and eyes and immediately you know that something bad is happening.

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refrigeration team lead the action unless life safety is a concern. RULE #3 – Refer to Rules 1 & 2 Now that we have a basic understanding of the Dos and Don’ts of Refrigeration, there is a lot more that your Safety Manager needs to know. There are several safety systems that apply to both inside and outside the Engine Room. You can find all of these safety systems in the PSM program / RMP manuals. If your facility utilizes Anhy drous Ammonia as a Refrigerant, and you don’t have a PSM or RMP program (10,000 pounds or more), Ammonia Refrigeration Management Program ARM (500 – 999 pounds), or ARM LT (less than 500 pounds), well you’ve got much bigger problems. As a former Safety Manager in a food plant myself, I know there are several safety programs that apply to both the manufacturing side of the business and the Refrigeration System. Administrative Controls “IE” signage is one such program. The Engine Room Entry Room Door signage is one example. Signage is used extensively throughout manufacturing facilities. Rarely will you find an entry point adorned with so many signs and emergency information as you’ll at the entry to an Ammonia Refrigeration Engine room. Along with the signs, you should also find Emergen cy Ventilation Switch, Emergency Shut0down Switch, and a bunch of other critical information that can save your life. Standard ANSI / IIAR-2 contains signage requirements for the engine room door. Here’s your sign. Read them, understand the meaning behind each word, symbol or graphic. Understand what they are telling you.

Another program common to refrigera tion is Lockout / Tagout (LOTO). There may be some very distinct differences between LOTO in the production areas and LOTO in the Engine Room. Let’s start with some basics information of what is LOTO? Lockout/Tagout is the isolation of a machine’s energy sources to prevent a sudden, unexpected release of stored energy that could injure or kill you. LOTO does not simply mean throwing the main breaker or switching the machine control switch to the off position. Understanding the complexity of LOTO in an Engine Room can be the difference between a catastrophic release or even life and death. One complexity to realize is where the LOTO procedures are documented. In the Engine Room, many time LOTO Procedures will be incorpo rated into the equipment’s Standard Operating Procedures “SOPs”. When I took over as a safety manager, I thought it would be a great idea to augment the LOTO Procedures with the Brady LOTO procedures. Oh boy, let me tell you, I had no idea what I just stepped off into by wanting to change, or add to a SOP. The first minor roadblock I ran into was this Gene, my lead operator, he kept referring to a thing called an MOC. I was

management, and I wanted to make a change, so what’s the big deal. Hmmm not that simple, as I soon discovered. There were several potential Hazards with LOTO in the Engine Room that I needed to learn, as far as that goes, there were lots of potential hazards associated with the entire Refrigeration System that I needed to learn about. I had no idea there were so many hazards just lurking around just waiting to try and kill me. Deenergizing or bringing refrigeration equipment to a Zero Energy State is delicate balance between Know-how, skill, and Science. Trapping liquid Ammonia in an isolated run of pipe is a hazard, therefore it has to be blead off. You can’t just open a valve to atmosphere and bleed off residual pressure. Ammonia has to be Pumped Out or evacuated, which can take several

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face on a day by day, sometime, moment by moment. You don’t know what you don’t know. If, or should I say when, an Authority Having Jurisdiction (AHJ) Regulatory agency like OSHA, the EPA, or a state regulator comes knocking on your door, you had better be able to answer their questions, or at least know where to find the information they are looking for. I learned this lesson the hard way, when my boss shut the conference room door with just me, my PSM contractor, and an EPA Compliance Officer sitting around a table with a set of books that I had never seen before in my life. OMG that was a long day. I don’t teach Ammonia Operator training classes, but if you want a couple of references, please don’t hesitate to give me a call. The author, Joseph (Joe) Baldwin - Baldwin Safety Solutions, Owner and Senior Safety Consultant 682-381-8680 Joe.Baldwin16@yahoo.com baldwinsafetysolutions.net linkedin.com/in/joseph-baldwin-67026b31

hours, and in some cases days to remove all residual Ammonia. Even after evacuat ing all the Ammonia, there is still residual Ammonia that will off-gas from compres sor oil along with any vapor left behind in pipes and equipment. Just as a side note. Don’t allow your ammonia operator to bleed residual ammonia into a 55-gallon barrel of water, with a water hose running wide open. We ended up with ammonia water flowing across the parking lot, down a storm drain and ended up discharging into a major waterway. Not a good day when the Fire Department, City Officials, the EPA, and local news media showed up at the plant. Lesson learned, the hard way. Process Safety Management (PSM) The next safety program I had to learn about was 29CFR1910.119 “PSM”. I had been in industrial safety for several years at this point. I had the entire Code of Federal Regulations to worry about, not just a few pages of the 1910.119. I’ve been an OSHA Authorized Instructor for the past 23 years. I’ve completed the OSHA (500) Train-the-Trainer Course, OSHA (501)

General Industry Trainer Course and Construction (510) Trainer Course, along with all the OSHA required updates. Not once during any of these training sessions, was there any mention of Process Safety Management (PSM), Risk Management Planning (RMP) 40 CFR Part 68, nor was the 29CFR1910.119 ever brought up. Oh my gosh, I had no idea how much PSM would change my life and my career path. I didn’t know what I didn’t know. In less than a year of taking over as safety manager, I knew I had educated myself on Ammonia Refrigeration. Where should you start? My advice to Safety Managers, if you are new to refrigeration in the food industry or a seasoned professional, continue to educate yourself. Taking some Ammonia Refrigeration training classes. I started with the Operator 1 Course. Also, if you’re not already involved, get involved with your Process Safety Management (PSM) Team. You don’t have to lead the team, just show-up to the monthly meetings and get involved. A safety manager needs to know what their ammonia operators

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HOW TO GET THE MOST OUT OF THE RETA 2024 NATIONAL CONFERENCE

Prepare for Conference By preparing yourself beforehand, you most certainly will get the most out of what the RETA 2024 National Conference offers: • What do I want to learn? • Who do I want to meet? • What sessions & workshops do I want to attend? • What social & networking opportunities do I want to attend? • What products or services do I want to see? Be specific and clear when answering your questions, as this will better prepare you for the day. Organize Your Schedule Review the conference agenda in advance and create a personalized schedule that includes sessions, workshops, and networking opportunities that align with your objectives. You can find the RETA 2024 National Conference Schedule at https://reta.com/page/2024-conference-schedule Research Speakers and Topics Familiarize yourself with the speakers and their expertise. Prioritize attending sessions led by experts in your field or on topics of particular interest to you. Write down questions you want to ask the speakers. Here are example questions you might want to ask: • How do you see this field/industry evolving in the future? • Are there any specific resources, tools, or methodologies you would recommend for someone interested in this area? • Are there any upcoming trends or innovations you think we should be aware of? • What are some key insights you have gained from your experience in this area? • Remember to listen actively and engage in a conversation with the speaker or presenter. Additionally, don’t hesitate to ask follow-up questions based on their responses to delve deeper into the topic.

Conferences can be overwhelming and daunting with the amount of people, maneuvering the venue and schedule. Don’t worry. Our Conference tips listed below will help anyone tackle them confidently and efficiently.

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Prepare for Networking If you’re a shy person, the thought of networking may be frightening. However, networking is one of the most important things you can do as a professional. Wheth er you’re there to represent your company or yourself, prepare yourself beforehand so you can network like a pro. Here are some quick tips: • Introduce yourself clearly and concisely. A first impression really does count! • Plan conversation topics ahead of time. By doing this, you will avoid awkward silences and off-topic discussions. • Hype yourself up before the event. This one may sound silly, but positive self-talk has a huge impact on self-confidence! Before heading out, look in the mirror and tell yourself how confident you are. The more you repeat it, the more confident you’ll feel. Download any Apps, Maps or Schedules RETA 2024 not only has the schedule online but will also offer a conference app with a schedule you can access before attending and onsite during Conference. Make sure to download it in advance so you can plan your day in a more efficient way and become familiarized with the program. Pack and Plan for the Day As a RETA 2024 full-conference attendee, you will receive a conference bag filled with many useful items, like a padfolio notepad and pen for taking notes. Here are other items you may consider: • Tablet or laptop • Battery pack and charging cord for your phone

• Breath mints or mouth sprays can go a long way, as coffee breath can linger for hours! Plan Your Outfits The RETA National Conference is NOT a stuffy environment. In fact, we are all family! We want you to be comfortable but also professional. Keep in mind you’ll potentially be rubbing shoulders and shaking hands with industry leaders. Make a lasting impression by dressing appropri ately in smart casual attire with layers. Comfortable shoes are always a safe and appropriate choice. Research the Venue Beforehand If you are local, will you be driving there, catching an Uber? Or will you be staying onsite at the Gaylord Texan Resort? Make sure you allow yourself plenty of time to arrive on time, especially if you are from out of town. The last thing you want is to show up feeling flustered and stressed because you didn’t anticipate the traffic. By researching where the venue is, you’ll also be able to see what’s available at the venue and in the area. Additionally, you will have several options to suggest if someone wants to prolong a conversation over drinks or a meal. Let’s recap! Preparing yourself for RETA 2024 will provide you with the confidence needed to navigate the venue and schedule like a pro!

BEWARE OF HOTEL POACHERS The Gaylord Texan Resort & Convention Center is the ONLY contracted hotel for the 2024 RETA Room poaching is a practice carried out by third-party companies that act as travel agencies. These poachers may inform you that the hotel room block is sold out or offer a discounted rate. They may even state they represent RETA or use the RETA Logo solicitations to the 2024 RETA National Conference from convention housing bureaus offering reduced hotel rates. These housing companies are known as Hotel Poachers or Hotel Pirates. They are NOT affiliated with the 2024 RETA National Conference or the Gaylord Resort & Convention Center. How hotel poachers book rooms and attempt to get your money: Most poaching agencies do not have a contract with any hotels for room blocks they will contact a housing wholesaler, such as Expedia, Priceline, etc. to see if rooms are available that they can mark up to resell to unsus pecting guests. Typically, want your money upfront, paid in full. DON’T BE MISLED! **There are NO 3rd party housing companies authorized to represent RETA or the Gaylord Resort & Convention Center. National Conference offering a discounted nightly group rate. in their emails. This is not true. We have been made aware of

• Charger for your laptop or tablet • Bottle of water and some snacks

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IN MEMORY OF TROY WILLIAM BAKER

May 31 2024

April 27 1964

Troy William Baker, age 60, of Las Vegas, NV, passed away on May 31, 2024. He was born on April 27, 1964, in Passaic, NJ. Troy was an accomplished and well-respected Sales & Business Change Leader, having most recently served as the VP of Sales for Panda Doors and Windows as well as the Vice Chair on the Board of Directors for ASTI (Ammonia Safety & Training Institute). His career was marked by excellence in leadership in every industry he touched. As a proud United States Army NBC Officer, Troy’s military associations were a significant and instrumental part of his life. Following his education at Manchester Regional High School, Troy began his journey into adulthood at The Citadel Military College of South Carolina. He was recognized for his many accomplishments and held leadership ranks of Battalion and Regimental Staff. It was here that he learned perseverance and what it takes to overcome adversity, the importance of tradition, discipline, and

the values of honor, duty and respect. This served him well during Desert Storm where he served as a 1st Lieutenant with the 419th Water Dawgs - the highest rated Water Battalion in the US Army. Troy was a loving husband to Jessica Glenn-Baker and a devoted father to William(22), Wesley(20), Raquel(19), Wynston(5), and Whitney(1). Troy is survived by his mother, Diana Baker, his sister Sloane Baker, and his nephew Brooks Baker. He was preceded in death by his father, Leonard William Baker. Troy was known for his caring nature and generosity. He was passionate about his family and friends, an enthusiastic sports fan(Mets, Jets, Rangers, Knicks, and Notre Dame), a music and concert lover, a lifelong learner, and he constantly challenged himself both professionally, personally, and physically. His impact on those around him will always be remembered and cherished. He pushed everyone around him to be their best selves, and did whatever it took to provide the opportunities for others to do so.

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SERVICE

The Shade Tree Mechanic volume LVI — Be on the “Teams”

I don’t care what you call it: Teams, Zoom, Zimo, Webex, Bob’s online, or any other darn electronic meetin’ places. But if your gonna be on the Teams’, then be on the Teams’. We didn’t have them electronic meetings back in my day. We showed up to meetings and sat there listening. If we didn’t we got our behinds chewed. You know why people like them things? I do It’s easier to sleep than in in-person meetins’. If it’s not sleepin’ then it’s doing other things. Heck I’m writin this while I’m on a Teams Meetin’. I’m not alone, I bet 50% of the people in this meeting is doin something else right now. Hopefully it’s work related, but I’m sure people are checking their NASCAR fantasy team. Some are probably working their side hustle on Facebook Marketplace or eBay. Some are probably live streaming today’s big game, Some may be watchin Judge Judy. Heck some may be reading a comic book, or on another call. And yes, at least one is writin a Breeze article for that damn Sanderson guy. I know we talk about how much time we save. But do we? How much are we missing because of being distracted? It must be a lot. How

many times do you wait till the meet- ing notes come out to figure out what happened. How many times are you muted and began talking only to find no one can hear you. Then you get unmuted and stop the meeting to go back to provide input. Hey at least your participating. How many times do you ask someone a question and get no answer? You call their name 4-5 times and then give up. If you’all really want to have some fun. Stay on at the end of the meeting and see how long it takes for everyone to drop off the meeting. I do this on occasion, I had someone stay on all night. I’m figurin they left the office during the meeting and left their computer logged into the meeting. He probably noted when he got back to the office the next morning. How much did he get from the meeting? Have you ever logged into a meeting on your phone and a different meeting on your laptop, only to find that 3-4 people are doing the same thing? I’m guessing your not going to be the best participant. Maybe some of this is our fault. Are we inviting people to the meeting that we want to have input? We don’t want anyone to feel left out so we invite everybody and their brother and their cousins, and Blind

Bill from outside the Sunoco station. Why?

Are we scheduling meetings that would better be emails. Of course, if people don’t read their emails, it doesn’t do any good. Are we taking steps to make sure the people in the meeting are engaged. I do something really annoying; I ask people questions throughout the meeting. They have gotten to the point that they expect it. They know I’m going to pause till they answer, even if I need to call their cell phones to see where they are. It’s embar rassing, That’s the point. If they pull this crap, they deserve to be called out. Afterall, others took time out of their day to attend the meeting.. Part of the problem is that the ease of scheduling these electronic meetings lends itself to more meetings. “Think before you schedule.” I think that would make a great T-shirt or screen saver. Oops gotta go someone in the meetin’ just called my name. I wonder what we’re discussin? The shade tree grows outside of the little town of Broughton, Ohio. Where everyone is always welcome, the beer is always cold, and something is always needin fixin.

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PERMEABILITY & PERMEANCE DO YOU KNOW THE DIFFERENCE? By Ron King, Past President/Consultant, National Insulation Association

P HYSICAL PROPERTIES for mechanical insulation materials are normally found on the respective materials’ data sheet. In comparing materials, it is important to be sure the physical properties being com pared are tested to the same test method, procedure, and the values are expressed in the same units. If not, a true comparison is very difficult, if simply not impossible. All physical properties are important, and it is equally important to understand the effect each will have on the insulation systems performance. Two such properties that are extremely significant, and often misunderstood, in below ambient applica tions, are water vapor permeability and permeance.

A February 2013 article in Insulation Outlook, by Biji Thomas, (Perspectives on Water Vapor, Permeance Mechanical Insulation Systems) served as a great reminder as to the importance of under standing permeability and permeance. “Both are measures of a material’s ability to resist penetration of moisture from the air. The terms are defined in ASTM Standard C168-10, “Standard Terminology Relating to Thermal Insulation” as follows: Water vapor permeability - the time rate of water vapor transmission through unit area of flat material of unit thickness induced by unit vapor pressure difference between two specific surfaces, under specified temperature and humidity conditions. Water vapor permeance - 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. Permeability is measured in units of perms-inch and is used to compare materials that are typically used in a variety of thicknesses (¼” or greater). Permeance is measured in units of perms and is used to describe thinner materials (e.g., jacketing products) that are used in the field in the exact thickness at which the material is tested.” Sound confusing? It is, but understanding those values, initially and over time, is imperative in below ambient applications. Most will tell you, as a general rule, the lower the perm the better. Equally impor tant is to understand how such things as the protective covering - jacketing being

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DESIGNING, INSTALLING AND MAINTAINING THE TOTAL INSULATION SYSTEM PROPERLY CANNOT BE OVER EMPHASIZED. “

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sealed properly, improperly sealing around penetrations, etc. will impact the long-term performance of the insulation system. Designing, installing and maintaining the total insulation system properly cannot be over emphasized. Doing one without the other will have consequences. In the selection process of the primary insulation material, you often hear about hydrophobic, and water-resistant insulation. That can also be confusing. Hydrophilic material tends to repel or not to absorb water. Water resistant material is able to resist the penetration of water to some degree but not entirely unless it and the system is zero perm. These properties are important, but they do not replace the need for understanding the permeability of the material being considered for any application. Take the time to investigate and understand all physical properties of the insulation system components and their compatibility, inspect during the application what you expect and timely and properly maintain the insulation system. When in doubt, seek help, assuming could be costly. 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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UH, OH... HERE COMES MORE REGULATIONS THAT WE NEED TO WORRY ABOUT. PART 1

As much as I love to speak and write about codes and standards, there have been several changes on the regulatory front that ammonia refrigeration facility owners and operators need to know about. Many of you have probably heard of the changes to the EPA’s Chemical Accident Prevention Provisions, of which the Risk Management Plan, is a part. These changes became effective on May 10, 2024. I will be giving a presentation at the National Conference in October about these changes and strategies for com- pliance. I will likely turn that into an article in the next edition of the Breeze. In this issue, I want to raise awareness about some changes to the Clean Water Act that will impact some of the larger facilities in our industry to some extent. Now, some of you may be familiar with the Clean Water Act as it pertains to Stormwater runoff from your facility or wastewater treatment of your process

water. In a nutshell, legislation to reduce/ eliminate water pollution was originally passed as the Federal Water Pollution Control Act in 1948. After amendments to this law were passed in 1972, it became known as the Clean Water Act (CWA). This act established the basic structure for regulating pollutant discharges into the waters of the United States and gave the EPA the authority to implement pollution control programs such as setting waste- water standards for industry. Additional amendments to this Act were passed in 1981 and 1987. Here is an excerpt from the Act: “(j)(1) Consistent with the National Contingency Plan required by subsection (c) (2) of this section, as soon as practi cable after the effective date of this section, and from time to time thereafter, the President shall issue regulations consis tent with maritime safety and with marine and navigation laws (A) establishing

By: Bill Lape and Jeff Marshall, SCS Engineers

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unfulfilled. Over the years, regulations to address this requirement of the CWA were proposed, but never finalized. In 2015, the Natural Resources Defense Council (NRDC), along with other plaintiffs sued EPA. Despite this lawsuit, the EPA pub- lished the following in the Federal Register on 09/03/2019: “…based on an analysis of the frequency and impacts of reported CWA Hazardous Substances discharges, as well as the existing framework of EPA regulatory requirements, the Agency is not establishing at this time new discharge prevention and containment regulatory requirements under CWA section 311.” With the change in administration, EPA reversed course and on March 28, 2022, the EPA published a proposed rule in the Federal Register to address such discharges. The final rule was published earlier this year on March 28, with an effective date of May 28 of this year. So what do these new rules require? There are three to four distinct steps for compliance with this new regulation. 1 Determine if your facility has a chemical covered under these new regulations. 2 Determine if your facility does or can have more than the threshold quantity on site. 3 Determine if there is a risk of substantial harm due to water release of this chemical. This evaluation must be submitted to the EPA for each chemical listed in Table 116.4 in 40 CFR

So what is the threshold quantity? It is 1000 times the reportable quantity listed in Section 311(b)(2)(A) of the CWA. In layman’s terms, take the reportable quantity threshold for calling that National Response Center and multiple it by 1,000. So, the threshold quantity for ammonia that triggers proceeding to steps 3 and possibly 4 is 100,000 pounds. A lot of you are probably going, “Whew, we don’t have that.” Remember, you need to look at all of the chemicals that you have on site and that are listed on Table 116.4. On to step 3, the Risk of Substantial Harm Criteria. Appendix A of 40 CFR 118.5 provides a form for submitting the certification to EPA. It lists several criteria that constitute substantial harm: 1 Is the facility within one-half mile of navigable waters or a conveyance to navigable waters? 2 Is the facility located at a distance such that a worst-case discharge from the facility could cause injury to fish, wildlife, and sensitive environments? 3 Is the facility located at a distance such that a worst-case discharge from the facility could cause injury to public receptors? 4 Would a worst-case discharge from the facility cause substantial harm to a public water system by causing any one, or any combination of more than one, of the adverse impacts listed below? a Violates any National Primary Drinking Water Standard or State Drinking Water Regulation, such as exceedance of a Maximum Contaminant Level; b Compromises the ability of the public water system to produce water that complies with any National Primary Drinking Water Standard or State Drinking Water Regulation; c Results in adverse health impacts in people exposed to the maximum concentration that could enter a drinking water distribution system; d Contaminates public water system

methods and procedures for removal of discharged oil and hazardous substances, (B) establishing criteria for the develop ment and implementation of local and regional oil and hazardous substance removal contingency plans, (C) establish ing procedures, methods, and equipment and other requirements for equipment to prevent discharges of oil and hazardous substances from vessels and from onshore facilities and offshore facilities, and to contain such discharges...” Regulations addressing the oil pollution portion of the CWA were promulgated in 1976. They are found in 40 CFR Part 112, Oil Pollution Prevention, which are the source regulations for, amongst other things, Spill Prevention, Control, and Countermeasures (SPCC) plans, and Facility Response Plans (FRP) for larger quantities of oil on site. However, the requirements to regulate the discharge of hazardous substances remained

116.4 that is over the threshold quantity on site at the facility.

4 If it is determined that there is a risk of substantial harm due to the release of a

listed chemical into water, then a Facility Response Plan must be prepared and implemented AND submitted to the EPA.

Ammonia is found in Table 116.4, so step #1 is satisfied for this chemical. It should be noted that there may be others at your facility that could be covered, particularly those found in sanitation chemicals, such as phosphoric acid, nitric acid, sodium hydroxide, and sodium hypochlorite, depending upon whether or not the threshold quantity is exceeded.

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• Reportable discharge history • Notification requirements and discharge info • Personnel roles and responsibilities • Evacuation plans • Discharge detection systems • Response actions • Disposal plans • Containment measures

• Training procedures • Exercise procedures • Self-inspection • Emergency response action plan

In addition to submitting this FRP to the EPA, it must be coordinated with the Local Emergency Planning Committee (LEPC) in a manner similar to the Emergency Response Coordination requirements found in the RMP requirements. Much of the information that is required in the FRP is based upon the plans, procedures, training, and coordination that is required for Emergency Action (EAP) and/or Emergency Response Plans (ERP) for toxic releases to air. It is critically important to make sure that the information presented in the FRP do not conflict with the information presented in your EAP or ERP. The deadline to submit both the Risk of Substantial Harm Certification and the Facility Response Plan is June 1, 2027, shortly after the deadline for several of the new RMP provisions. It is important to evaluate the facility and determine the Risk of Substantial Harm soon so that you give yourself enough time to develop the FRP prior to the deadline. 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 Treasurer of the Refrigerating Engineers and Technicians Association. Jeff Marshall, PE is a chemical engineer with over 42 years of experience in hazardous materials management and compliance, including scores of SPCC Plans and FRP plans.

Figure 1: Flowchart of CWA FRP Applicability

infrastructure, including but not limited to intake structures, treatment facilities, and distribution systems, or premise plumbing systems to a degree that requires remediation to restore system components to acceptable performance; or e Impairs the taste, odor, or other aesthetic characteristic of the water entering a drinking water distribution system to a degree that could make the water unacceptable to consumers and that could prompt the public water system to issue use restrictions. 5 Has the facility experienced a reportable CWA hazardous substance discharge to navigable waters within the last five years? Answering these questions may require chemical specific toxicity information, along with surface water calculations and modeling. The requirements for modeling the worst-case release scenario have some similarities to the worst-case release

scenario in the RMP requirements. Details on the modeling requirements may be found in 40 CFR 118.10 and in Appendix B of that section. It is important to note that there are no provisions for active or passive mitigation or secondary containment when modeling the worst-case scenario. If the analysis of the facility determines that there is a risk of substantial harm, then it must proceed with the development and implementation of a Facility Response Plan (FRP). The requirements for such plans are listed in 40 CFR 118.11. They are similar to the requirements of an SPCC for oil but are considerably more complex. They must include: • Identification qualified individual with authority to implement • Response resources, personnel and equipment, contractors • Training, testing and drills • Facility details • Owner/operator • Hazard Evaluation, chemical info, risk ID, risk characterization, risk control, risk communication,

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The ammonia refrigeration industry is always changing, sometimes for the good and sometimes for the not so good. One of the changes is the coming and going of personnel. Workers get promoted, retire, or find different career paths, and new people are hired. With these changes, there is a constant need to train new people on all the systems. Some of these people will have a strong background in refrigeration while for others, it will be a completely new experience. This article is an operator’s perspective on ways to deal with this challenge for both the new hires and the veteran operators. For someone just entering this field, the question, “How and where do I begin?” will probably go through their mind. The first step will hopefully be an orientation session that will explain the company’s work rules, emergency action plans, facility layout, safety policies, and general procedures. Depending on the plant and staffing con- ditions, this could be a gradual training program on the plant’s systems or a crash course. Then the hard work begins! Hopefully the new operator will have a skilled and patient mentor who will show and explain the layout, how things operate, and what is expected of the operator. To the new operator, trying to learn the whole system all at once is a daunting task and will probably lead to frustration and questioning how can this actually be accomplished while maintaining one’s sanity. A way to approach this is to answer the question, “How do you eat a hippopotamus?”The obvious answer is: one bite at a time. The same applies to learning the ammonia system. Firstly, depending on the new operator’s experience, learning the basic refrigeration cycle will help with the understanding of how the system components work together. The next step is to locate and use the Piping and Instrumentation Drawings (P&IDs) and Standard Operating Procedures (SOPs) to learn the system. The SOPs detail how to operate the piece of equipment, including starting, shut down, valve positions, operating parameters, emergency procedures, and preparing the equipment for maintenance.

P&IDs illustrate the piping and valve layouts. This drawing is the road map of the system. P&IDs show the position of the valves (normally open or normally closed), pressure and temperature gages, transducers, pressure switches, and level switches, just to name a few. P&IDs are used in conjunction with SOPs to safely operate and maintain the ammonia system. By familiarizing yourself with these documents and using them in the learning process, the road to learning the system becomes considerably easier. Borrowing from my submarine days when I would go for a Systems Qualification Check-out, one of the first tasks was to draw the system. While one would not expect a person to recreate the whole P&ID from memory, being able to draw the valve group from a single evaporator is a building block to understanding the whole system. Learning the system in small bites makes the task much more manageable. The experienced operator should take the trainee with them when adjusting a machine and when performing planned or corrective maintenance. After the job is completed, take the component (such as a valve) that is going to be thrown away and

AN OPERATOR’S PERSPECTIVE OF AMMONIA REFRIGERATION By Gordon Rascoe

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look at the individual parts to see if the reason for failure can be determined, and then try to put it back together using the manufacturer manuals. This will help the trainee understand how things work. When working with someone, offer to help. Just remember, new workers, especially if new to the industry: Try not to get in the way! The fastest way to irritate the Trainer is running into the Trainee when trying to move around the job. Another good learning experience is when contractors are working on a piece of equipment. Ask them if you can watch. Take notes and ask questions when it will not interfere with the task being performed. Whereas the new operator is expected to learn as quickly as possible, the experienced operator should be expected to assist in facilitating the process. Just dumping a pile of books in front of the new operator and saying, “There you go!” can be counter- productive. While manuals are an important part of learning, having an experienced operator demonstrating, explaining, and making sure the new operator is performing the task correctly is vital to the smooth and safe progression of the new operator.

While the experienced operator may think that the newbie is asking too many questions or following them around too much, the new operator needs to learn. Observing and helping the veteran operator is one of the better options for learning. The veteran operator may wish to remember that they were once in the beginner’s shoes themselves! Everyone learns differently and at different rates, this should be considered during the training process. The experienced operator should share any tricks of the trade and other ‘secrets’ that will make the trainee’s and veteran’s life safer, easier, and more efficient. Keeping techniques and procedures to oneself and watching someone struggle and possibly hurt themselves or damage the equipment, is counterproductive and may cost the company a good operator. In the long run, withholding knowledge makes the experienced operator’s life more difficult because they will not have anyone willing and able to help them. The experienced operator should also keep an open mind and be willing to learn from the junior operator. Ultimately, the goal is to make everybody’s job safer, easier, and more productive.

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RETA TESTING CORNER NO. 43

EARN RETA CREDENTIALS AT THE ANNUAL CONFERENCE Dr. Ron Rodgers, RETA’s Psychometrician (testing expert) and ANSI Accreditation Manager

Two of the most effective ways for candidates to earn RETA credentials have been to complete a review class, then take their examination at the RETA Annual Conference. Over 80 RETA candidates have earned RETA credentials in the past three years after participating in review classes and/or testing at RETA annual conferences. This tradition started at the RETA Annual Conference in Monterey, CA in 2008.

All review classes at the annual confer ence are taught by RETA Authorized Instructors (RAIs). RAIs must present evidence of experience teaching in- dustrial refrigeration to become an RAI. Their recertification also requires evalu- ations from candidates they have trained to assess the quality of their instruction. RAIs must demonstrate their skills teaching refrigeration to adults in a Train the Trainer course or comparable experience.

Candidates must do their part by studying relevant references and materials BEFORE they arrive for a review class. Candidates who see complex industrial refrigeration concepts for the first time DURING a three- day review class are unlikely to earn a credential on the first try. Online training also may not be sufficient for some can- didates to master the challenging content required to earn CARO, CIRO or CRST.

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