RETA Breeze Sept/Oct 2025

Further MOC and PSM

Documentation It is important to determine what is construction documentation and what should be included as part of your PSM/RMP Process Safety Infor mation (PSI). I would file the following with the Management of Change (MOC) materials, but would not con sider them part of PSI: • Inspection Reports; • Nondestructive Evaluation (NOE) Reports; • Weld Maps; • Work-In-Progress Inspection/ Testing Reports; • Testing Documentation; • Welding Documents and Welder Continuity Report(s); • Line Break Permit(s); • Ammonia Delivery Bill of Lading/ Invoice(s) and Delivery Receipts; Management or Management of Change (MOC); and • The following should be considered as PSM documentation, but I would file them in other sections of the program: • Standard Operating Procedures  file in the Standard Operating Procedure section of the PSM / RMP program. • Training Records  file in the Training section of the PSM / RMP program. • Hazard Safety Review or Assess • Pre-Startup and Safety Review (PSSR).

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Block Flow & Piping & Instrumenta tion Diagrams (P&IDs) - when completed Ammonia Charge Calculations Ammonia Delivery Bill of Lading/ Invoice(s) and Delivery Receipts Safety System & Relief Data Material & Energy Balance Pressure Vessel Data Forms & All U-Stamped Equipment Equipment and/or System Operation & Maintenance Manuals Pressure Relief Valve (PRY) Calcula tions Relief Discharge Line/Header System Calculations Machinery Room Ventilation Calculation & Ventilation System Data Change Management or Manage ment of Change (MOC) Hazard Safety Review or Assessment and/or Process Hazard Analysis (PHA) - Final Pre-Startup and Safety Review (PSSR) Standard Operating Procedures Equipment/Valve Lists ASME Ul-A, U-2, U-3 Forms

equipment where the information is no longer available. There is not a good definition that describes “safe operating conditions.” Here is what I use: if a unit has been operating at -20°F for the last 30 years, operation at -20°F is safe. if you decide to change the operating parameters to -60°F, then you need documentation. A memo won’t do because you don’t have a safe operating history under these new conditions to justify the memo. ANSI/IIAR-4 and Post-installation Docu mentation— ANSI/IIAR-4 is titled “Installation of Closed-Circuit Ammonia Refrigeration Systems.” Appendix B. (Informative) provides what insulation documentation is to be maintained. Per the text:

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B.3 AFTER INSTALLATION: •

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As-Built Drawings - Upon full installation completion

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Inspection Reports

Nondestructive Evaluation (NOE) Reports

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Weld Maps

Work-In-Progress Inspection/Testing Reports Testing Documentation - Per ANSI/ IIAR 5-2019 requirements Certificate of Compliance indicating Standards and Codes followed for installation Welding Documents (Per Section 4.4.1 and 4.4.2) and Welder Continu ity Report(s)

Training Records

Additional Items to be submitted for installation close out.

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See sidebar, titled "Further MOC and PSM Documentation," for further details on MOC and PSM documentation. Multitude of Essential PSI Documenta tion— the following diagrams, lists and drawings are crucial to having a complete PSI file: Electrical field wiring— the electrical one-line diagram is part of my PSI. I want to maintain it as current, and the easiest way to do that is to add it to my PSM/RMP program and manage changes through the management of change program.

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Line Break Permit(s)

Electrical Field Wiring & Ladder Wiring Diagrams

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PLC Programming

ment and/or Process Hazard Analysis (PHA)  file in the PHA section of the PSM / RMP program.

Process Safety Information (PSI) Installation Updates - Where PSM regulated Installation Specifications and Drawings

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18 RETA.com

SEPTEMBER/OCTOBER 2025