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Dan Dettmers - Understanding RAGAGEP
Dan Dettmers - Understanding RAGAGEP
Daniel Dettmers
Industrial Refrigeration Consortium
University of Wisconsin‐Madison
Overview…
• Explain IIAR Standard 9: Standard for Recognized and Generally
Accepted Good Engineering Practices (RAGAGEP) for Existing
Closed‐Circuit Ammonia Refrigeration Systems
• Not…I’m not that smart, people
• Examine the RAGAGEP Landscape
• Codes – alphabet soup: IMC, UMC, CMC
• International Institute of Ammonia Refrigeration (IIAR) Standards
• American Society of Mechanical Engineers (ASME) Code
• American Society of Heating, Refrigerating, and Air Conditioning
Engineers (ASHRAE) Standard
• Common gaps
• Adherence
What the heck is “RAGAGEP”?
• An acronym derived from requirements in the process safety
information portion of PSM where it states all equipment in
PSM-covered process must comply with:
Recognized And
Generally Accepted
Good Engineering Practices
This requirement also appears in RMP – Program 3 facilities §68.65(d)(2) & (3).
PSM and RAGAGEP
Mechanical Integrity – 1910.119(j)(4)
• (ii): Inspections and tests are performed on
process equipment subject to the standard's
mechanical integrity requirements in
accordance with RAGAGEP; and
• (iii): Inspection and test frequency follows
manufacturer's recommendations and good
engineering practice, and more frequently if
indicated by operating experience.
This requirement also appears in RMP – Program 3 facilities §68.73(d)(2) & (3).
“RAGAGEP” has been confusing
• End‐users and regulators have not agreed what
constitutes RAGAGEP
• What RAGAGEP applies to my ammonia refrigeration
system?
• What do I need to show compliance? Especially on a
system that has had phased growth through many
years.
• Fed OSHA responded by developing guidance through
preparation of a “RAGAGEP Memo”
• Expect other regulators to refer to the
contents of the Fed OSHA memo
OSHA RAGAGEP Memo
• Issued to Regional Administrators on May 11, 2016
• Intended to provide clarification and direction on RAGAGEP
(rescinds prior memo issued 6/5/15)
• Provided examples of RAGAGEP
• Widely adopted codes (NFPA 70)
• Consensus standards and recommended
practice documents (ASME B31.5, IIAR 2)
• Non‐consensus documents (mfgr recommendations)
• Internal standards (as appropriate)
OSHA RAGAGEP Memo provides
clarification on “Shall” vs. “Should”
“Shall”, “shall not”, “must”, “must not”, …
• Represents a mandatory minimum requirement
• If an employer deviates, OSHA assumes a violation and employer
will have an opportunity to explain the deviation from RAGAGEP
“Should”, “should not”, “can”, “can not”, …
• Denotes a recommendation that reflects an acceptable and
preferred practice
• If an employer deviates, OSHA will not presume a violation but
CSHO will evaluate
approach to see if it
reflects RAGAGEP (ASME B31.5‐2016)
(IIAR Bulletin 110)
OSHA RAGAGEP Memo clarification
on “informative” vs. “normative”
Appendices or annexes that are normative may contain
“shall” and “should”
• Employers are expected to meet the shall provisions
Appendices or annexes that are informative
• Employers should read and consider these sections, but
OSHA does not expect IIAR Standard 5
employers to consult Appendix A: (Normative) Pressures
Appendix B: (Normative) Machinery Rooms and Auxiliary Safety
all of the sources that Equipment
are cited in an Appendix C: (Normative) Leak Test, Evacuation and Dehydration
Appendix D: (Informative) Pre‐Charging and Pre‐Start‐Up Check Lists
informative section Appendix E: (Informative) Purging
Appendix F: (Informative) Considerations and Planning for Closed‐
or appendix Circuit Ammonia Refrigerating System Tie‐Ins
Appendix G: (Informative) Temperature Reduction Procedure for
Newly Constructed Cold Storage Areas
Appendix H: (Informative) Pressure Chart
International Mechanical Code
• Current version is IMC 2015
• State & local jurisdictions may
adopt by reference
• Relies heavily on ASHRAE 15 and
IIAR 2 for technical content on
refrigeration
US Mechanical Code Coverage
None
UMC
Minimal codes
International Mechanical Code
• Scope:
• Regulate the design, installation, maintenance, alteration
and inspection of mechanical systems that are permanently
installed and utilized to provide control of environmental
conditions and related processes within buildings.
• Intent:
• To provide minimum standards to safeguard life or limb, health,
property and public welfare by regulating and controlling the
design, construction, installation, quality of materials, location,
operation and maintenance or use of mechanical systems.
International Mechanical Code
Mechanical Systems Covered
– Ventilation – Boilers, water
– Exhaust systems heaters, and
– Duct systems pressure vessels
– Combustion air – Refrigeration
– Chimneys and vents – Hydronic piping
– Appliances and fuel – Fuel oil piping & storage
burning equipment – Solar systems
International Mechanical Code
1101.6 General
Refrigeration systems shall comply with the
requirements of this code and, except as modified
by this code, ASHRAE 15. Ammonia‐refrigerating systems
shall comply with this code and, except as modified by
this code, ASHRAE 15 and IIAR 2.
California Mechanical Code Looks Solely
to IIAR for Ammonia Refrigeration
• Chapter 11 covers refrigeration systems
CMC states that ammonia
refrigeration systems
must comply with IIAR 2,
IIAR 3, and IIAR 5
List of IIAR Standards Applicable
to Ammonia Refrigeration
• IIAR 1‐2017 ‐ Definitions and Terminology used in IIAR Standards
• IIAR 2‐2014 ‐ Standard for Safe Design of Closed‐Circuit Ammonia
Refrigeration Systems
• IIAR 3‐2017 – Ammonia Refrigeration Valves
• IIAR 4‐2015 – Installation of Ammonia Refrigeration Systems
• IIAR 5‐2013 ‐ Start‐up and Commissioning of Closed‐Circuit Ammonia
Mechanical Refrigerating Systems
• IIAR 7‐2013 ‐ Developing Operating Procedures for Closed‐Circuit
Ammonia Mechanical Refrigerating Systems
• IIAR 8‐2015 ‐ Decommissioning of Closed‐Circuit Ammonia
Refrigeration Systems
IIAR Standards Under Development
• IIAR 6 – Inspection and Maintenance of Closed‐Circuit
Ammonia Mechanical Refrigerating Systems
• IIAR 9 – RAGAGEP for Closed‐Circuit Ammonia
Mechanical Refrigerating Systems
• IIAR CO2 ‐ Standard for Safe Design of Carbon Dioxide
Refrigeration Systems
IIAR 2 (2014)
IMC, UMC, CMC require ammonia systems to comply with IIAR 2.
Standard for Safe Design of Closed‐Circuit
Ammonia Refrigeration Systems
Purpose:
Specifies minimum requirements for the safe design of closed‐
circuit ammonia refrigeration systems.
Scope:
Applies to stationary closed‐circuit refrigeration systems
utilizing ammonia as the refrigerant.
IIAR 3 (2017)
This standard is generally aimed at valve manufacturers.
Ammonia Refrigeration Valves
Purpose:
to specify performance criteria for valves and strainers used in
closed‐circuit ammonia refrigeration systems
IIAR 5 (2015)
CMC requires ammonia systems to comply with IIAR 5.
Start‐up and Commissioning of Closed‐Circuit
Ammonia Mechanical Refrigerating Systems
Purpose:
Specifies criteria and procedures for start‐up and
commissioning of closed‐circuit ammonia mechanical
refrigerating systems.
ASME Boiler & Pressure Vessel
Code: Section VIII Div. 1 (2015)
IIAR 2 requires vessels to comply with this ASME code.
• Applicable to pressure vessels used for containment
of pressure (internal or external)
• Covers materials, design, fabrication, examination,
inspection, testing, certification
• Includes requirements for pressure relief protection
ASME B31.5 (2016)
IIAR 2 requires piping to comply with ASME B31.5
• Covers the design and construction of refrigeration
piping, heat transfer components and secondary
coolant piping
• The requirements of this standard must be met
before startup of the system
• Covers all refrigerants, not just ammonia
ASHRAE 15 (2016)
Oregon code calls for complying with IIAR 2 and ASHRAE 15
• Specifies safe design, construction, installation, and
operation of refrigeration systems
• Establishes safeguards for life, limb, health, and
property and prescribes safety requirements
• Applies to all refrigerants, not just ammonia
RAGAGEP “snowball” example ‐ piping
Consider the normative reference standards
identified in IIAR 2 – “snowball”
High level RAGAGEP for NH3 systems
* Guideline document Maintenance provisions for
ISEA Z358.1
eyewash and safety showers
Be aware of code & standard traps!
One Example:
• Consider the following normative requirements
from the International Fire Code & International
Mechanical Code
(IFC 2015)
(IMC 2015)
(IFC 2015)
Be aware of code & standard traps!
(cont.)
• Allows users to select from a database of
RAGAGEP “questions” based on specified criteria
• Standard, Project phase, Location, and Equipment
• Can individually pick questions if desired
• Questions “interrogate” compliance with RAGAGEP
• Best suited for design, maintenance, and infrastructure reviews
Questions?
37
Additional
information on
RAGAGEP
38
IIAR 2 – 2014, excerpts
39
IIAR 2
Table of Contents
1. Purpose, scope, applicability
2. Definitions Part 1: General
3. Reference standards
4. Location of ammonia refrigeration
machinery
5. General system design requirements Part 2: Design
and Installation
6. Machinery rooms Considerations
7. Refrigeration equipment located in areas Affecting Construction
other than machinery rooms
IIAR 2 – 2014
Table of Contents
8. Compressors
9. Refrigerant pumps
10. Condensers
11. Evaporators
12. Pressure vessels
Part 3: Equipment
13. Piping
14. Packaged systems & equipment
15. Overpressure protection devices
16. Instrumentation & controls
17. Ammonia detection and alarms
IIAR 2 – 2014
Part 4 Appendices
Appendix A ‐ Explanatory material
Appendix B ‐ Ammonia characteristics and properties
Appendix C ‐ Methods for calculating relief capacity for HX internal loads
Appendix D ‐ Duplicate Nameplates on Pressure Vessels
Appendix E ‐ Method for calculating capacity for compressor PRV
Appendix F ‐ Pipe Hanger Spacing, Hanger Rod Sizing, and Loading
Appendix G ‐ Hydrostatic Pressure Relief
Appendix H ‐ Stress Corrosion Cracking
Appendix I ‐ Emergency Pressure Control Systems
Appendix J ‐ Machinery Room Signs
Appendix K ‐ Alternative ventilation calculation methods
Appendix L ‐ Pipe, fittings, flanges, and bolting
Appendix M ‐ Operational containment
Appendix N ‐ Reference and sources of references ‐ Normative requirement
‐ Informative
IIAR 3 – 2017
Ammonia Refrigeration Valves
Scope:
• Applies to shut‐off valves, control valves, check valves, ball valves, gauge
valves, and strainers designed and manufactured for use in closed circuit
mechanical refrigerating systems utilizing ammonia as the refrigerant.
• Includes criteria for materials of construction, pressure‐containing
envelope, seat leakage, quality assurance, marking, and production
testing applicable to finished products as delivered by the original
manufacturer.
• Applies to actuator elements that form a part of the pressure‐containing
envelope on valves.
• Applies to valves incorporating a mechanical actuating float or other
mechanism exposed to the refrigerant.
• Compliance with this standard shall not be required for products
manufactured prior to the publication date of this standard.
IIAR 4 ‐ 2015
Installation of Closed‐Circuit Ammonia
Refrigeration Systems
Purpose:
Specifies minimum requirements for the safe installation of closed‐
circuit ammonia mechanical refrigeration systems and overpressure
device piping when used in conjunction with a closed‐circuit
ammonia refrigeration system.
Scope:
Standard for the installation of closed‐circuit ammonia mechanical
refrigeration systems.
Excludes: absorption systems, functionally‐equivalent replacement
parts, equipment installed prior to effective date of standard.
IIAR 4 – 2015
Table of Contents
1. Purpose 8. Evaporator Installation
2. Scope 9. Pressure Vessel Installation
3. Definitions 10. Pipe and Valve Installation
4. Normative References 11. Components and Controls
Installation
5. General Requirements 12. Insulation
6. Compressor Installation 13. Testing of Installation
7. Condenser Installation 14. (Informative) References
and Sources of References
IIAR 5 ‐ 2013
Start‐up and Commissioning of Closed‐Circuit
Ammonia Mechanical Refrigerating Systems
Purpose:
Specifies criteria and procedures for start‐up and commissioning of closed‐
circuit ammonia mechanical refrigerating systems.
Scope:
Provides minimum requirements for safe start‐up and commissioning of
closed‐circuit mechanical refrigerating systems and equipment.
Unless otherwise noted, it is the responsibility of the owner or the
owner’s representative to obtain or otherwise arrange for the
completion of all requirements in this Standard.
IIAR 5 – 2013 (cont.)
Start‐up and Commissioning of Closed‐Circuit Ammonia
Mechanical Refrigerating Systems
Scope:
2.1 This Standard provides basic minimum requirements for the safe start‐up and
commissioning of completed closed‐circuit mechanical refrigerating systems utilizing
ammonia as the refrigerant and to additions and modifications made to such systems…
2.2 Start‐up and commissioning shall be performed, at a minimum, in accordance with
equipment manufacturer’s instruction manuals. This standard focuses on practices that
promote safety.
2.3 This standard refers to those parts of a refrigerating system that are in contact with
ammonia.
2.4 Unless otherwise noted, it is the responsibility of the owner or the owner’s
representative to obtain or otherwise arrange for the completion of all requirements in
this Standard. It is permissible for the owner or the owner’s representative to delegate
this responsibility by contract.
IIAR 5 – 2013
Contents
6. Records
1. Purpose
7. Start‐Up of New Installations
2. Scope
8. Start‐Up of Additions and
3. Definitions Modifications to Existing
4. References Installations
5. General Ammonia Information 9. Sources of References
IIAR 5 – 2013
Contents
Appendix A ‐ Pressures
Appendix B ‐ Machinery Rooms and Auxiliary Safety Equipment
Appendix C ‐ Pressure Test, Evacuation and Dehydration
Appendix D ‐ Pre‐Charging and Pre‐Start‐Up Check Lists
Appendix E ‐ Purging
Appendix F ‐ Considerations and Planning for Closed‐Circuit Ammonia
Refrigerating System Tie‐Ins
Appendix G ‐ Temperature Reduction Procedure for Newly Constructed
Cold Storage Areas
Appendix H ‐ Pressure chart
‐ Normative requirement
‐ Informative
IIAR 5 – 2013, excerpts
Design Records:
6.1.1 The system shall have been designed by, and installed under the
supervision of, persons who by reason of knowledge, training and
experience are competent for the tasks. Such persons typically include:
a. experienced refrigeration contractors, possibly in combination with a
code authority, authorized inspection agency or property insurance
underwriter
b. in‐house design/engineering staff of the owner or the owner’s
designated representative
c. consulting engineers, acting on behalf of the owner or the owner’s
designated representative
d. refrigeration equipment suppliers.
IIAR 5 – 2013, excerpts (cont.)
Design Records:
6.2.1 A system component inventory list shall be prepared. The list shall
include the major components of the ammonia refrigerating system,
including: compressors, condensers, evaporators, pressure vessels, liquid
ammonia pumps, piping, valves and fittings, ammonia machinery room
ventilation system, and
other control and safety devices.
6.2.2 The inventory list shall contain a record of the maximum working
pressure(s) and minimum temperatures as applicable.
6.3 Records shall be kept of these tests. These tests shall be completed
before the refrigeration system is charged with ammonia
IIAR 5 – 2013, excerpts
Initial Status and Safety Provisions:
7.8.1 Before the system is charged with ammonia, it shall be verified
• designed and built in accordance with the requirements of the governing edition of IIAR 2
(ref. 4.1.3)
• cleared of all …obstructions that could impede egress in…an emergency
• Emergency lighting…ventilation fans are ready for operation.
• Required first aid and safety equipment is available.
7.8.2 The owner shall ensure that eye wash and deluge shower facilities
are available
7.8.3 Before system is charged and put into service, it shall be confirmed
that the local emergency authorities are aware that ammonia is used or is
to be used at that location.
IIAR 5 ‐ 2013
Commissioning:
7.15.2 During the commissioning of the system the trained start‐
up technician shall involve the persons responsible for the day‐
to‐day operation of the system.
7.15.3 The system shall be operated to demonstrate correct
function…
7.15.4 Following the training of the system operators…and there
has been a period of continuous and fault free running, the
refrigeration system may be handed over...
ASME B31.5 – Key Contents
• Chapter 1 – Scope & Definitions
• Chapter 2 – Design
• Chapter 3 – Materials
• Chapter 4 – Dimensional Requirements
• Chapter 5 – Fabrication and Assembly
• Chapter 6 – Examination, Inspection, and Testing
ASME B31.5 ‐ Scope
500.1.1 Code prescribes requirements for the
materials, design, fabrication, assembly, erection, test,
and inspection of refrigerant, heat transfer
components, and secondary coolant piping for
temperatures as low as −320°F (−196°C), whether
erected on the premises or factory assembled, except
as specifically excluded
B31.5 – Design considerations
• 501.5 – Dynamic Effects
• Impact forces (including hydraulic shock and liquid slugging)
• Wind (for exposed piping)
• Earthquake (seismic forces)
• Vibration
• Discharge reactions
• 501.6 – Weight Effects
• Live loads
• Dead loads
• Test loads
B31.5 Design criteria overview
• 502.3 – Allowable Stresses & Other Stress Limits
• Table 502.3.1 establishes allowable stress valves to be used for design
calculations but the code does define some modifications
Allowable stress to 100F material temperature.
IIAR Informative Reference to EPCS
(IIAR 2‐ 2014)