Mechanical Integrity Inspections of Ammonia Refrigeration

1
Mechanical Integrity Inspections of Ammonia
Refrigeration
Peter Thomas, P.E. pthomas_at_resourcecompliance.com
559.994.0162 - AmmoniaPeter
2
Question

• Why are there so many safety and environmental
  regulations?

3
Oppau, Germany 1921

• 4,500 tons of Ammonium Sulfate/Ammonium Nitrate
  mixture exploded
• 500-600 people killed
• 2,000 people injured

Largest man-made explosion prior to atomic bomb
4
Bhopal, India 1984
5
Bhopal, India

• Background Union Carbide built in 1969 to
  produce the pesticide Sevin using methyl
  isocyanate (MIC). MIC production plant was added
  in 1979.
• Accident On December 2-3, 1984 water entered a
  tank containing 42 tons of MIC. The water caused
  an exothermic reaction. 30 metrics tons of MIC
  escaped and dispersed over Bhopal.

6
Bhopal, India

• Consequences
• 2,259 died immediately
• 3,787 total deaths
• Some estimate 8,000 died within two weeks and
  another 8,000 or more have died.
• 2006 government report stated that it caused
  558,125 injuries 38,478 temporary partial
  disabling injuries 3,900 severely and
  permanently disabling injuries

7
(No Transcript)
8
Bhopal, India

• Possible Causes
• Employees Workers cleaning out a clogged pipe
  with water about 400 feet from the tank.
• Union Carbide Water was introduced directly into
  the tank as an act of sabotage by a disgruntled
  employee. Water could have been introduced via a
  connection to a missing pressure gauge.

9
Bhopal, India

• Possible Causes
• Government 1985 report cited the following
• Storing MIC in large tanks and filling beyond
  recommended levels
• Poor maintenance practices
• Failure of safety systems due to poor maintenance
• Safety systems being switched off to save money -
  including the MIC tank refrigeration system which
  would have mitigated the disaster

10
Bhopal, India

• Union Carbide made large attempts to reduce
  expenses
• There were examples of leaking pipes that weren't
  replaced
• Indian employees only had access to English
  manuals
• The MIC tank alarms had not been working for four
  years.

11
Bhopal, India

• There was only one manual back-up system,
  compared to a four-stage system used in the
  United States.
• The flare tower and several vent gas scrubbers
  had been out of service for five months before
  the disaster.
• The steam boiler, intended to clean the pipes,
  was in-operational for unknown reasons

12
Bhopal, India

• According to the operators, the MIC tank pressure
  gauge had been malfunctioning for roughly one
  week. Other tanks were used, rather than
  repairing the gauge. The build-up in temperature
  and pressure is believed to have affected the
  magnitude of the gas release.
• Carbon steel valves were used at the factory,
  even though they were known to corrode when
  exposed to acid.

13
More Recent News

• OSHA cites paint business 138K for PSM
  deficiencies http//ow.ly/eiL7X
• Man threatens police with a cylinder of
  anhydrous ammonia http//ow.ly/elvGo
• Fire fighters injured during NECCO ammonia leak
  response
• Ammonia leak at a winery causes evacuations, road
  closures
• More on the Fresno ammonia leak
  http//ow.ly/eoYHh
• Man accused of threatening police with ammonia is
  arrested 
• Road reopened following a sulfur dioxide leak
  http//ow.ly/er93z
• Another ammonia spill
• Hospital evacuated after ammonia leak
  http//ow.ly/ewhTw
• Copper thieves nearly cut through an
  ammonia pipe http//ow.ly/eyZEh
• Anhydrous ammonia thief caught http//ow.ly/eFauN
• 30 hospitalized after Hubei ammonia gas leak -
  Xinhua http//ow.ly/eHuiw
• Ammonia appears to be the cause of a large fish
  kill in Iowa http//ow.ly/eVi6L
• Man has ammonia thrown at him in Gravesend
  restaurant http//ow.ly/f3R9S
• Ammonia leaks from ice factory http//ow.ly/f7Hw1
• Ammonia Leak Contained At Newark
  Warehouse http//ow.ly/ffINm
• Ammonia leak forces evacuation of Salina
  plant http//ow.ly/fgE5o
• Several people indicted for unlawful possession
  of ammonia http//ow.ly/flRW4
• OSHA Hands Out 55,000 In Fines For Ammonia
  Spill http//ow.ly/flS1F

14
(No Transcript)
15
(No Transcript)
16
How Accidents Happen
17
Question

• Why are there so many safety and environmental
  regulations?
• Answer
• Historically there have been catastrophic process
  safety accidents that have injured and killed
  hundreds of thousands of people and also caused
  significant environmental damage. These accidents
  are typically caused by human error or mechanical
  failure.

18
General Duty Clause

• Under the Clean Air Act Section 112(r)(1), all
  facilities that use hazardous chemicals in any
  quantity, have a general duty to prevent
  releases, and to minimize the consequences of
  accidental releases which do occur.
• This applies to any facility regardless of the
  chemical inventory

19
Mechanical Integrity Requirements

• Mechanical Integrity requirements for CalARP
  include
• Inspection and Testing
• Training
• Written Procedures
• Correction of Deficiencies
• Quality Assurance

20
MI Applicability

• CalARP Mechanical Integrity applies to
• Pressure vessels and storage tanks
• Piping systems (including valves)
• Relief and vent systems
• Emergency shut down systems
• Controls (monitoring devices, sensors, and
  interlocks)
• Pumps
• PSM Mechanical Integrity applies to
• Equipment and appurtenances

21
Inspection and Testing

• Inspections shall be performed
• Inspections shall follow recognized and generally
  accepted good engineering practice (RAGAGEP)
• Frequency of inspections shall be based on
  manufacturers recommendations, RAGAGEP, and
  prior operating experience
• Inspections shall be documented

22
MI Training

• Each employee involved in maintaining the
  on-going integrity of process equipment must be
  trained
• in an overview of the process
• in the process hazards
• in the procedures applicable to the employee's
  job tasks
• The purpose of MI training is to assure that the
  employee can perform the job tasks in a safe
  manner

23
RETA Certification
24
Written Procedures

• Written mechanical integrity procedures must be
  developed and implemented

25
Deficiencies

• Equipment deficiencies must be corrected before
  further use
• Key word MUST

26
Common Deficiencies
27
Common Deficiencies
28
Common Deficiencies
29
Common Deficiencies
30
Quality Assurance

• New Equipment
• Must be suitable for the application
• Existing Equipment
• Must be properly installed compared to design
  specifications
• Maintenance Materials (and PPE)
• Must be suitable for the application

31
Quality Assurance
32
RAGAGEP

• Examples of RAGAGEP for ammonia refrigeration
  systems

33
IIAR Bulletins
34
IIAR Bulletins
35
IIAR Suite of Standards

• IIAR 1 Definitions
• IIAR 2 Equipment and Design
• IIAR 3 Valves
• IIAR 4 Installation
• IIAR 5 Start-up and Commissioning
• IIAR 6 Maintenance
• IIAR 7 Operating Procedures
• IIAR 8 Decommissioning

36
RETA
37
Industry Forums
38
ASHRAE

• ASHRAE 15
• ASHRAE 34

39
(No Transcript)
40
Why Mechanical Integrity?
PSSR
MI
41
Maintenance Programs

• Reactive Maintenance
• Preventive Maintenance
• Predictive Maintenance
• Reliability Centered MaintenanceInformation
  courtesy of U.S. Department of Energy

42
Reactive Maintenance

• Run it til it breaks
• No maintenance efforts are made from commission
  until failure
• Predominant mode of maintenance (55 of all
  maintenance is reactive)

• Pros
• Low Budgeted Cost
• Less Staff

• Cons
• Unplanned downtime
• Overtime
• More expensive repairs
• Inefficient use of staff

43
Preventive Maintenance

• Actions performed on a time- or machine-run-basis
• Developed by U.S. Navy
• 12-18 savings over reactive maintenance
• i.e. Changing oil in your car every 3,000 miles

• Cons
• Labor intensive
• Includes performance of unnecessary maintenance
• Potential for incidental damage to components in
  conducting unneeded maintenance

• Pros
• Reduced downtime
• Increased life cycle
• Energy savings
• Flexible scheduling
• Catastrophic failure less likely

44
Predictive Maintenance

• Differs from preventive in that maintenance
  schedule is based off actual condition as opposed
  to a preset schedule
• i.e. Testing your car oil may show that it is
  good for 10,000 miles

• Cons
• Investment in diagnostic equipment
• More staff training required
• Savings potential harder to see

• Pros
• Increased life and availability
• Preemptive actions
• Decreased parts and labor
• 8-12 savings over preventive

45
Maintenance Example

• Corroding refrigerant pipe
• Reactive Do nothing, leak develops, replace
  entire pipe
• Preventive Implement a company policy of
  repainting/reinsulating all refrigerant pipes
  yearly
• Predictive Use visual inspection or a thermal
  imager yearly to determine problem areas and
  paint if necessary
• Ideal program is
• lt10 Reactive
• 25-35 Preventive
• 45-55 Predictive

46
Reliability Centered Maintenance

• Not all equipment is of equal importance
• Use company resources in the most cost effective
  way
• Combines the predictive and preventive

• Pros
• Most efficient
• Minimize frequency of intervals
• Focus on critical equipment

• Cons
• Significant startup cost, training, equipment
• Savings potential not easily seen

47
Reliability Centered Maintenance
Reactive Applications Preventive Applications Predictive Applications
Small parts and equipment Equipment subject to wear Equipment with random failure patterns
Non-critical equipment Consumable equipment Critical equipment
Equipment unlikely to fail Equipment with known failure patterns Equipment not subject to wear
Redundant systems Manufacturer recommendations Systems which failure may be induced by incorrect preventive maintenance
48
Summary
49
Questions?

• Peter Thomas, P.E.
• pthomas_at_resourcecompliance.com
• 559.994.0162
• - AmmoniaPeter