One phrase that drives me crazy while working with my friends in the Ammonia Refrigeration industry is,
“Come on, Bryan; we’re not a refinery or chemical plant; that is unnecessary here.”
For example, recently, we were asked to aid in an investigation into a reportable release from a PSM/RMP-covered process, and during our review of what happened, the facility failed to mention that their process was built with an Emergency Pressure Control Systems (EPCS), a term used by IIAR and many of the other codes and standards that pertain to mechanical refrigeration processes. These systems are now a requirement in most states and are intended to reduce releases of NH3 (as well as other refrigerants) to the atmosphere. Obviously, in this case, something did not work as planned. After a quick visit to the EPCS location, we found the required maintenance isolation valves on BOTH SIDES of the EPCS closed. Further investigation indicated that they had most likely been closed for many years, as the last time any work was done on the EPCS was eight years earlier (when we assumed the valves were closed and not re-opened).
A root cause failure that led to the release?