In response to the tragic 2017 incident in which several people were killed by exposure to ammonia at an ice arena in Fernie, British Columbia, ABSA is now extending the scope of the plant registry to include ammonia refrigeration plants and they just published new guidance and establishes requirements for the ammonia-bearing refrigeration systems operating in Alberta. This new guidance was issued as a supplement to AB-512 in order to provide guidance that is MORE SPECIFIC to these ammonia-bearing refrigeration systems. The document establishes and discusses requirements for the:
- design and design registration,
- construction,
- installation,
- operation,
- maintenance,
- repairs and alterations,
- integrity assessments, and
- decommissioning
It also provides an overview of the annual self-audit reviews that owners of these facilities are REQUIRED to perform, outlines requirements for reporting unsafe conditions, accidents, and fires, and discusses the types of records that owners are required to keep.
It is NOT intended for large scale industrial facilities related to the oil & gas or petrochemical industries and does not replace any existing registered owner-user pressure equipment integrity management system or supersede any requirements established by AB-512.
Here is a breakdown of each element and its requirements and frequencies:
- Design – A refrigeration system includes compressors, pumps, brine tanks, and pressure equipment. The refrigeration system pressure equipment typically includes pressure vessels to store liquid refrigerant, evaporators, condensers, piping, fittings, and safety valves. The design of each item of pressure equipment shall be registered for use in Integrity Management requirements for Mechanical Refrigeration Systems Containing Ammonia, Issued 2020-04-27, AB-538, Edition 1, Revision 06 of 15, and have a CRN (Canadian Registration Number) number assigned. Manufacturers of the pressure equipment are responsible for obtaining the CRN and for demonstrating compliance to the appropriate code of construction. Owners must verify this requirement. Boilers, vessels, heat exchangers,and safety valves will have the CRN stamped on the nameplate. Verification of this number is required prior to the operation of the pressure equipment. Pressure piping, depending on its system volume, may be exempt from design registration. Design registration is achieved by submitting the appropriate design information to the ABSA design survey department.
- Construction – The owner must select a manufacturer or contractor that holds a Certificate of Authorization Permit for the construction of the pressure equipment. The requirement for a Certificate of Authorization Permit applies to both shop and field construction. The owner should request a copy of the manufacturer or contractor’s Certificate of Authorization Permit to be part of the quality control file for the refrigeration system. The local Safety Codes Officer requires a copy of the Manufacturer’s Data Report for any pressure vessels prior to the final installation inspection. AB-275, General Requirements for Mechanical Refrigeration Systems, shall be completed by the designer, signed, and presented to the local Safety Codes Officer. The completed-275 becomes part of the equipment records.
- Installation – A final construction inspection of the refrigeration system shall be performed by the owner’s representative and the ABSA Safety Codes Officer after the equipment has been installed and prior to commissioning/re-commissioning in order to initiate plant inspection records for the equipment and to verify that the equipment meets the Safety Codes Act, PESR, and CSA B-52. The installation inspection shall include but is not limited to:
- verifying adequate safety relief device installation,
- visual inspections of all pressure equipment,
- pressure testing of the refrigeration system,
- registration of pressure vessels in the system for the issuance of a Certificate of Inspection Permit, and
- verification of the plant capacity for the plant registry.
Additional installation inspections may consist of
-
- baseline thickness readings of piping and pressure vessels subject to corrosion,
- internal inspections of vessels,
- checking for proper pipe supports,and
- checking that all flange bolts are properly torqued.
The owner should have a checklist or have a qualified contractor perform these verifications.
Safe operating limits must be established for the system, and control devices must be verified to ensure the proper operation within the pressure equipment operating limits. The applicable requirements of CSA B52 shall be met. The owner must involve a qualified contractor familiar with refrigeration system instrumentation, electrical, pipefitting, and inspection. An ABSA Safety Codes Officer must also be present when performing these inspections. The ABSA Safety Codes Officer will request a copy of the AB-275 at this time.
- Operations – Operation is a critical responsibility for owners. The duties are short-term and long-term, which means they are to be performed daily, monthly, end-of-season, and pre-start-up. AB-615, Guidelines for care and operation of mechanical refrigeration systems containing ammonia lists, as a guide, what this might look like. AB-615 is a MINIMUM GUIDE, and the operating instructions must be modified for each specific system. Owners shall follow the manufacturer’s instructions and ensure that the equipment operates within its safe operating limits. Training of operations personnel is a critical component to ensure the safety of the facility. SOPEEC (Standardization of Power Engineer Examinations Committee) has developed an examination for refrigeration plant operator certification. Although this certification is not mandatory in the province of Alberta, the owner may choose to have its operating staff write this exam as a means of demonstrating knowledge. The owner shall ensure that operating staff are appointed and are competent in the daily operation of the system. In brief, competency may be verified by having the operator demonstrate their knowledge of the hazards associated with operating an ammonia refrigeration system, the appropriate response to an ammonia leak, as well as demonstrate the ability to both start and shutdown the system, to take daily operating readings, and to understand the operating limits of various components.
Operators must be aware of the location of safety equipment, such as safety shutdowns switches, respirators, evacuation fan switches, and the emergency dump valve. They should also know the location of the SDS (Safety Data Sheet) for the various chemicals on-site (and be familiar with their contents) as well the location of emergency contact phone numbers, such as fire and rescue, the maintenance contractor, and owner representative.
The owner shall ensure that the brine is tested for pH, residual inhibitor, and iron content two times per year, at minimum. These tests are normally accomplished by sending a small sample to a lab. The pH testing of brine is done to indicate the presence of ammonia in the brine and may be done on-site with pH test sticks. The frequency of testing shall be increased should the system require the addition of ammonia or if there is a loss of brine. A change in pH or loss of inhibitor requires immediate follow-up, as this may indicate a loss of containment. When requested, results of the brine analysis shall be presented to the Safety Codes Officer. A reputable refrigeration service company can provide guidance on brine testing.
Any loss of containment(e.g. an ammonia leak) is considered a reportable incident to ABSA. See Section 5.10 for details on reporting these types of incidents. As part of operating preparedness, the owner should contact the local fire department and municipal representatives to ensure that emergency procedures and staff training are in place in case of an incident(such as an ammonia release).
Owners, operating staff, and local emergency response personnel should be familiar with mechanical room exists, ventilation system, ammonia dump valve(s), emergency shutdowns of electrical equipment, storage of respirators and how to use them, evacuation plans of the facility, etc.
- Maintenance – Maintenance must be performed by competent, qualified personnel, whether this is done by in-house staff or a qualified contractor hired by the owner. Maintenance performed by unqualified personnel may lead to unsafe conditions. Therefore, the owner shall have documented procedures as to how in-house maintenance personnel is trained and evaluated. Any replacement of pressure components such as pipe, pipe fittings, and valves, must be of the same grade and specification as the original code of construction. Documentation of repairs and alterations must be kept on file for the life of the equipment. The owner must also ensure that safety interlocks, control systems, and safety shutdowns are identified and calibrated annually. These inspections must be documented and kept as part of the equipment file records.
- Repairs and Alterations – Owners must also refer to AB-513 (Pressure Equipment Repair and Alteration Requirements) for guidance on pressure equipment repairs. Companies that perform repairs to pressure vessels and/or piping MUST hold a Certificate of Authorization Permit issued by ABSA for the code of construction to which the vessel and/or piping were manufactured. Welders MUST hold a valid pressure welder Certificate of Competency and work under a qualified company that has the proper welding procedures. These qualification documents shall form part of the repair file. Owners who are not familiar with these requirements shall employ a representative/contractor coordinator for the repair. The scope of a proposed alteration must be presented to the local ABSA Safety Codes Officer prior to starting the alteration. Refer to the definition section of this document for the definition of an alteration. Depending on the scope of the alteration, submission to the ABSA Design Survey department for review and acceptance may be required. A change of type of refrigerant is considered an alteration that must be submitted to ABSA’s Design Survey Department for registration.
- Integrity Assessments – The owner’s pressure equipment integrity assessment program shall include all pressure equipment:
- pressure vessels,
- condensers,
- evaporators,
- heat exchangers,
- piping,
- safety valves, and
- instrumentation.
The owner shall refer to AB-506 (InspectionandServicing Requirements for In-Service Pressure Equipment). An integrity assessment program should also ensure that all fluids in the system are within their recommended specification. Contamination of one fluid by another may lead to a dangerous condition, including catastrophic failure of equipment or release of ammonia. Inspections of pressure equipment in a public occupancy facility shall be performed by an ABSA Safety Codes Officer. Owners shall follow upon all recommendations and assessment findings that show deviation from original specifications.
- Decommissioning – Pressure equipment that is decommissioned must be left in a condition that presents no risk to the public. Equipment must be properly vented and purged of any process fluid. Pressure equipment that is taken out of service as a result of its condition must be left in an unpressurized state and isolated from any process that may cause it to be pressurized. ABSA must be notified of the decommissioning of the equipment. This notification may be made using form AB-10 (Status Report).
- Program Review – Owners shall perform ANNUAL reviews (self-audits) of their integrity management system to ensure that all the elements of this AB-538 are addressed. Internal audits provide the opportunity to identify gaps and are an important part of ensuring facility safety. Any such review must be documented suitably to ensure findings and so that recommendations are not lost. If owners are not familiar with all the requirements, they should employ a consultant or contractor to perform this review. ABSA will audit the integrity management program periodically to ensure compliance with this AB-538 requirement document.
- Unsafe Conditions, Accidents, and Fires – Owners shall report unsafe conditions, accidents, and fires to the nearest ABSA office. Examples would be the release of ammonia, leak or failure of piping or piping components, failure of pressure vessels, leaking of evaporator tubes, which can cause ammonia to be released via the brine system, etc. Owners shall have DETAILED PROCEDURES and take IMMEDIATE ACTION should safety interlocks become impaired. Information Bulletin IB18-004 (Reporting Unsafe Conditions, Accidents, and Fires) was issued by the Administrator to clarify these requirements
- Equipment records per section 41(A) – The owner must maintain a current inventory of all pressure equipment items that are owned or operated by the company. The equipment records shall include:
- design information,
- data reports,
- inspection plans,
- integrity assessment reports,
- repair and alteration records,
- Certificate of Inspection Permits,
- pressure relief valve servicing records,
- annual interlock checks, and
- other relevant maintenance, servicing, and test records
Owners and vendors who sell equipment must ensure that the equipment records are provided to the new owners. The owner who acquires the equipment must ensure that relevant equipment history and other equipment records are requested, and they must assess the integrity of all purchased assets. This would include reviewing all historical data and performing inspections when required (refer to PESR Section 36). The seller must ensure that Absa is notified when there is a change of ownership or location. This notification is required for all items that are identified with an Alberta number (refer to PESR Section 36). ABSA form AB-10 may be used to notify ABSA when there is a change of ownership or location or other status changes.
APPENDIX 1–TASKS AND DUTIES
The following is a list of suggested tasks and duties that should be completed and documented (see AB-615 for more information):
- an up-to-date log of activities and condition readings two times per day while the unit is in operation
- brine temperature and pressure
- compressor(s) discharge temperature and pressure
- compressor suction pressure
- oil level and pressure
- refrigerant level
- brine level
- hour meters
- outside air temperature
Also:
- Ensure that ammonia detectors are operational
- Ensure that doors are kept closed and sealed properly
- Check brine circulation pump(s)
- Check if the condenser fan is operational
- Check for ice buildup on the evaporator(s)
- Check room exhaust fan
- Log all personnel entering and leaving the mechanical room
- Owners shall ensure the brine is tested for ammonia, iron, and pH
- Keep the mechanical room clean and FREE OF ALL COMBUSTIBLE MATERIAL