During a recent project the SAFTENG team came across an interesting “change” to a covered process that fits the “changes to facilities” perfectly. The covered process was a Selective Catalytic Reduction (SCR) unit on a coal fired boiler. The unit was having problems during cooler months with the ammonia condensing before it reached the SCR unit. The distance between the vaporizer(s) and the injectors was about 120′ vertical and this was just too far. So the facility built a room (four walls, roof, and two doors) around where the ammonia went into the injection header. In order to keep the room hot, they installed a gas fired heater at ceiling height. The room had no ventilation and was not designed to a Class I Division 2 location.
When asked about an MOC for this change, we got the look of wonderment, but the light soon came on. This is a perfect example of a “change to facilities” that would require an MOC. It actually created a new hazardous location in a process that was, before the room, 100% “outside” and did not require any areas be electrically classified areas. The facility was left with either installing ventialtion meeting a RAGAGEP or making the room an electrically classified hazardous location.
“Changes to facilities” are changes that many facilities still struggle with, but many of these changes have been found to be factors in accidents and should never be viewed as “minor” or “insignificant”.