Field Services

Inspection Services
gap assessment

GAP Analysis is an examination of your current facilities compliance program and documentation. Following the examination, an assessment is performed to compare what your current state is compared to what your actual requirements are. Our Compliance Specialists and Engineers will then compile all the recommendations necessary to fill out your current programs. Often NEAS has all the resources required to complete any services you may need.

IIAR 6 inspections

IIAR (International Institute of Ammonia Refrigeration) continues to work diligently to help keep the industry as safe and vigilant as possible. They’re latest development of standards has set forth the minimum requirements for inspection, testing, and maintenance for closed-circuit ammonia refrigeration systems, the IIAR – 6 Inspections. All ammonia refrigeration systems, above and below the PSM/RMP 10,000lb threshold, will soon be REQUIRED to adhere to these specific inspections annually.

mechanical intergrity

Mechanical integrity (MI) is just one of the 14 elements included in Process Safety Management (PSM), driven by the OSHA 1910.119 standard, which reads that “Mechanical Integrity means the process of ensuring that process equipment is fabricated from the proper materials of construction and is properly installed, maintained, and replaced to prevent failures and accidental releases.” Mechanical Integrity is primarily centered around fixed equipment. Some examples might be pressure vessels, dispersion tanks, piping systems and attached hardware (valves, fittings, etc), relief devices, vent hardware, and emergency shutdown/control systems. Rotating equipment/assets, such as pumps, blowers, fans, and compressors that may be used to move hazardous materials within these systems, are also included. In many cases, this means that all equipment within the boundaries of a facility is subject to the Mechanical Integrity PSM standard.

Ammonia (R-717) has been a longtime, popular refrigerant choice in industrial facilities, such as cold storage warehouses, food processing plants, and chemical manufacturing plants. Now with increased regulatory activity on fluorocarbon refrigerants (i.e., HCFCs and HFCs), even more interest has grown with ammonia as a refrigerant.

The caveat, however, with this refrigerant is that it is a high health hazard, and releases of it pose a significant threat to personnel. Therefore, it needs to be properly managed. In fact, certain practices must be followed during the operation and maintenance of ammonia refrigeration systems.
While there are many safety and environmental laws on ammonia, in this article, we will focus on OSHA’s Process Safety Management (PSM) Standard (29 CFR 1910.119) and its requirements. Compliance with the PSM standard helps ensure that personnel are kept safe. Let’s get started.

How Does OSHA Define Process?

First, to understand this standard and its requirements, one must consider how OSHA uses the term “process” in PSM.

Process means “any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.”
Keeping this in mind, let’s move on to when a facility is covered by OSHA PSM.

When Is an Ammonia Refrigeration System Covered by OSHA PSM?

Ammonia refrigeration systems that have 10,000 pounds of ammonia (approximately 2,000 gallons) or more are subject to OSHA’s process safety management requirements. Specifically, this PSM standard is applicable to ammonia manufacturers and facilities with large ammonia refrigeration systems; it does not apply to retail facilities. Regardless of whether your refrigeration is covered by this standard, the requirements are recommended practices and thus those a part of industrial ammonia refrigeration applications should be familiar.

What Must a Covered Facility Do?

MT is a quick, cost-effective NDT inspection method to detect suface and near-surface discontinuiities, available in the field or in the lab. Our technicians magnetize a ferromagnetic material and apply finely-milled iron particles coated with a dye pigment to it. The particles indicate a discontinuity in the material by clustering directly over it, which can be visually detected under proper lighting conditions.

We utilize Dry Powder and Wet Fluorescent Magnetic Particle testing (MT) for finding surface/near-surface defects in ferromagnetic material. MT requires a skilled technician to distinguish between relevant and irrelevant indications. It is often used for metal cracking detection, weld verification, and stress corrosion cracking detection.

Process Safety Information

While there are many elements of the PSM standard (14 in total), we will focus on the ones that are particularly relevant to the hazards associated with industrial ammonia refrigeration systems:

  • Process Safety Information (PSI)
  • Process Hazards Analysis (PHA)
  • Operating Procedures
  • Mechanical Integrity (MI)
  • Compliance Audits
Process Hazard Analysis

A process hazard analysis must be performed on processes covered by the PSM standard. Such analysis must identify, evaluate, and control the hazards involved in the process.

An employer must conduct an initial process hazard analysis and, at least every five years thereafter, the process hazard analysis must be updated and revalidated by a qualified team to assure that the process hazard analysis is consistent with the current process.

One or more of the following methods must be used to determine and evaluate the hazards of the process being analyzed:

  • What-if;
  • Checklist;
  • What-if/checklist;
  • Hazard and operability study (HAZOP);
  • Failure mode and effects analysis (FMEA);
  • Fault tree analysis; or
  • An appropriate equivalent methodology.

Whichever method(s) are used, the process hazard analysis must address the following:

  • The hazards of the process;
  • The identification of any previous incident that had a potential for catastrophic consequences in the workplace;
  • Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware.);
  • Consequences of failure of engineering and administrative controls;
  • Facility siting;
  • Human factors; and
  • A qualitative evaluation of a range of the possible safety and health effects on employees in the workplace if there is a failure of controls.

The process hazard analysis is the key provision of this standard. It should be performed by a team with expertise in engineering and process operations, and such team should include at least one employee who has experience with and knowledge of the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.

A facility must establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

Process hazard analyses and updates or re-validation for each process covered by PSM, as well as the documented resolution of recommendations, must be kept on file for the life of the process.

Operating Procedures

An employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and must address the steps for each operating phase; operating limits; safety and health considerations; and safety systems and their functions. (See 29 CFR 1910.119(f) for full details on these elements.)

Mechanical Integrity (MI)

It is a priority of the PSM standard to maintain the mechanical integrity (MI) of critical process equipment to ensure it is designed and installed correctly and operates properly. Such MI requirements apply to the following equipment:

  • Pressure vessels and storage tanks;
  • Piping systems (including piping components such as valves);
  • Relief and vent systems and devices;
  • Emergency shutdown systems;
  • Controls (including monitoring devices and sensors, alarms and interlocks) and;
  • Pumps.

Of particular interest to us here at Bacharach is the “controls” part of the Mechanical Integrity section, which is clarified as “including monitoring devices and sensors, alarms and interlocks” (29 CFR 1910.119(j)(v)). This is because our ammonia refrigerant detectors and monitors, like the MGS-400 Gas Detection Series, are applicable.

Engineered for use in cold storage facilities, MGS-400 gas detectors feature ammonia-specific sensors and are flush mounted in the enclosure to optimize the response time. For instance, when ammonia is detected, the leak detectors integrated audio/visual alarms alert personnel to the leak.
Now, to get back to the point, an employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Inspection and testing must be performed on process equipment, following recognized and generally accepted good engineering practices.

Compliance Audits

An employer must certify that they have evaluated compliance at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.

It is important to determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.

The two most recent compliance audit reports should be on-hand.

How Long Must I Follow These Requirements?

The PSM Standard is not a one-time occurrence; rather, it is a continuous program that should be sustained as long as a facility is operating a covered industrial ammonia refrigeration system.

On-going Requirements of PSM
PSM Element On-going Requirement Frequency
Employee Participation Employees involved Continuous
Process Hazard Analysis Update and re-validate 5 Years
Operating Procedures Certified current Annually
Training Refresher training 3 Years
Contractors Evaluate contractor performance Periodically
Mechanical Integrity Inspections and tests Periodically
Management of Change Update program during plant changes As-needed
Incident Investigation Investigate and develop recommendations As-needed
Compliance Audit Audit PSM program 3 Years

Therefore, the question should not be framed as how long but how best.

Ensure Proper Maintenance and Safe Operating Procedures for Compliance

In sum, we’ve highlighted a few important elements from OSHA PSM for industrial ammonia refrigeration systems, but keep in mind that there are 14 elements in total that one should be familiar.

Importantly, throughout the PSM Standard, ammonia refrigerant detection plays an important role, and that’s where Bacharach is here to help. In fact, check out our range of refrigerant detectors and monitors for ammonia via our handy Gas Selector Tool.

Ultimately, performing proper maintenance and ensuring safe operating procedures with industrial ammonia refrigeration systems is the key to OSHA PSM compliance and ammonia refrigerant leak prevention.

Traditional Non Destructive Testing Inspection

An employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and must address the steps for each operating phase; operating limits; safety and health considerations; and safety systems and their functions. (See 29 CFR 1910.119(f) for full details on these elements.)

Mechanical Integrity (MI)

It is a priority of the PSM standard to maintain the mechanical integrity (MI) of critical process equipment to ensure it is designed and installed correctly and operates properly. Such MI requirements apply to the following equipment:

  • Pressure vessels and storage tanks;
  • Piping systems (including piping components such as valves);
  • Relief and vent systems and devices;
  • Emergency shutdown systems;
  • Controls (including monitoring devices and sensors, alarms and interlocks) and;
  • Pumps.

Of particular interest to us here at Bacharach is the “controls” part of the Mechanical Integrity section, which is clarified as “including monitoring devices and sensors, alarms and interlocks” (29 CFR 1910.119(j)(v)). This is because our ammonia refrigerant detectors and monitors, like the MGS-400 Gas Detection Series, are applicable.

Engineered for use in cold storage facilities, MGS-400 gas detectors feature ammonia-specific sensors and are flush mounted in the enclosure to optimize the response time. For instance, when ammonia is detected, the leak detectors integrated audio/visual alarms alert personnel to the leak.
Now, to get back to the point, an employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Inspection and testing must be performed on process equipment, following recognized and generally accepted good engineering practices.

Compliance Audits

An employer must certify that they have evaluated compliance at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.

It is important to determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.

The two most recent compliance audit reports should be on-hand.

visual testing (VT)

The oldest and most basic form of non-destructive testing, traditional visual testing involves our technicians inspecting equipment with their eyes to determine any visual defects. We offer visual inspectors that are certified to a variety of industry codes and regulations.

Often the first technique that we utilizes at the outset of a project, we provide a variety of visual inspection (VT) services to multiple industries. The method is useful for determining a project’s scope, establishing the extent of existing damage, and informing the technician of where more advanced, in-depth inspections are needed.

ultrasonic Testing (UT)

Conventional Ultrasonic Testing (UT) inspection is a commonly-used non-destructive testing (NDT) technique that measures the propagation of mechanical vibrations (ultrasonic waves) through a material to examine properties, measure thickness, determine elasticity, and detect a range of discontinuities, including corrosion/erosion, flaws, cracks, and more.

An NDT) staple, our technicians utilize conventional ultrasonic testing (UT) to detect surface and sub-surface defects and supply accurate readings regarding discontinuity size and shape. Ultrasonic surveys are used as the main inspection technique for a plant’s erosion/corrosion programs, and are utilized extensively at our multiple evergreen site locations around the world.

Penetrant Testing (PT)

A traditional, relatively simply method of field or lab non-destructive testing, Penetrant Testing (PT) is used for finding surface-breaking discontinuities on relatively smooth, nonporous surfaces. It is based on the properties of capillary action, or the phenomenon of a liquid rising or climbing when confined to a small opening. After the excess penetrant is removed and a developer is applied, a trained inspector can identify any remaining penetrant that may indicate a flaw.

Also referred to as Liquid Penetrant Inspection (LPT), Penetrant Testing (PT) is used on non-ferrous materials such as metals, composites, and ceramics, identifying surface anomalies such as cracks, seams, laminations, blow holes, laps, external bursts and welding defects.

Predictive Maintenance (PDM) Testing Services and Programs

 

A well-designed PDM program enables facilities to predict potential damages and equipment failures before they happen, enhancing safety and maximizing operational uptime. As a OneSource provider of asset protection solutions, we offer the high level of technical knowledge and proficiency in inspection, engineering consulting, and vibration testing solutions necessary for your predictive maintenance program to deliver maximum value.

Our custom-tailors predictive maintenance services and programs to our client’s individual facility needs. This can be as simple as supplying an inspector to collect and analyze equipment vibration data, or as complex as having our engineering, inspection, and mechanical teams design, implement, and execute a comprehensive PDM program.

(PdM) Program Implementation Services

Whether your facility needs to design and implement a brand-new PdM program, or upgrade an existing one, MISTRAS offers engineering support and fully-developed PdM procedures and guides.

Our PdM program implementation consulting services include:

  • Gap Analyses
  • Failure Modes and Effects Analysis (FMEA)
  • Key Performance Indicator (KPI) definition
  • Procedure Development
  • Root Cause Engineering Analysis
  • Third Party Acceptance Testing
  • Training of In-House Personnel

Our PdM engineers bring expertise in database construction/management and data collection, reporting, analysis and documentation. We are also able to assist you maximizing the value of your capital investments and performing a cost-benefit analysis of your program.

(PdM) Inspection & Testing Services

In addition to designing PdM programs, we will also execute a full range of PdM inspection and testing services.

We can conduct the entire PdM program for you by assessing your machines and writing your entire database, including analysis parameters and vibration limit specs. We’ll provide an engineering report that diagnoses possible problems and recommends maintenance actions.

Our goal is to provide an integrated solution that lowers facility maintenance costs and increases production and profits.

Our other predictive maintenance services include:

  • On-line Vibration Monitoring
  • Walk-Around Vibration Services
  • Advance Vibration Diagnostics
  • Field Balancing Services
  • Infrared Thermography Inspections
  • Lube Oil and Grease Analysis
  • Ultrasonic Lubrication and Leak Detection Services
  • Motor Condition Monitoring (Motor Current Signature Analysis)
  • Strain Gage Materials Testing and Stress Analysis
  • Laser Shaft Alignment
  • Installation of Permanent Online Vibration Monitoring Systems

Digital Radiography (DR) Inspection

Vibration analysis are used heavily in predictive maintenance (PdM) programs, where our technicians measure and identify signs of irregular or excessive in-service movement occurring within rotating equipment. Vibration analysis measures amplitude, intensity, and frequency to detect mechanical failures, such as core/winding loosening.

Vibration analysis is one of the most popular techniques utilized in PdM programs. We analyze vibrations of machinery and rotating equipment as part of condition assessments, enabling us to more accurately predict failures before they cause more costly damages.

Our vibration sensors and monitoring equipment include local read-out meters and alarms that can be wired to your control room for trending and shutdown capabilities. These sensors and systems are useful for machinery in locations that may be difficult or unsafe for personnel to access. Vibration systems also provide consistent and accurate trending data on operating conditions, helping operators make more informed maintenance decisions.

 

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