The public review period for BSR/IIAR 6-202X ended yesterday, May 27, 2024. IIAR 6 was originally published in 2019, so this is only the first revision of the important standard. For those unaware, IIAR is the standard for the Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems. While the structure and content of the standard largely stayed the same, there were some notable changes. Here at Macha PSM, as a member of IIAR, we decided to register our comments with the committee. For your benefit, we have included our comments here. Note: These changes are not yet final, but are only in draft form.
Comment 1: Seasons and Weekends Exception
Section as is:
5.2.3 [DELETED]
A.5.2
Occasional record keeping interruptions may occur from being reviewed once per day on weekends, during holidays, and/or during harvesting off seasons. This is when coverage by refrigeration personnel is not scheduled. During the next scheduled shift when a trained technician is back on duty, the assigned record keeping activities should resume and be analyzed for comparison and current operating conditions. See Section 2.2 “Frequency” definition and Appendix A, Section A.2.2.
Section how you want it to read:
5.2.3 When coverage by refrigeration personnel is not scheduled during weekends, holidays, and/ or during harvesting off seasons, daily inspections are not required. Daily inspections shall resume during the next shift when a trained operator or technician is back on duty.
Justification:
We should leave the exception found in the 2019 edition alone. Relegating this exception to the appendix removes its potency. This explanation is crucial for seasonal facilities and facilities which do not operate on the weekends. By removing this exception from the normative part of the standard, regulators will have the right to penalize facilities for failing to complete daily rounds on the weekend.
Comment 2: Data Reports for Heat Exchangers
Section as is:
5.3.3 *The current system documentation records shall be readily accessible and include the following:
...
7. Manufacturer data reports for all pressure vessels;
...
Section how you want it to read:
5.3.3 *The current system documentation records shall be readily accessible and include the following:
...
7. Manufacturer data reports for all pressure vessels and ASME-certified heat exchangers;
...
Justification:
ASME-certified heat exchangers are also required to have a corresponding data report per ASME Boiler and Pressure Vessel Code, Section VIII, Division 1.
Comment 3: Oil Stored in Machinery Rooms
Section as is:
5.6.3.5
Compressor oil is permitted to be stored in machinery rooms outside of fire rated cabinets so long as the containers or barrels do not obstruct the pathways to eyewash & safety showers and do not obstruct emergency egress routes.
Section how you want it to read:
5.6.3.5
Compressor oil is permitted to be stored in machinery rooms outside of fire rated cabinets so long as:
5.6.3.5.1
The flash point of the oil is above 200°F.
5.6.3.5.2
The containers or barrels do not obstruct the pathways to eyewash & safety showers.
5.6.3.5.3
The containers or barrels do not obstruct emergency egress routes.
Justification:
This is a major reversal on the part of IIAR without explanation. When regulators do not see a clear explanation for the loosening of a requirement, they tend to ignore it (e.g., CalOSHA). Have we proven or somehow demonstrated that oil stored in the machinery room does not pose a hazard?
By adding the qualifier, "with a flash point above 200°F," to the exception, this should clearly show that these oils are rendered relatively harmless. The 200°F figure comes from the NFPA Placarding system. Most refrigeration oils have a flammability rating of "1" which corresponds with a flash point above 200°F. Frick oil, to take one example, has flash points ranging from 370-514°F (see the chart on page 4 of this document: https://www.keepsupply.com/media/productattach/p/u/publ-8393_frick_pureoil_brochure_2017.pdf).
Comment 4: Inspecting Pumped Out Equipment
Section as is:
5.6.11.1
Where refrigerant has been removed from refrigerant containing equipment, the ITM Tasks for that equipment are permitted to be deferred in accordance with this section. ITM tasks shall be addressed and a pre-startup safety review (PSSR) performed before placing the equipment back into service.
Section how you want it to read:
5.6.11.1
Where refrigerant has been removed from refrigerant containing equipment, besides the ITM tasks described in Tables 11.1 - 11.3 the ITM Tasks for that equipment are permitted to be deferred in accordance with this section. ITM tasks shall be addressed and a pre-startup safety review (PSSR) performed before placing the equipment back into service.
Justification:
If a portion of the system is pumped out, periodic inspections of the equipment piping should still be performed until it is cut from the system. Without implementing Table 11.1 Inspection Item L, for example, a plug or cap could be missing. Then, all that would need to happen is the isolation valve keeping the equipment from the live system would have to fail and an active release would occur through the opening. I agree ITM tests are unnecessary as they pertain to the operation of the equipment, but the facility should at least verify that the integrity of the equipment while it is still connected. If they do not want this responsibility, then they should cut it from the system.
Comment 5: Compressor Alignment
Section as is:
Table 6.1 Inspection Item Y: Visually inspect alignment of compressor-motor drive shaft
Section how you want it to read:
Table 6.1 Testing Item F: Test the alignment of compressor-motor drive shaft
Justification:
IIAR 6 defines "inspection" as: "The evaluation and assessment of equipment, a component, a system, or a portion of a system using human senses such as vision, hearing, touch, smell, or a combination thereof." The human senses - the naked eye in this case - are incapable of detecting misalignment (apart from misalignment so terrible that the compressor would not be able to run).
This requirement should be put in the testing category. IIAR 6 defines "test" as: "The operation of equipment, a component, or a device to verify that it is functioning correctly, or the measurement of a system characteristic to determine if it meets requirements." This is exactly what we should be after - a measurement to quantify that the compressor is properly aligned.
Comment 6: High Level Float Switch Testing
Section as is:
6.1.2.1
High Liquid Level cutout devices and shutdown circuits shall be tested by raising the liquid level in the device to activate the high liquid level shutdown, while taking care to prevent vessel overfilling or causing carryover of liquid refrigerant to associated compressors.
Section how you want it to read:
Delete 6.1.2.1
Add A.6.1.2
High Liquid Level cutout devices and shutdown circuits may be tested by raising the liquid level in the device to activate the high liquid level shutdown, while taking care to prevent vessel overfilling or causing carryover of liquid refrigerant to associated compressors.
Justification:
This is an extremely restrictive requirement. Instead of putting this requirement in the normative section of the standard, it should be placed in the appendix under the previous section. This is a good way to test the high level float switch, but it is unreasonably onerous for most facilities when other testing methods are available.
Comment 7: Maintenance Items that Should be Inspection Items
Section as is:
Table 7.1 Maintenance Item A: Verify base frame anchors are in place and secure
Table 10.1 Maintenance Item B: Verify base frame anchors are in place and secure
Table 12.1 Maintenance Item C: Verify emergency ventilation override switch mounting is secure
Table 12.2 Maintenance Item A: Verify emergency shutdown switch mounting is secure
Table 12.3 Maintenance Item A: Verify sensor mounting is secure
Table 12.3 Maintenance Item B: Verify panel mounting is secure
Section how you want it to read:
Table 7.1 Inspection Item ?: Verify base frame anchors are in place and secure
Table 10.1 Inspection Item ?: Verify base frame anchors are in place and secure
Table 12.1 Inspection Item ?: Verify emergency ventilation override switch mounting is secure
Table 12.2 Inspection Item ?: Verify emergency shutdown switch mounting is secure
Table 12.3 Inspection Item ?: Verify sensor mounting is secure
Table 12.3 Inspection Item ?: Verify panel mounting is secure
Justification:
None of these are maintenance items. These should be inspections. The intent is that a visual inspection be performed on anchors and mounting. Touch may also be used to verify everything is secure. No maintenance is being performed here.
Comment 8: Inspecting Bunker Coil Fans
Section as is:
Table 9.1, Column "Bunker Coil"
Inspection Item A: Listen to rotating parts for abnormal sounds | NA
Inspection Item E: Verify fan guards are in position and have no obstructions | NA
Section how you want it to read:
Table 9.1, Column "Bunker Coil"
Inspection Item A: Listen to rotating parts for abnormal sounds | WA-W
Inspection Item E: Verify fan guards are in position and have no obstructions | WA-W
Justification:
These inspection items are intended for evaporators with fans. Bunker coils do have fans, but they are not always immediately adjacent to the coils. Regardless of their proximity, these ITM tasks should not be "NA," but "WA-W" like most other evaporator types.
Comment 9: Bunker Coil Excessive Ice Inspection Frequency
Section as is:
Table 9.1, Column "Bunker Coil"
Inspection Item G: Verify evaporator is free from excessive ice buildup | W
Section how you want it to read:
Table 9.1, Column "Bunker Coil"
Inspection Item G: Verify evaporator is free from excessive ice buildup | M
Justification:
A weekly visual inspection of bunker coils is onerous. It is unreasonable to require that bunker coils be inspected for ice more frequently than forced-air evaporators. A lot of bunkers are difficult to access, especially during the busy season. It is also excessive because bunkers are typically designed to support the excess weight.
Comment 10: Testing Door Interlocks with Fans
Section as is:
Table 9.1 Testing Items A-E
Section how you want it to read:
Table 9.1, Testing Item F: Functionally test door interlock shuts off fan(s)
Bunker Coil column: WA-S
Make-up Air/Make-up Hygienic With Heat column: WA-S
All other columns: NA
Justification:
Some bunker coils and make-up air units have door interlocks to shut the fans down when the door is opened. This is an important safety system to prevent operators from being struck by a rotating fan. The functionality should be periodically tested.
Comment 11: Checking Pressure Vessel Liquid Levels
Section as is:
Table 10.1 Inspection Items A-K
Section how you want it to read:
Table 10.1 Inspection Item L: Visually inspect the liquid level to ensure it is 85% or lower
The frequency for insulated and non-insulated vessels should be: WA-D
Justification:
For a normal system, operators are already checking the level of their high pressure receiver on a daily basis. This is important for several reasons. For one, continually tracking the level in a major vessel can prevent continued rogue emissions. For example, if the level keeps dropping day after day, the operators will know to search the system for a leak. It is unnecessary to visually check the liquid level of every vessel which has sight glasses, which is why a "WA-D" should be used. A system might not have a high pressure receiver, but might check their one suction accumulator level every day, for example.
Comment 12: Inspecting Piping Weekly Instead of Annually
Section as is:
Table 11.1 Inspection Item L: Visually inspect to verify all piping system openings, except relief discharge termination points, are plugged, capped, or locked closed with appropriate administrative controls
Frequency: A
Section how you want it to read:
Table 11.1 Inspection Item L: Visually inspect to verify all piping system openings, except relief discharge termination points, are plugged, capped, or locked closed with appropriate administrative controls
Frequency: W
Justification:
Currently, piping and valves are only required to be inspected on an annual basis. If a facility has most of their piping and valves on the roof, they could only go onto the roof once per year and still be in compliance with IIAR 6. This is unacceptable. Besides checking to make sure all openings are sealed, operators should also perform a weekly walk of their system just to rule out active leaks.
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