Technical Safety BC Ammonia Refrigeration Survey Report

From Oct 1 - 31, 2019, a survey was conducted to collect feedback on a guideline developed by Technical Safety BC to help improve practices and programs around equipment integrity management at ammonia refrigeration facilities. This report is based on 19 responses to the survey. The survey replies received from Technical Safety BC safety officers has been combined with the data received from facility owners/operators and refrigeration industry professionals who participated in the industry review. Survey Questions and Analysis The survey contained multiple choice questions, rating questions and open ended comment feedback. Background of Survey Responders Individuals completing the survey were asked how their work related to refrigeration systems and to identify in one of the categories below: Some submitters identified in more than one category. The submissions of multi-category submitters was evaluated in a single identification category based on their job title and company.

Licensed Contractor

10%

Power Engineer Operator

16%

Owner/Manager21%

Training Provider10%

Consultant Plant Designer

16%

Safety Officer16%

Other11%

SUBMITTER IDENTIFICATION

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Technical Accuracy Technical accuracy was assessed by a multiple choice question where the guideline was rated as completely accurate, somewhat accurate and not accurate. Overall, 95% of submitters indicated that the guideline was accurate from a technical perspective.

63% selected completely accurate

32% selected somewhat accurate

5% indicated not accurate (one submitter) Responses to open ended questions indicated that the accuracy could be improved by adding information about:

- mitigation of early lifts on pressure relief valves - the effectiveness of leak detection methods and safety - damage mechanisms and inspections for liquid transfer systems - qualifications of individuals doing inspection - qualifications of individuals operating refrigeration systems - code requirements for inspection intervals - decommissioning of equipment at end of life - clarification that WorkSafe BC may have additional regulatory requirements for ammonia

detection levels - ammonia diffusion and flare systems - minimum code acceptance criteria for inspection

Applicability of Guideline Applicability of the guideline to their work was strongest among owners/managers, operators/power engineers and safety officers and weakest with contractors.

69% of respondents indicated that the guideline was highly applicable to their work

23% indicated it was neutral (somewhat applicable)

8% indicated it was not applicable The survey responses indicated that the guideline was most applicable to ice rinks, cold storage and food processing facilities. It was considered to be least applicable to curling clubs, other recreational and other industrial facilities. There were three open ended comments indicating that the guidelines were more applicable to large facilities and that the guidelines were too complex or not relevant to smaller facilities. One comment indicated that the guidelines could be applied to all facilities if modified for the specific size and design of a facility. Some comments stated that the guidelines should be adapted or customized to specific types of facilities such as ice rinks. Implementation

60% of respondents said to make the adoption of the guideline mandatory through regulatory requirements.

15% of respondents were in favour of voluntary adoption.

Other methods suggested included staging the implementation as follows:

mandatory adoption for registered special status plants or high risk plants followed by other facilities

adoption by large facilities who have the resources and expertise to implement an integrity management program followed by implementation of specifically designed guidelines for smaller facilities

Survey respondents said that it would take 1 to 2+ years to implement the guidelines at a facility. Factors impacting the implementation identified in the open ended comments included:

a lack of adequate knowledge and expertise (11 comments) of facility staff limited number of consultants with specialized knowledge of ammonia refrigeration

integrity management. consultants would be required because facilities lacked the expertise or resources to

develop and implement an integrity management plan. financial and staff resources would not be available or difficult to obtain for

implementation of a program. Comments indicated that making it a regulatory requirement to adopt the guidelines would help obtain adequate budgets and resources to implement and administer an integrity management program. Post implementation problems identified in the comments included:

acquiring the resources and expertise required to administer an integrity program would be a challenge

the costs to administer a program would be prohibitive a lack of people with sufficient expertise to run a program.

Resources to Assist With Adoption of Guidelines Education at 38% was identified as the best resource to assist with adoption. This correlates with comments from open ended questions which indicated that many survey respondents considered that there was a lack of knowledge and expertise about the development, implementation and administration of integrity management programs. Checklists and samples/templates were the second best resources identified. Both were selected by 26% of the respondents. Support for Guideline

74% of respondents indicated that they support the guideline (42% were strongly in support, and 32% supported it)

16% of respondents opposed the guidelines and none strongly opposed it Consultants, owner/managers and safety officers were the top supporters. Opposition to the guideline was largely from contractors and training providers. Reasons for supporting the guideline included:

It is a good reference which will assist in implementing integrity management program It will have positive impact on safety, inspection and maintenance

It could be adopted by any facility if they are customized to the facility's design and equipment

50% of the respondents indicated that they could envisage the facility they work at adopting the guideline while 50% indicated that they could maybe envisage their facilities adopting it. Reasons for opposing the guideline included:

it is too long and not an easy read guide will not improve or have no impact on inspection/maintenance practices likely to be adopted only by large facilities or organizations with multiple facilities having

staff/financial resources to develop an integrity management program not likely to be adopted by small facilities with limited staff/financial resources it is too complex and most organizations lack the expertise to develop integrity

management programs it would be better accepted if they were customized to specific types of facility (ice rinks,

food processing etc.) Safety Impacts Awareness:

69% of respondents indicated that they agree the guideline will raise refrigeration safety awareness (27% strongly agreed it will increase safety awareness and 42% agreed it would increase safety awareness).

5% of respondents disagreed that the guidelines would increase safety awareness.

None strongly disagreed. Better maintenance practices:

74% of respondents indicated that they agree the guideline will improve maintenance practices and equipment integrity (16% strongly agreed it will improve maintenance practices and 56% agreed it will improve maintenance practices).

5% of respondents disagreed that the guidelines would improve maintenance practices.

None strongly disagreed. Clarity of roles and responsibilities:

55% of respondents indicated that the guideline would raise awareness around roles and responsibilities for safety and compliance.

25% indicated the guideline would help lay a foundation to build equipment integrity programs.

10% consider the guideline to be a great starting point for equipment integrity programs.

None of the respondents said that the guideline would have no impact. Two respondents provided other impacts as follows:

- minimal impact - impact would be dependent on the type of plant

Appendix A – Graphical Summary of Survey Responses Question 3 – In your experience, is the information in the guideline accurate from a technical perspective?

Completely63%

Somewhat Accurate

32%

Not accurate5%

Overall Accuracy

* Note: Chart corrected for submitter's identifyiing in more than one ID

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0 0 0

1

0 00

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Guideline Accuracyby ID Classification

Completely

SomewhatAccurate

Question 5 - How applicable is the guideline for your work?

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Contractor OperatorPower

Engineer

OwnerManager

Consultant Trainingprovider

Safety Officer Other

Applicability by ID Classification

Highly Neutral Not applicable

Highly

69%

Neutral

23%

Not applicable

8%

GUIDELINE APPLICABILITY OVERALL RATINGS

1

3

9

Question 6 - How applicable would this guideline be for various types of refrigeration facilities in BC? Ice Rinks

Curling clubs

Other recreational

Cold storage

Food and beverage processing

Other industrial

Question 7 - How long would it take to implement a refrigeration maintenance program that's in alignment with this guideline?

Question 8 - What implementation method would be most effective to encourage adoption by the refrigeration industry?

Question 9 - What implementation method would be most effective to encourage adoption by the refrigeration industry?

Question 11 - Do you believe that this guideline will help increase refrigeration safety awareness in your industry?

Question 12 - Do you believe that this guideline will help improve safe maintenance practices and equipment integrity?

Question 13 - Having a maintenance guideline to help with planning would...

Question 15 - After reviewing the guideline, what is your level of personal support for this new maintenance planning tool?

Question 17 - Can you see the facilities you work with adopting and using this guideline?

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1

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Contractor OperatorPower

Engineer

OwnerManager

Consultant Trainingprovider

Safety Officer Other

Will Facilities Use Guideline by ID Classification

Yes Maybe No

Appendix B – Analysis of Comments in Open Ended Questions

Theme or Topic Number of comments Specific Details

Acceptance of Guidelines

31

Good reference which will assist in implementing integrity management program; 4 comments* Guideline will have positive impact on safety; 4 comments

Guideline will have no impact on safety as it is too long and not an easy read guide; 1 comment

Guideline will improve inspection/maintenance practices; 1 comment

Guideline will not improve or have no impact on inspection/maintenance practices ; 4 comments

Guidelines most likely to be adopted by large facilities or organizations with multiple facilities and greater staff/financial resources; 3 comments

Guidelines could be adopted by any facility if they are customized to the facility's design and equipment

Guidelines least likely to be adopted by small facilities (ice rinks, curling rinks, single plant); 2 comments

Most organizations do not have the resources to implement integrity management program and will adopt them only if mandatory; 1 comment

Guidelines are too complex and most organizations lack the expertise to develop integrity programs; (7 comments)* Guidelines would be better accepted if they were tailored to specific types of faculty (ice rinks, food processing etc.) or if they were flexible so that only requirements applicable to the facility are used without addressing all the requirements in the guideline; 3 comments

Issues Impacting Implementation

20

Two issues impacting the implementation of a integrity management program were identified:

a lack of adequate knowledge and expertise (11 comments) of facility staff and limited number of consultants with specialized knowledge of ammonia refrigeration integrity management.

a lack of staff and financial resources (9 comments) required to implement integrity management programs; getting support and budgets from facility management/owners may be difficult

Reasons ammonia refrigeration facilities operations are high risk

12

The comments indicated that the top two reasons for high risk are limited management resources for inspection/maintenance and insufficient knowledge/training of operators. Other reasons identified are lack of enforcement of regulations, aging equipment and inadequate inspection/maintenance programs.

Method of implementation

12

Mandatory implementation through regulatory requirement and staged implementation where guidelines would be mandatory for special status plants or high risk plants first then other facilities each had 3 counts. Other methods suggested were voluntary, staged with well-resourced facilities first, combination of mandatory and voluntary, voluntary and specific program for small facilities.

Resources required to implement an integrity program

8

There were 3 comments indicating that consultants would be required because facilities lacked the expertise or resources to develop and implement a plan. 5 comments were that financial and staff resources would not be available or difficult to obtain for implementation of a program. These issues regarding financial/staff resources and expertise will have an impact on time to implement an integrity program.

Theme or Topic Number of comments Specific Details

Technical Accuracy 8

7 comments indicated missing information and one comment was about unclear information. Suggested the following information be added:

mitigation of PRV early lifts by implementing manufacturer recalls and installation of rupture disks

add information about leakage detection; no soap solution test and revise order of effectiveness for sulphur sticks, litmus and ammonia detectors

liquid transfer systems are high risk and corrosion/cycling impact on these systems should be added - consider oversight direction and criteria

need to be more specific on qualification of the people conducting the inspections

be more specific about inspection intervals (code requirements and industry norms)

more specifics on what to do at end of life and decommissioning

the information in the manual doesn't contradict what's in the regulations (period for retention of records) - use of Sulphur stick ok with WorkSafeBC?

Detectors – guideline references 300bpm and there is also WSBC regulations.

Look at info about diffusion and flare systems

Substitution of material - change "may" to "must" in #9.

Training and Competency - clear up the info about Chief Engineer VS "person in charge" - the person on a shift is the "person in charge" too... could be a 4th class PE or an Operator.

include info about qualifications not just about training.

add minimum acceptance criteria for assessment / safety officers.

Applicability of Guideline

6

There were two comments that the scope of the guideline should be expanded to include types of refrigeration other than ammonia (specifically all refrigeration systems and CO2). Three comments that the guidelines were more applicable to large facilities and too complex or not relevant to smaller facilities (ice rinks). One comment that guideline was applicable to all facilities if modified to suit a facilities specific size and design.

State of existing integrity programs

5 Comments indicated that current programs if in place are basic programs that may incorporate some aspects of the guideline requirements but are not equivalent.

Facilities have established inspection/ maintenance programs

4

3 comments indicated 4 facilities or organizations that have implemented inspection/maintenance programs. Only one comment specified how a program compared to the guideline requirements and it was not as comprehensive as the guideline. There was one comment that generally maintenance requirements specified in B52 are well understood but there is a lack of understanding about pressure equipment inspection requirements.

Time Required for Implementation 4

Comments indicated that between 1 and 2 years would be the period required to implement an integrity management program at a facility.

Theme or Topic Number of comments Specific Details

Resources Needed to Administer an Integrity Mgmt. Program

2

Comments indicated that the both the resources and expertise required to administer an integrity program would be a challenge. It was felt that the costs to administer a program would be prohibited and that there were not many people available with sufficient expertise to run a program.

Risk awareness 1

Most mangers, supervisors, contractors and operators are familiar with risk in ammonia refrigeration facility operation

Comments that are unclear and require more information

5