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RETABREEZE

Refrigerating Engineers & Technicians Association 2012 Issue #2 (March/April)

OPERATING PROCEDURES EMERGENCY SHUTDOWN


— By Lee Pyle and Jeanna Emmons, SCS Tracer Environmental

U nder the Process Safety Manage-


ment standard (29 CFR 2910.119),
facilities are required to prepare operat-
- Emergency Operations,
- Normal Shutdown, and
safe and timely manner” [REF: 29
CFR 1910.119 (f)(1)(i)(D) and 40 CFR
Part 68.69(a)(1)(iv)].
- Startup following a turnaround or
ing procedures (1910.119 (f) for the safe
emergency. Are there qualifications for a person to
operations of their ammonia refrigeration
system. Specifically, 1910.119 (f) (1) states: While each equipment SOP will c o n d u c t e m e rg e n c y s h u t d o w n
have normal and emergency operations?
“The employer shall develop and imple- shutdown steps, consider an overall
ment written operating procedures that What if you don’t have an Emergency
emergency shutdown SOP. This SOP
provide clear instructions for safely con- Response Team? Many facilities do not
should include, but is not limited to,
ducting activities involved in each have the in-house capabilities to
the following:
covered process consistent with the support a full Emergency Response
process safety information…” -What conditions warrant shutdown? Team.
- Location of the E-stop? What if you use an outside refrigeration
As most already know, this can become
a very intimidating task and take many - Manual button located at facility? contractor? Many facilities use outside
man-hours to write, review, double/triple - Remote via computer log-in?
check, update and maintain. As detailed Continued on page 4
- Who to contact (Chief Engineer,
in the January/February 2012 RETA
Fire Department, Plant Manager,
Breeze article, there are many require-
etc.)? INSIDE THIS ISSUE
ments under 1910.119(f). This article will
focus on one little item: - Who is authorized/qualified to
President’s Message . . . . . . . . . . . . . . . . . . . . . . . 2
actuate the E-stop?
1910.119(f)(1): SOPs shall address at Board of Directors . . . . . . . . . . . . . . . . . . . . . . . . . 2
- What are the safety issues associ-
least the following elements: Executive Director’s Memo . . . . . . . . . . . . . . . . . 3
ated with activating the E-stop? This is How It Goes . . . . . . . . . . . . . . . . . . . . . . . . 3
- Steps for each operating phase: - How will personnel know it is Certification Honor Roll . . . . . . . . . . . . . . . . . . . . 4
- Initial Startup, safe to access the E-stop? Power of Insulation . . . . . . . . . . . . . . . . . . . . . . . . 6
- Normal Operations, Emergency Shutdown What are the Requirements ? . . . . . . . . . . . . . . 7
Responsibilities Chapter Meeting Schedule . . . . . . . . . . . . . . . . 8
- Temporary Operations,
Questions & Answers . . . . . . . . . . . . . . . . . . . . . . 8
- Emergency shutdown, including Both the PSM and RMP regulations Common Unsafe Practices . . . . . . . . . . . . . . . . 10
the conditions under which emer- state that “emergency shutdown, includ- Industry News . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
gency shutdown is required, and ing the conditions under which
News from HQ . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
the assignment of shutdown re- emergency shutdown is required, and
sponsibility to qualified operators Member News . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
the assignment of shutdown responsibil-
to ensure that emergency ity to qualified operators to ensure that Conference Countdown . . . . . . . . . . . . . . . . . . 18
shutdown is executed in a safe emergency shutdown is executed in a Policy Update . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
and timely manner. Classifieds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
–4–
RETA Breeze • Mar./Apr. 2012 - Issue #2
OPERATING PROCEDURES EMERGENCY SHUTDOWN

Certification
Continued from page 1

Honor Roll refrigeration maintenance contractors and do - Can they access the Emergency Kill
not employ refrigeration operators. Switch safely?
Congratulations to our newly - Has anyone tested the Emergency Kill
RETA Certified Operators. Many ammonia refrigerated facilities are re-
thinking their response levels. With newer Switch to see what it would do or how long
These are folks who passed the
exam(s) between January 1 and process controls and code requirements that it will take for the system to be brought
February 29, 2012. allow personnel to shut down either the entire back on line?
For information about the system or portions of the system remotely - Who will bring the system back on line?
examination process and with computer access responding at the Oper-
preparation to take the RETA Incorporating who is qualified to shut down
exam, please go to the RETA ations Level is manageable. your ammonia refrigeration process and how
website: www.reta.com. this can be accomplished reaches into your
Since many facilities are non-responding
which means that you will call 9-1-1 and Training Program. Not all plants have 24-7
leave, then you don’t need to address emer- ammonia refrigeration technicians. If a facility
CIRO is planning to designate non-maintenance/re-
CERTIFIED INDUSTRIAL REFRIGERATION gency shutdown procedures in the PSM/RMP
OPERATOR documentation – right? frigeration staff to assist during other
operating shifts (such as a Shift Supervisor),
Walter Anderson From EPA’s General Guidance on Risk they should be incorporated into the PSM
Daniel Austin
Management Programs for Chemical training program. The training program
Manuel Burruel
Roby Bush Accident Prevention, March 2009: should include the tasks expected to be per-
Brian Carney formed and the frequency of refresher training
EPA does not intend to force such facilities
Robert Conlee (at least every three years).
Mike Covey [with limited personnel] to develop emergen-
David Cuellar cy response capabilities. At the same time, Example: Shift Supervisors should know
Floyd Francis you are responsible for ensuring effective where the Emergency Kill Switch is located
Michael Gannon emergency response to any releases at your and when it should be actuated. Shift Supervi-
Benjamin Garcia
John Garland
facility. If your local public responders are sors and your refrigeration chief engineer/
Jason Goyne not capable of providing such response, lead/contractor should meet periodically to
Logan Greer you must take steps to ensure that effective review the following:
Luther Horn response is available (e.g., by hiring
Joseph Jacob response contractors).” - Where the E-Stop is located.
Kenny Kerpa
Travis Leach - When the E-Stop should be actuated.
Whatever your response capabilities, the
Curtis Mahaney
PSM/RMP document may say something - What happens when the E-Stop is
David McCarthy
Chuck Mundlin like: actuated.
Tomas Nevarez - How often the E-Stop is tested and
Christopher Newman “Among the personnel authorized to initiate
what does it take to bring the system
Vincent Okony emergency shutdown are the Shift Supervisor
back on line.
Ronnie Patrick and the Operations Manager.”
Fred Pedersen Any meetings, training sessions, evacuation
Lucas Schurman A facility should ask itself: drills, tailgate topics, etc. related to your
Johnny Smallwood
ammonia refrigeration system should be
Kenneth St. Pierre - What makes someone qualified?
Allen Tucker documented.
Russell Wagner - What is safe and timely manner?
Stacy White Bottom line – be sure your SOPs include
- Have conditions that would warrant
Jason Wohleen who is qualified to shut down your
the Shift Supervisor or the Operations
ammonia refrigeration system as well the
Manager activating the Emergency
conditions under which emergency
Kill Switch been discussed?
shutdown is required.
- Do they know where the Emergency
Kill Switch is located?

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