03 Condenser NOV21

THE OFFICIAL MAGAZINE OF THE AMMONIA REFRIGERATION INDUSTRY n NOVEMBER 2021
Building
the BASE
IIAR RELEASES
CO2 STANDARD,
IIAR-2 UPDATE,
NEW GUIDELINES
WWW.IIAR.ORG/CONFERENCE
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NOVEMBER 2021
CONDENSER
STA F F
8 COV E R STO RY
Publisher
Gary Schrift
Building
the BASE
Editor-In-Chief
Andrea Fischer
Staff Writer
Mindy Long IIAR RELEASES
Creative Director CO2 STANDARD,
Bill Ellis
IIAR-2 UPDATE,
V.P. Marketing
and Sales NEW GUIDELINES
Eileen McKeown
V.P. and Technical
Director
Eric Smith
International
Institute of Ammonia
Refrigeration
1001 North
Fairfax Street,
Suite 503
Alexandria, VA 22314
www.iiar.org
Phone: 703-312-4200
Fax: 703-312-0065 4 President’s Message 20 Government Relations
6 Chairman’s Message 22 Improving PHAs with
11 IIAR-2 Updates Address Detection, sample-safeguards checklists
Ventilation and More 26 Financial Tech Tip
13 EPA Grants IIAR’s Petition for 28 Lesson Learned
Increased Hydrofluorocarbon 32 IIAR Participates in Coalition
Restrictions Amicus Brief to the Court
14 CO2 Standard Provides Guidance Regarding Release Investigations
on Growing Segment of the Industry
16 Critical Task Guidelines
www.iiar.org A Publication of the International Institute of Ammonia Refrigeration | November 2021 | CONDENSER | 3
president’s M ESSAGE BY GARY SCHRIFT
I
n this issue of the Condenser, All changes to membership fees, benefits, classes, videos, and conference technical
we’re looking at how IIAR’s and structure will begin with next fiscal presentations noted above. For academics,
mission continues to shape the year’s membership which begins July 1, students, retired, code groups, insurance
world of refrigeration, even as 2022 companies, and regulatory agencies the
that world is constantly shift- Moving forward, IIAR’s membership individual membership fee will be $100.
ing. From our standards writing efforts will include access to a broader range of I hope that these substantial changes will
to new training program development, benefits and services. Starting next fiscal give our smaller IIAR member companies
the task of influencing and even guiding year, payment of your membership fee a positive incentive to add their employees
regulatory activity so that it keeps pace will now include one Academy of Natu- who would like to participate in IIAR, as
with new technology and an ever-evolv- ral Refrigerants online training class per well as encourage everyone to take advan-
ing business landscape – falls to us. year; one online training video per year; tage of the new level of broader access to
These constant evolutions and re-evalua- online access to the content recorded from IIAR’s standards, training, and educational
tions extend even to our own organization, our in-person IIAR annual conference, materials.
After implementing the change to IIAR’s
As a membership group, I’m especially proud membership structure, your Board of Di-
rectors and IIAR staff are tackling several
of our ongoing performance on important

key initiatives for the coming year. With
the release of IIAR-2 2021, which you will
read about in this issue, there has been an
initiatives like standards development and outpouring of questions and clarifications
requested on the newly updated stan-
this year’s significant change in IIAR’s dard. Our standards committee is already
reviewing these requests and is off to the
membership structure races in formulating responses.

Next up will be the update of IIAR-1
and IIAR-3 as well as the development of a
new hydrocarbon standard.
its membership structure, and IIAR’s plans including technical sessions, workshops,
As a membership group, I’m especially
for the future. and technomercials; and downloads of all
proud of our ongoing performance on
It’s no surprise to anyone that the world IIAR’s standards.
has changed in unforeseeable ways since important initiatives like standards devel-
The next substantial change includes the
late 2019. Everything from the way we do opment and this year’s significant change
addition of group membership fees. Mem-
business to the ways we meet, even to the in IIAR’s membership structure. Both will
bership will start with a standard $1,000
ways we try to hold on to practices that serve to advance our influence and enthu-
fee for the first member from a company,
worked in the past, and need a new place siasm for what we do every day. These are
who will also be the voting member. From
in the present, has changed. significant steps forward for our industry
there, a $2,000 fee will include five full
That’s why your IIAR Strategic Plan- in our mission to improve regulatory guid-
individual memberships from the same ance and the general level of safety in all
ning committee and Membership Task company, 1 voting, 4 associate members.
Force members have been evaluating the our facilities.
A $4,000 fee includes 10 memberships, I’m looking forward to continuing that
IIAR membership structure since last year,
$6000 includes 15 memberships, $8000 in- mission when we return to IIAR’s annual
searching for ways to make the organi-
cludes 20 memberships and a $10,000 fee conference in Savannah, Georgia, this
zation more relevant and accessible to
provides 25 full memberships and with the coming year. And as always, you, as an
members than ever before.
option to add additional full memberships IIAR member, represent the experience and
As your IIAR president, I’m happy to
at $100 per person for as many members institutional knowledge that keep our fa-
report that your Board of Directors voted
from the same company as possible. All cilities, operators, and the public safe. Your
to change IIAR’s membership structure
at the most recent board meeting held on members, voting or associate will have ac- participation and membership are vitally
October 7, 2021. cess to the online training content of ANR important. See you all in Savannah!
4 | CONDENSER | November 2021 | A Publication of the International Institute of Ammonia Refrigeration www.iiar.org
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chairman’s M ESSAGE BY ERIC JOHNSTON
I
t’s amazing how quickly a year I believe we met that challenge head-on, the industry in general. One of the best
(or two) can go by. Our 2022 and we will now build on those achieve- parts of being IIAR’s Chairman over the
annual conference, March 6-9 ments in the months ahead. past year has been the opportunity to be
in Savannah, Georgia, is on the As IIAR members, the programs part of this work, and now, to showcase
horizon already, and while that we support are made possible by the it at our upcoming annual conference.
means we’re approaching the last an- hard work of our committees and the Our 2022 exhibit hall is packed with
nual meeting during my term as Chair- volunteer members who run them. the best in technology and expertise
man, this year’s conference represents IIAR continues to focus on providing from across our industry. I hope you’ll
something much more important – a our members with the safety standards, make plans now to take advantage of
return to in-person conferences and the regulatory support, industry technology, the opportunity to see the best your
colleagues and business partners have
to offer in the latest equipment, prod-
ucts, and services available in natural
While the pandemic certainly disrupted life refrigeration.
I’d also like to highlight the IIAR
as we knew it, it also presented an opportu- technical program, an essential part of

the work we do. It’s the best way to en-
gage in the ongoing conversation about
nity for change and a challenge to make that new ways of doing things with other
professional engineers. I hope you’ll
change lasting and positive. I believe we met make it a priority to read the work of
your peers and stop into a live presenta-
that challenge head-on, and we will now build tion to take part in a technical paper
discussion.
I’ll end this month’s column with a
on those achievements in the months ahead. challenge to IIAR members and non-
members alike. This year, become your
industry’s best advocate by taking an ac-
tive role in your continuing education.
beginning of many exciting develop- and other member services that are nec- Get involved in the work of the IIAR
ments for IIAR and its members. essary to operate an ammonia system in committees and lend your voice and
In each membership year, the annual today’s environment. experience to one of our many mem-
conference is the place to kick off new Each opportunity for sharing knowl- ber projects. With your help and hard
programs and initiatives for the year edge and information, such as our work, IIAR and our industry is poised
ahead. In 2020, and 2021 we met sev- annual conference, our Academy of for unprecedented growth.
eral important goals, even as we were Natural Refrigerants program, and the Although we are still months away
meeting remotely and adjusting to the many other IIAR initiatives we advance from a long-awaited in-person meeting,
challenges of an unprecedented in our every day, is a chance for us to build I am already looking forward to seeing
time global pandemic. and strengthen the resources we have many of you at the conference. And be-
While the pandemic certainly disrupt- available for our members. yond that, I’m looking forward to see-
ed life as we knew it, it also presented an We are constantly at work, developing where the achievements of the past
opportunity for change and a challenge ing the world’s largest and best informa- few years take us as we move towards
to make that change lasting and positive. tion resource for our membership and the future of our industry.
March 5, 2022
The Club at
Savannah Harbor
The Ammonia
Refrigeration Foundation
is a 501(c)(3) education
and research
organization supporting
the natural refrigeration
industry.
All proceeds from this

annual tournament are
used to support the
Foundation's
scholarship, research
and outreach programs.
For more information

email us at
golf@nh3foundation.org
With the 2022 IIAR Natural Refrigeration Conference & Expo March 6-9, 2022 Savannah, GA
COVER story
Building
the BASE
IIAR RELEASES
CO2 STANDARD,
IIAR-2 UPDATE,
NEW GUIDELINES
T
he International Eric Smith, IIAR’s vice president, consequently we don’t want them to be
Institute of Ammonia and technical director said the process too lax or too onerous,” Smith said.
Refrigeration’s history of writing standards is never-ending. Maybe even more important is the
is rooted in standards, “New technologies come out that allow knowledge and experience users gain
and the association has safety to be accomplished in new and over time that can improve a standard.
released its latest up- different ways and design standards do “We’ve done these systems for so many
date to IIAR-2, which was first released and should reflect new technologies and years and generally we can find ways to
in 1974, and its first-ever safety stan- new observations in the industry and make systems inherently safer through
dard for carbon dioxide IIAR CO2. observations of what problems need to experience. The standards capture his-
“The benefit of a standard is to be addressed,” he said. tory well,” Hegg said.
bring consistency to safe systems,” said Also, how standards are being used IIAR-2 has incorporated 47 years of
Trevor Hegg, vice president, product can change. “Regulatory agencies rely history to get to its current state, Hegg
development, industrial refrigeration, more and more on IIAR standards when explained. “Fast forward to CO2. There
and water systems for EVAPCO Inc. inspecting refrigeration systems and weren’t many standards dealing with
COVER story
CO2, so you have a huge variety of dif- CO2 Standard starting in 2015 and the IIAR considers every comment.
ferent systems,” he said. IIAR Hydrocarbon Standard starting IIAR also had bi-weekly meetings for
While IIAR was founded with a vision in 2018. This sustained effort by many about a year. Then those turned into
to create standards related to ammonia, volunteer members of the Standards weekly meetings for about another year.
end-users and manufacturers requested Committee, the Board of Directors, and “There was a group of about 20-30
that IIAR develop a standard for CO2. staff have continued to build on IIAR’s people who regularly participated in
The IIAR Board of Directors embraced position as a natural refrigeration orga- these meetings, and I can’t praise them
the idea and viewed it as a way to nization. enough for their dedication to getting
promote the use of CO2 and attract new Now, IIAR is focusing on CO2’s more this done,” Smith said. “Their dedica-
members to IIAR, Smith said. central role in the world of natural tion to meeting and discussing all of
The new standard brings consistency refrigerants. “It is clear for many sce- the comments and working through the
to which systems should be designed and narios, particularly light industrial and resolutions on a regularly scheduled
how to design safe systems, Hegg said. commercial refrigeration, that there is basis was the only way that we would
have been able to finish.”
Hegg said there is value in taking time
to gather public comments. “When you
IIAR has a long history of the development get this whole body of people comment-
ing on a standard, writing, commenting,
and re-writing, it leads you down the
of standards for natural refrigerants. path of having a dependable standard,”
he said. “We take comments very seri-
Over the course of the last 15 years, IIAR ously and many times we’re adjusting
our language.”
Smith said it is difficult to write
ammonia standards have become the basis language that states only the intended
meaning and does not imply anything
for the model building codes in the U.S. else. “Every phrase must be considered
and carefully constructed such that it
removes ambiguity as much as pos-
and many other countries. sible,” he said.
The latest version sets members up
for the next five to ten years, and Smith
said IIAR standards are critical to natu-
ral refrigerants’ future. “If accidents
IIAR has a long history of the a significant advantage to using CO2 were to become more prominent, then
development of standards for natural over synthetics and often over ammonia people would avoid using ammonia. It
refrigerants. Over the course of the last systems,” Smith said. “CO2 systems are would be detrimental to not only our
15 years, IIAR ammonia standards have becoming more and more prominent, industry but also the economy,” he said,
become the basis for the model build- and we felt like there needed to be an as- adding that the cold chain is a critical
ing codes in the U.S. and many other sociation that would champion its use.” part of national infrastructure.
countries. In addition to providing guidance on
The recent publication of the IIAR utilizing safe systems, Hegg said stan- THE NEED FOR A CO2 STANDARD
CO2 2021 standard is part of a pro- dards can even provide more flexibility Because CO2 systems were not all that
gression of efforts that started over 20 to end-users as they make decisions, prominent historically, there was scant
years ago. “My first inspiration for CO2 particularly with new technology. guidance on their construction, instal-
refrigeration was at an IIAR conference “Now they know what a CO2 system lation, and maintenance. Collins said
in Long Beach, California,” said John or what a hydrocarbon system will IIAR has created an important resource
Collins, industrial sales manager for ultimately need,” he said. to all of the industry by bringing
Zero Zone Inc. together experts to crystalize what is
“During this conference, in a panel IIAR-2 SAFETY STANDARD UPDATE needed to safely design, build, operate
session led by Professor Will Stoecker IIAR released the updated IIAR-2 Stan- and maintain CO2 systems.
and other leaders, a vision for IIAR to dard in September. The association has “CO2 is a developing area of refriger-
lead the development of CO2 refrigera- been working on the update for several ation and we have been not only putting
tion was first proposed to our organiza- years. “We had collected roughly 200 together a standard that captures the re-
tion.” Efforts to publish the IIAR CO2 observations and questions that were quirements for CO2 systems but also to
Handbook were started with the initial addressed before the entire publication some degree working with an evolving
publication in 2010. was put out for public review. Subse- industry that is rapidly applying new
Focused efforts to expand IIAR’s quent to public review, we addressed technologies,” Collins said.
scope beyond just ammonia have con- 200 public comments. It was a very By creating a CO2 standard, IIAR is
tinued with the development of the IIAR intense effort,” Smith said, adding that providing the minimum level of quality
that manufacturers and end-users need, that ASHRAE 15 does not address in of the IIAR standards on ammonia. It
Smith said. “Also, one reason we did it detail, Smith said. addresses design, inspection, start-up, and
is to be able to promote CO2 use in a Lundell noted that, “The standard maintenance in the same way several of
way that we thought would not be done would be applicable to industrial and the IIAR standards for ammonia cover
otherwise,” he explained. commercial systems, meaning pro- them individually,” Smith said.
Tony Lundell, senior director of duction facilities, grocery stores, and Collins said an effort is underway
standards and safety for IIAR, said CO2 warehouses.” to get the CO2 standard adopted into
runs at higher pressures than ammonia, There are several layers of approval the international and uniform codes.
so it requires more strength integrity needed to develop a standard, Lundell “Those approvals are pending,” he said.
as it circulates. “There is a little more explained. “We’re eagerly anticipating the outcome
sophistication in its operations and First, the intention must be published of those final hearings.”
maintenance,” he said. by ANSI. Then a consensus body is The publication of the IIAR CO2
The CO2 standard will standardize formed by inviting interested persons to Standard brings the industry a valuable
the means and methods of construction review the work and the process. When resource in a document that can be ref-
erenced as a basis for the proper use of
this developing technology. Collins said
the CO2 standard fills a gap that has
Because CO2 systems were not all that existed in many of our building codes
and standards.
prominent historically, there was scant “However, because the industry until
recent years hasn’t really utilized CO2 to
guidance on their construction, installation,

the extent it is becoming used, it hasn’t
been an identified gap,” Collins said.
“This fills that gap and, now that we
and maintenance. have thousands of CO2 systems around
the world, it is timely. It has been a
growing requirement and is only getting
greater.”
for industrial and large commercial re- a standard is complete, the subcommit- The CO2 standard was needed to
frigeration systems and provide a more tee, then the standards committee, then deliver beyond only general guidelines
even playing field to manufacturers and the consensus body, and finally the IIAR that previously existed, Lundell said.
contractors in the industry. “This is Board of Directors must all approve the The CO2 standard developed includes
obviously a benefit to owners and users content and the process in that order. more in-depth design requirements, as
so that people will be able to count on “To be ANSI approved, a standard must well as installation, startup, inspection,
a minimum level of quality and safety be developed according to strict adher- testing, and maintenance minimum
when it comes to construction consis- ence to ANSI approved IIAR procedures requirements.
tency,” Smith said. and the ANSI Essential Requirements. Collins said an effort is underway
This standard should be considered ANSI verifies the process through peri- to get the CO2 standard adopted into
a companion standard to AHRAE 15, odic, thorough audits,” he said. the international and uniform codes.
but it goes further than ASHRAE 15 by The same format was used for both “Those approvals are pending,” he said.
providing requirements for construction IIAR 2 and the CO2 Standard. “The CO2 “We’re eagerly anticipating the outcome
installation, testing, and maintenance standard is really more analogous to most of those final hearings.”
IIAR-2 Updates Address Detection,

Ventilation and More
T
he International Insti- sometimes it is a matter of safety, other volunteer committee members and the
tute of Ammonia Refrig- times it is a matter of clarification,” said public reviewers deserve a great deal of
eration has released the Eric Smith, IIAR’s vice president, and recognition for their years of hard work
latest version of IIAR-2, technical director. “This revision was on this project.”
which covers the design the result of opening the entire docu- Tony Lundell, senior director of
of safe closed-circuit ment up for review and public comment standards and safety for IIAR, said
ammonia refrigeration systems. IIAR-2 as is required periodically according to the latest version has an updated title:
was first released in 1974 and received IIAR and ANSI procedures. The com- Standard for Design of Safe Closed-Cir-
its last major update in 2015. mittee addressed over 400 internal and cuit Ammonia Refrigeration Systems.
“Any change is important for vari- external comments in painstaking de- Previously it was called the Standard for
ous reasons. The real reason is that tail, resulting in this latest version. The Safe Design of Closed-Circuit Ammonia
Refrigeration Systems. ments and proof of operation • A significant revision of the appendix
IIAR-2 addressed several issues, requirements. providing guidance on hydrostatic
including a change in ammonia detec- protection.
tion and alarms. “Essentially, through • New requirements for evaporators
risk analysis, research, and a lot of concerning design for freeze protec- New appendices in IIAR-2 include:
discussion, the committee decided that tion and design for frozen products.
• O: Designing to Avoid Component
it was critical for emergency ventila- • Revised requirements for equipment Failure Caused by Abnormal Pressure
tion systems to be more reliable,” Smith enclosures. or Shock.
said. “The National Electric Code
requires that electrical equipment in a • A new requirement to pressure- • P: Removal of Water from a Refrig-
machinery room be either classified as protect any equipment with a volume eration System.
Class I, Division II or that the room be of greater than 0.5 Ft3, regardless
of whether it is constructed per the • Q: Guidelines for the Identification of
ventilated upon detection of ammonia.
ASME Boiler and Pressure Vessel Ammonia Refrigeration Piping and
Because it is critical that emergency
Code. System Components.
ventilation systems are triggered by am-
monia detection, these systems must be
reliable and consequently, the require-
ments for ammonia detection have been The History of ANSI/IIAR-2 BY TONY LUNDELL
enhanced.”
Therefore, with some exceptions, ma- The first edition of ANSI/IIAR-2 was released in 1974.
chinery rooms are now required to have Revisions occurred in 1978, 1984, 1992, 1999, 2008, 2014, 2014 Addendum, &
at least two detectors that are triggered 2021
at the same level to activate emergency
In 2008, the title was, “ANSI/IIAR 2-2008 Equipment, Design, and Installation of
ventilation.
Closed-Circuit Mechanical Ammonia Refrigeration Systems.”
Another big change is that IIAR has
integrated the fire code requirements ANSI/IIAR 2-2008 Addendum A was in 2010, which Included Machinery Rooms,
for emergency pressure control systems. Ventilation, & Relief Piping Material
“The good news is that emergency ANSI/IIAR 2-2008 Addendum B was in 2012, which included Flange
pressure control systems (EPCS) will be and Valve Installation
required only when the authority having
ANSI/IIAR 2-2014 – The standard was revised for safe design, becoming “ANSI/IIAR
jurisdiction requires them. An EPCS
2-2014 Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems”.
is presented as one option along with
diffusion tanks as a means of mitigating This version removed installation, startup, and most maintenance requirements. This
relief valve system releases,” Smith said. permitted the standard to address only the minimum requirements for designing safe
“By including this we are confident that closed-circuit ammonia refrigeration systems.
fire codes will defer all ammonia refrig- Some of the major changes include:
eration requirements to our standard
beginning in 2024.” • Design and Installation Considerations Affecting Construction
The standard now permits discharge • Refrigeration Equipment Located in Areas Other Than Machinery Rooms
to the atmosphere, when permitted by • Packaged Systems and Equipment (because of growth in smaller system)
the AHJ after an evaluation, or alterna-
tively, providing an EPCS or a dilution • Instrumentation and Controls
tank (rather than both). Prior to this • Ammonia Detection and Alarms
edition of IIAR-2, it was often required
to provide both redundant systems. • An (Informative) Appendix A for including Explanatory Material that correlated with
the Standard’s normative (required) sections.
There were many minor changes
made to improve clarity, function, or ANSI/IIAR 2-2014, Addendum A:
safety, and users of the standard should • Required the review and considerations of 53 pages
review it in its entirety. But additional
significant updates to IIAR-2 include: • Four (4) Public Reviews were done which had 149 comments
• New and revised definitions. • Highlights included:

n Ammonia-based absorption systems were added
• A new requirement is that evapora-
tors and condensers must comply with n Clarification of the grade of ammonia required
ANSI B31.5, when not constructed to n Prohibits the use of fusible plugs
the Boiler and Pressure Vessel Code.
n Added provisions to align requirements with ASHRAE 15
• Clarifications on the requirements for n Added clarity to ammonia detection and ventilation
eyewash/safety showers. requirements for packaged systems
• Changes to machinery-room exhaust The latest version, ANSI/IIAR 2-2021, was released in September 2021.
and ventilation equipment require-
EPA Grants IIAR’s Petition for Increased
Hydrofluorocarbon Restrictions
T
he Environmental from equipment and facilitating the further regarding Chillers for Indus-
Protection Agency transition to next-generation technolo- trial Refrigeration. “Subsection (i) of
has granted a petition gies through sector-based restrictions. the AIM Act on ‘Technology Transi-
from the International The agency’s first proposed rulemaking tions’ authorizes EPA to ‘restrict, fully,
Institute of Ammonia under the AIM Act would set the HFC partially or on a graduated schedule, the
Refrigeration and its production and consumption baseline use of a regulated substance in the sec-
industry partners to use the agency’s levels from which reductions will be tor or subsector in which the regulated
authority under the American Innova- made, establish an initial methodology substance is used,’” according to the
tion and Manufacturing Act to restrict for allocating HFC allowances for 2022 petition.
the use of hydrofluorocarbons within and 2023, and create a robust, agile, In a letter to Schrift granting the peti-
the refrigeration sector. and innovative compliance and enforce- tion, Regan said, “The EPA intends to
move swiftly to develop a proposal and
will continue to engage with stakehold-
ers as we proceed. However, please note
that a petition grant does not mean
EPA will now have two years to propose that the agency will propose or finalize
requirements identical to those in your
petition.”
and finalize rulemakings addressing this IIAR is continuing to work with other
groups who submitted petitions to find
and other petitions and expects the

common ground and consensus moving
forward, Randel said.
Regan said that granting IIAR’s peti-
forthcoming rules will provide a clear tion along with others submitted was
“another step forward in advancing
regulatory landscape that will help the

President Biden’s commitment to tackle
the climate crisis, as we work to phase
down and restrict the use of super-
transition to more climate-friendly polluting HFCs as Congress directed. In

less than a year, EPA has already begun
implementing the AIM Act to build a
alternatives, the agency said. strong foundation, moving the United
States away from these climate-damag-
ing chemicals.”
Regan said the agency looked forward
to working with IIAR and all stakehold-
ers in the next steps of the process.
“This is a significant opportunity for ment system, the agency said. As part of its petition, IIAR wrote
IIAR to take a leadership role and it is IIAR’s petition, which was sent to that the technology has existed for de-
very encouraging that EPA has granted EPA Administrator Michael Regan, cades in the design and manufacturing
IIAR’s petition,” said Lowell Randel, requested that the EPA limit the use of of chillers for industrial process refrig-
director of government affairs for IIAR. refrigerants of 150 or greater GWP in eration using natural refrigerants for
“It places the organization in a very the refrigeration sector in general (both all temperature ranges. The association
good position to play that lead role in commercial and industrial). The petition told EPA the use of natural refrigerants
working with other stakeholders and identifies several areas, including food including CO2, ammonia, and hydro-
the EPA to shape the ultimate policy.” retail, cold storage warehouses, and carbons will significantly and posi-
EPA will now have two years to pro- manufacturing, where these limits could tively impact global warming reduction
pose and finalize rulemakings address- be set in place. IIAR was joined by co- goals using refrigerants with ultra-low
ing this and other petitions and expects petitioners, the Refrigerating Engineers refrigerant GWP values and increased
the forthcoming rules will provide a and Technicians Association, and the operational energy efficiency of these
clear regulatory landscape that will help Ammonia Safety & Training Institute. refrigeration systems.
the transition to more climate-friendly In the petition, Gary Schrift, IIAR’s IIAR recommended that the chillers for
alternatives, the agency said. president, said the association believes industrial process refrigeration restriction
The AIM Act directs EPA to address that California’s framework for HFC take effect on Jan. 1, 2026, to provide
hydrofluorocarbons by phasing down phase-down can serve as a good model manufacturers, contractors, and owners
production and consumption, maximiz- for EPA’s implementation of the AIM the time to meet the needs created by this
ing reclamation and minimizing releases Act. However, IIAR petitions to go excellent single-step approach.
CO2 Standard Provides Guidance on
Growing Segment of the Industry
T
he International Insti- During the development of the CO2 of the equipment. IIAR has compiled in
tute of Ammonia Re- Standard, it first went through a pre- the IIAR CO2 standard what is covered
frigeration has released public review receiving over several for ammonia in multiple standards from
its safety standard for hundred comments that were addressed, IIAR-2 through IIAR-7.
CO2 closed-circuit then progressed through four public re- Lundell said there are several benefits
systems. The standard views receiving 186 comments that were to CO2 as it is a natural refrigerant
covers all phases of the CO2 system all addressed, said Tony Lundell, senior with zero ozone-depleting potential and
lifecycle, from design, installation, and director of standards and safety for IIAR. a global warming potential rating of
start-up to inspection, testing, and “We made a significant effort in this one. Anhydrous ammonia, the leading
maintenance. It encompasses the CO2 process to engage and encourage the natural refrigerant, has zero ODP and
portion of a cascade system, systems involvement of a wide range of indi-
zero GWP. CO2 is non-flammable and
using CO2 as a secondary fluid, systems viduals, many not traditionally involved
is not toxic, which simplifies install
operating part- or full-time in the tran- with IIAR,” Collins said. “Our task
requirements and reduces many of the
scritical cycle, and heat pumps. group included members who work in
safety restrictions compared to ammo-
nia. Compared to synthetic refrigerants,
Part One of the Standard defines the scope the heat transfer characteristics of CO2
are more attractive and CO2 refrigerant
and purpose along with key definitions and is less expensive. These characteristics
coupled with the realities of the chang-
references. Part Two of the Standard provides ing regulatory environment are driving
a shift toward CO2 refrigeration which
requirements for proper design. is rapidly gaining momentum.
CO2 must operate at higher pressures
than other refrigerants, but a system
“We’re seeing more transcritical the commercial side of refrigeration in designed to the IIAR CO2 Standard is
refrigeration systems. If people are using retail and other non-industrial applica- safe. The properties of CO2 offer great
these systems, they need to understand tions. This was an important part of opportunities for cost-effective, high-
what is appropriate in terms of using assuring the document covers all CO2 performing, systems with more compact
them and constructing them and they applications and was key to gaining the components and smaller piping than
need somewhere to look to,” said John broad acceptance that allows this stan- feasible with other refrigerants. The
Collins, industrial sales manager for dard to serve the entire industry.”
technology of today’s CO2 refrigeration
Zero Zone. “Transcritical CO2 is some- Part One of the Standard defines
systems has advanced over the last 20
thing that is somewhat of a mystery to the scope and purpose along with key
years to be efficient, cost-effective, and
many people.” definitions and references. Part Two
relatively easy to install and operate.
Collins said many people have experi- of the Standard provides requirements
for proper design. Key aspects of CO2 There is still more work to be done.
ence working with the requirements “Given the quantity of new applications
of ammonia, especially around the system design include:
where we’re seeing CO2 being installed
detection, ventilation, and managing the • Location of equipment now, it is becoming more and more appar-
risks and hazards of ammonia, but are
• Carbon dioxide leak concentration ent that we need more development. We’re
less familiar with the properties of CO2.
limits looking at next steps in terms of develop-
“Carbon Dioxide has a safety classifica-
• CO2 refrigerant specifications ing the standard further,” Collins said.
tion as an A1 refrigerant, not a B2 re-
frigerant, and as such the requirements There are likely opportunities to use
• System design pressures the Ammonia Refrigeration Founda-
for design are different than ammonia.
It is a learning process for many people • Suitable materials and components tion and IIAR’s Research Committee to
to understand what a different refriger- • Overpressure protection conduct research that will benefit the
ant requires,” he explained. CO2 Standard. “IIAR has a tremendous
• Monitoring equipment and levels group of members and a lot of resources
The safety standards for CO2 are dif-
ferent than they are for ammonia and Parts three, four, and five of the Stan- and we’re in a good position to synthe-
even different from other A1 refriger- dard cover installation, startup, and in- size a lot of what the industry has out
ants. “Because we have a dedicated spection, testing, and maintenance. This there,” Collins said.
standard to CO2, we’re able to provide is a comprehensive standard that covers This includes drawing from the
a depth of background and be sure that all aspects of CO2 refrigeration from the knowledge of our colleagues in Europe
the particulars that are unique to CO2 initial system design concept to con- where CO2 has been more widely used
are properly addressed,” Collins said. struction and through the operating life in the last 20 years than in the U.S.
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www.iiar.org 15
A Publication of the International Institute of Ammonia Refrigeration | November 2021 | CONDENSER |
GUIDELIN
IIAR Releases Critical Task Guideline S K E
TA
S
he International mends wearing an APR when working
ITICAL
Institute of Ammonia aloft on equipment that is near charged
Refrigeration (IIAR) has ammonia systems. This will not only in-
recently published the crease the person’s awareness that care
first edition of a new should be taken but also prepare them
guideline titled “Critical should an incident occur.
CR
Task Guidance for Ammonia Refrigera- The guideline addresses the need and
tion System Emergency Planning.” applicability of dealing with medical
The “Critical Task Guidance” was de- and rescue duties included in facilities’
signed to assist employers, government Emergency Action Plans and/or Emer-
regulators, and public safety emergency gency Response plans, as required by 29
responders who prepare emergency CFR 1910.38 and/or 29 CFR 1910.120.
procedures to address ammonia inci- It also outlines the extent to which
dents. The document was developed a technician could take offensive or mum requirements of the regulations.
by consensus among members of IIAR, corrective actions when dealing with a The guideline simply helps them address
the Refrigerating Engineers and Techni- release, which can help to mitigate them the specific topics covered within it.
cians Association (RETA), the Global and keep them from becoming more The “Critical Task Guideline” was
Cold Chain Alliance (GCCA), and the problematic. created because there was a lack of best
practice emergency plan information for
medical, rescue, and emergency system
The guideline identifies three critical tasks

control available to employers and emer-
gency planners to address the most threat-
ening part of an ammonia operator’s
associated with the safe operation and mainte- world, explained Gary Smith, president,
and chief executive officer of ASTI.
nance of ammonia systems and response to an “Cal-OSHA was aggressively going
after industry because emergency action
unplanned ammonia incident—preparation, es- plans lacked substance and value when
defending the worker from a sudden
cape and system emergency control and rescue. release of ammonia. This occurs during
maintenance, service, repair, and a sud-
den failure within the ammonia refriger-
ation system,” Gary Smith said, adding
Ammonia Safety and Training Institute It also establishes a protocol of that Cal-OSHA was correct in pointing
(ASTI) and reflects insights from various awareness training, the necessity of out the issue.
regulatory agencies. communications, and an incident com- The regulations are not specific. They
“This guidance is intended to be mand system. The guideline offers in- are performance standards that are of-
integrated into site-specific plans to ad- formation about APRs, interpretations ten interpreted to mean that companies
dress pre-event readiness and ammonia of applicability, a sample leak investi- should simply evacuate a facility and
release actions. It addresses emergency gation procedure, guidance on heroic call 911 in response to any emergency.
action training requirements, emergency rescue, a sample teaming agreement This approach can be problematic in
action planning, and advocates for the for local emergency response groups, a many ways in that the first 30 minutes
use of air-purifying respirators (APRs) sample emergency action checklist, and of a release is usually the most critical
and the circumstances in which they other useful information. time. This is when small releases can
should be used. It is intended to be inte- Lundell noted that it is important to be stopped, systems shut down, and an
grated into new emergency action plans understand the guideline should be used orderly escape and evacuation should be
and/or emergency response plans. It to augment plans and does not consti- carried out, said Eric Smith, IIAR’s vice
can also be used to strengthen existing tute a complete plan. president, and technical director.
plans,” said Tony Lundell, senior direc- Companies can reference this guide- “The most frustrating part of the
tor of standards and safety for IIAR. line and use it as a Recognized and problem was that most of us knew the
The guideline identifies three critical Generally Accepted Good Engineering answer to the problem but adding or
tasks associated with the safe operation Practice (RAGAGEP) if so desired. “By changing OSHA regulations is a very
and maintenance of ammonia systems a company declaring a publication is difficult process,” Gary Smith said. “We
and response to an unplanned ammonia used as RAGAGEP in their programs it felt that a better solution would be to
incident—preparation, escape and sys- will be enforced through PSM/RMP, a give advice to the industry that they
tem emergency control and rescue. local requirement, and/or by the Gen- could use to upgrade their Emergency
“It is designed to avoid and address eral Duty Clause (GDC),” Lundell said. Action Plans so that injury of workers
ammonia incidents,” Lundell said, However, it is not mandatory to do would be significantly reduced.”
adding that responders often aren’t so. Companies can simply integrate the IIAR, ASTI, RETA, and GCCA all
prepared to deal with an ammonia situ- recommendations into their plans in worked together to create the guidance,
ation and need additional information. part or whole. But regardless of their which Gary Smith said was a sensible solu-
For example, the guideline recom- choice, they must still meet the mini- tion and a win on all sides. “I think we hit
CRITICAL TASK guidelines
the bullseye on this one,” he said. “From of bulletins in favor of ANSI developed try, typically end-users, develop their
the standpoint of the leadership, I would standards where applicable,” said Eric own methods for high-quality programs
say collectively we did a good thing.” Smith, IIAR’s vice president, and techni- that aid them in efficient, safe, and com-
Gary Smith said Cal-OSHA has cal director. pliant operations,” Smith said.
reviewed the guideline and said it is an Standards relay prescriptive require-
“And while guidelines are not devel-
excellent compromise between simple ments and undergo the ANSI process of
oped per the ANSI method, they are
evacuation and a full HAZWOPER development and review. The industry
response requiring specially trained tech- must follow the standards and regula- vetted by a broad range of industry
nicians and equipment. He added that tors are obliged to observe them. Bulle- professionals, including contractors,
a favorable outcome in the TECO case tins contained a lot of informative mate- end-users, engineers, consultants, aca-
would enhance the importance of this rial that was not deemed to be necessary demics, and manufacturers, who partici-
new guideline to safely address releases, to mandate for minimum safety require- pate on the committees that develop or
whether they are incidental or not. ments. So, in keeping with the concept review them as well as the IIAR Board
Gary Smith said the bottom line is that to retire bulletins, such informative of Directors, which ultimately decides
no one should suffer serious injury or information was either included in stan-
to publish them or not,” Eric Smith
death because of an ammonia release if dards’ appendices or was re-branded as
they follow the guidance. He added that guidelines. “New informative informa- explained.
90% of the problem is solved if the operation on specific topics is being published IIAR standards and bulletins serve as
tors wear the right type of respirator. as guidelines, such as this guidance on the information that regulators respect as
The publication is being published emergency action plans,” Eric Smith “gospel” while a guideline is a collection
as a guideline, rather than a standard said. “While it did not undergo the of good information that has no official
or a bulletin. Bulletins were developed ANSI development process, it’s was a standing in the regulatory world, Gary
before most of the IIAR standards collaborative effort relaying a compila- Smith said. “It’s a compilation of good
were created, and before the advent tion of good information from various information from many sources outside
of OSHA’s and EPA’s promulgation of authoritative resources.”
of the reign of the regulators,” he said.
Process Safety Management and Risk Guidelines, like the bulletins before
Management regulations. The bulletins them, do not undergo the ANSI process The guideline is now available for
covered many of the topics that are now and their use is not mandated by any purchase. Like all IIAR guidelines, it
covered by standards. “IIAR decided code or regulation, Eric Smith said. will be subject to periodic review by
over a decade ago to end publication “They are published to help the indus- relevant committees.
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As HFCs are Phased-Down, Disincentives
for Ammonia Must be Avoided
RELATIONS
government BY LOWELL RANDEL, IIAR GOVERNMENT RELATIONS DIRECTOR
W
ith the passage providing climate-friendly refrigeration ally, the requirements do not take into
and ongoing solutions. The majority of industrial re- consideration the increased automation
implementation frigeration facilities in the United States and safety features built into modern
of the American already utilize anhydrous ammonia as ammonia refrigeration systems. Cur-
Innovation and their primary refrigerant. Industry over- rent rules for gold seal operators were
Manufacturing whelmingly chooses ammonia because implemented long before automa-
(AIM) Act at the federal level, some it is the most efficient refrigerant for tion and other widely adopted safety
states are also taking actions to phase industrial applications. The one excep- features were prevalent. On average, it
down hydrofluorocarbons (HFCs). As tion to the widespread use of ammonia is estimated that these licensing require-
policymakers move away from HFCs, it is the State of New Jersey. The Toxic ments result in a minimum of $100,000
is also important that ammonia policies Catastrophe Prevention Act (TCPA) and in additional costs annually for facilities
be kept in an appropriate balance, to the New Jersey Refrigeration Operator in New Jersey.
avoid unintended consequences of poli- licensing requirements, as they currently Combined, the TCPA and operator
cies that may serve as disincentives for apply to ammonia refrigeration systems licensing requirements cost facilities in
facilities to move to natural refrigerants. are the most restrictive in the United New Jersey using anhydrous ammonia
A good example of such policies can be States and serve as strong disincentives
over $120,000 more annually than
found in the State of New Jersey. for facilities to move away from HFCs.
their counterparts in neighboring states.
The New Jersey Department of Envi- IIAR estimates that the initial cost to
These policies provide a direct deter-
ronmental Protection (NJDEP) has initi- come into compliance under the TCPA
rent to facilities looking to transition
ated a rulemaking to begin its process is approximately $32,500 and the an-
from HFCs to ammonia and put the
to phase down HFCs. The rulemaking, nual cost after that is over $21,000.
State of New Jersey at a disadvantage
Docket Number: 06-21-05 Proposal It is important to note that the TCPA
when competing for jobs and economic
Number PRN 2021-058 Greenhouse Gas comes on top of the U.S. Environmental
growth. These policies continue to take
Monitoring and Reporting, focused on Protection Agency’s Risk Management
a toll on the growth of the refrigerated
establishing a baseline of HFC use, moni- Program (RMP) and the U.S. Occu-
warehousing industry in New Jersey, as
toring, and reporting. The International pational Safety and Health Adminis-
tration’s Process Safety Management well as the broader food sector.
Institute of Ammonia Refrigeration
requirements. Because federal regula- As the State of New Jersey and
(IIAR) provided oral comments during
an NJDEP public meeting and also sub- tions are in place to address the very other jurisdictions move forward with
mitted written comments regarding the same hazards as TCPA, there will be no policies designed to reduce the use and
state’s policies. IIAR comments focus on diminishment in safety to workers or emissions of HFCs, removing unneces-
the importance of a holistic look at New the environment should anhydrous am- sary regulatory burdens on ammonia
Jersey state policies and the removal of monia be removed from the TCPA. would eliminate major disincentives for
disincentives for companies to transition The second barrier is the New Jer- companies wanting to transition from
from (HFCs) to natural refrigerants such sey Refrigeration Operator licensing HFCs to a natural refrigerant with zero
as anhydrous ammonia. requirement that mandates a 24-hour global warming potential. This will be
IIAR shares NJDEP’s goal of reducing Gold Seal operating engineer. New Jer- an important consideration as US EPA
emissions of greenhouse gases with high sey is the only state with such licensing and OSHA look at potential revisions
global warming potential. However, in requirements, which place a significant to the Risk Management Program and
addition to the current rulemaking be- economic burden on facilities using Process Safety Management regula-
ing considered, the State of New Jersey ammonia as an industrial refrigerant. tions. IIAR will continue to work with
should address current barriers to com- Requirements for trained Refrigeration policymakers to promote the use of
panies wanting to transition from HFCs Operators in Federal regulations such natural refrigerants and advocate for
to anhydrous ammonia. The use of as PSM and RMP already ensure that the appropriate balance of policies to
natural refrigerants such as anhydrous qualified personnel are operating am- avoid any potential disincentives for the
ammonia will play an important role in monia refrigeration systems. Addition- transition to ammonia.
Improving PHAs With Sample-Safeguards Checklists
J A M E S H A D L E Y , P. E .
This article represents the opinions of the author only. It does not necessarily reflect any official position
of IIAR and is presented here for the consideration of the reader. Questions or comments about the article
can be sent to IIAR and may be forwarded to the author at IIAR’s discretion.
F
or many ammonia- • ammonia refrigeration PHAs have • a more comprehensive starting point
refrigeration systems, a often used blended methods, including (avoid missing well-known hazards
what-if/checklist process- some what-if questions resembling the and safeguards);
hazard analysis (PHA), methods of a HAZOP study (pressure,
temperature, level... is high or low, • saving time and avoiding exhausting/
with brainstorming about
here or there) and others resembling frustrating the PHA team (burnout);
unique situations enhanced
by a comprehensive safeguards checklist, failure modes and effects analysis • easier to see what is unique about a
provides a robust method for identifying (this or that mechanical, electrical... refrigeration system or facility, which
hazards, analyzing risks, and developing component fails in some way). may create unusual risks, by using revi-
any needed recommendations. sion tracking to compare the custom-
More collaboration on sample docu- AN ADDITIONAL SOLUTION ized to the sample PHA reports, and;
ments would help the industry complete One approach to improving a what-if/
better PHAs. The technical and legal checklist PHA is to start with a sample • easier to aggregate the results across
tools for collaboration are improving document that has: many facilities, to gain an understand-
rapidly, ranging from artificial intel- ing of which hazards and safeguards
• fewer but broader what-if questions,
ligence to better revision-tracking soft- are widespread because the causes,
to help the PHA team catch unique
ware, and also including widely used consequences, and safeguards are
situations;
copyright and licensing approaches. semi-structured data.
Whether improving PHA methods • more detailed sample safeguards (also
Semi-structured data is facilitated by
for ammonia refrigeration is needed, called controls), which serve as a
giving sample causes, consequences,
and if so, how, has been discussed in the checklist, and;
and safeguards both names and descrip-
industry recently. For over twenty years, tions. The PHA team can then select
• sample lists of causes and consequenc-
the what-if/checklist PHA method has es, which may be modified as needed. these by name, modify the description
typically been used to evaluate refrig- as needed, but only modify the name if
eration systems that contain 10,000 For comparison, based on a small necessary. If an owner of many refrig-
pounds or more of ammonia refrigerant sample: eration systems then compares PHA
in the USA. Some facilities have used • some HAZOP and what-if/checklist reports between their facilities, they’ll
hazard and operability (HAZOP) studies PHA reports, for ammonia-refrigera- see mostly the same names for causes,
instead, and the 2021 IIAR conference tion systems, have 300 to 400 scenar- consequences, and safeguards, with dif-
included a technical paper on “The Case ios, whose safeguards include 10,000 ferences in their descriptions.
for HAZOP,” by Stephanie Smith, P.E., to 20,000 letters, approximately;
Risk Management Professionals, Inc. SHARING ANONYMIZED PHA DATA
A full HAZOP study is appropriate • recent safeguard-checklist focused INDUSTRY-WIDE
for processes with unique science or what-if/checklist PHA reports have Some industries, via companies that are
engineering, which may include parts of 130 to 145 scenarios, whose safe- members of the Center for Chemical
some ammonia-refrigeration systems. guards include 50,000 to 65,000 Process Safety, have started to compile
Often ammonia-refrigeration systems are letters, approximately. anonymized PHA data from multiple
designed to code, handbook, and manu- facility owners to improve their PHA ef-
With a longer sample-safeguards forts. The cost and effectiveness of these
facturer recommendations, and a good
list, a big part of the PHA team’s effort artificial-intelligence approaches may
checklist covers most of the ground. becomes comparing sample safeguards
It would be very difficult to quan- depend on the quality of PHA reports
to the planned or as-built system and and other documents used as inputs.
titatively compare PHA methods by deciding if any need to be implemented.
what matters most — how much they This type of collaboration may allow
The goal is a PHA that’s both com- better comparisons of PHA methods,
improved safety — because: prehensive and easier to complete. than the limited attempt made above, in
• multiple checks help ensure safeguards this article.
are in place (if a PHA team didn’t AVOIDING CANNED PHAs
catch something, a building inspector, The desire to avoid “canned” PHAs, COLLABORATING ON SAMPLE PHA
contractor, maintenance manager... that don’t get adequately customized, REPORTS ESPECIALLY SAFEGUARDS
has led to under-appreciating the ben- CHECKLISTS
might);
efits of having sample cause, conse- IIAR standards provide a starting point
• a PHA team’s effort may compensate quence, and safeguard wording, that for sample safeguards that PHA teams
for the pros and cons of the method only get customized as needed. These may review.
they use, and; benefits include: IIAR 9-2020, Minimum System Safety
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Improving PHAs With Sample-Safeguards Checklists
Requirements for Existing Closed-Cir- changes well tracked, some free tools informality of developing sample
cuit Ammonia Refrigeration Systems, that could help include the following. documents in this way would help
calls for completing minimum system- • Git and GitHub allow tracking distinguish them from standards, to
safety evaluations by about March 2025 and sharing large sets of text docu- which regulators may try to enforce
and every five years thereafter. If a PHA ments. They also allow branching, compliance.
is done in the meantime, shouldn’t it for example, if two groups of people
at least check if these minimum system • Legal tools for licensing sample
can’t agree on a change to a sample
safety requirements are met? document, the document could be documents (and computer code, etc.)
IIAR 6-2019, Inspection, Testing, and “branched,” with each group making that get modified for commercial use,
Maintenance [ITM] of Closed-Circuit their own version, and with the ability which to date have protected con-
Ammonia Refrigeration Systems, which to view the differences between the tributors from liability, include the
is a required “normative” reference of branches as time goes by and more Apache, Creative Commons, MIT,
IIAR 9-2020, describes ITM safeguards changes are made. The flexibility and and other licenses.
that a PHA team could compare to a
facility’s ITM practices.
The design and building codes and
standards that may apply to a refrigera-
tion system and its supports, based on
its location and installation start date
(or building-permit application date),
likewise can serve as checklists. In re-
cent decades, these usually include one
or more IIAR-2 editions, the ASME and
other codes & standards they reference,
and any applicable building codes.
The contents of IIAR handbooks
and guidelines, such as The Refrigera-
tion Piping Handbook, could make a
checklist too long, but a checklist can
reference them, and the PHA team may
turn to them as needed, such as for in-
formation on avoiding shocks or upper
limits for flow velocities in piping.
PHA teams should look further than
the minimum requirements in stan-
dards. Safeguards identified by prior
PHA teams over the years help do
this. Some PHA leaders have compiled
these, in documents or even just in their
memory, to provide suggestions during
PHA team meetings.
Collaborating on lists of sample
safeguards, or entire sample PHA Highest Quality Base Oil
reports could aggregate this experience,
from many PHA teams. Most of a PHA Highest Quality Additives
team’s effort, and hopefully the value
they create, results from their evaluation
Highest Quality Control
of a specific facility and refrigeration Highest Quality Customer Service
system, producing customized recom-
mendations. Collaborating on sample
documents would help focus attention
on this site-specific effort and would still
allow competition between who best
There is no substitute for the best.
leads PHA teams to provide the needed
customization.
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A Publication of the International Institute of Ammonia Refrigeration | November 2021 | CONDENSER | 25
N CIAL
Bitcoin: Fad or The Future? I NA
F
If someone told you about an investment a global virtual currency facilitates
that has made some people millionaires global commercial transactions, (3)
overnight and has both several high-pro- every block and Bitcoin transaction is
file supporters and a global reach, would recorded in a public ledger known as
you be tempted to invest? If you were “the blockchain,” and (4) the payer and
then told that the same investment also payee are anonymous, much like a cash
could lose most or all of its value almost transaction, though recorded transac-
overnight, and you might not have access tions are visible to anyone. However,
P
to your money when you need it, how that anonymity has attracted charges
that its chief use so far has been for ille-
TECH TI
would it sound now?
You’ve just confronted the debate gal activities such as money laundering;
surrounding the digital phenomenon in October 2013, the FBI shut down the
tested — over and over — by gut-
known as Bitcoin. An alternative cur- Silk Road Bitcoin exchange and seized
wrenching price declines.1
rency that exists strictly as digital code, its assets.
For the 12-month period through
Bitcoin has received a lot of attention. March 13, 2021, the price of Bitcoin
But is it an investment? A network of HOW DOES A BITCOIN rose more than 1,000%, driven, in part,
computers? An underground economy? PAYMENT WORK? by a stimulus-fueled surge of trading
The future of currency? If you’re won- Just as a physical wallet holds paper through brokerage accounts and invest-
dering what all the fuss is about, here’s money and change, a digital wallet ing apps.² But there was also a note-
a brief introduction to Bitcoin, how it stores the private software keys that are worthy increase in interest and demand
works, and some of the potential pitfalls bitcoins. It makes or receives payments from mainstream U.S. corporations and
it presents. by communicating with the network financial institutions. For example, one
of other Bitcoin wallets. A growing long-established U.S. bank announced
BITCOIN AS CURRENCY number of well-known merchants and that it will hold and transfer Bitcoin
Bitcoin isn’t a company but rather a services now accept Bitcoin as pay- and other cryptocurrencies on behalf of
virtual currency supported by a peer- ment. Physical bitcoins, with embedded clients, a major credit-card processor is
to-peer, computer-based electronic cash software keys, are also being minted. incorporating cryptocurrencies into its
system first outlined in 2009 by an However, acceptance of bitcoins as pay- network, and several widely used pay-
anonymous person or group using the ment is entirely at a seller’s discretion; ment and banking apps already provide
name Satoshi Nakamoto. Unlike printed there is no guarantee you’ll be able to various crypto services.³
currency or coins that are minted, spend them where you want to or get Despite its current lack of connec-
Bitcoin is created by “mining” — using the value you expect. Also, as outlined tion to any central bank, Bitcoin has
complex software to solve complicated below, problems at some exchanges been vulnerable to actions by indi-
have sometimes impeded access to vidual governments. In 2013 and 2017,
mathematical computations (or con-
Bitcoin funds.
tracting with a mining company to do Chinese regulatory crackdowns were
it for you). Solving a problem creates Note: Bitcoin payments are irreversible. accompanied by drastic declines that
a so-called “block,” and the computer Once you complete a transaction, it cannot cut Bitcoin’s value in dollars by more
that solved it is rewarded with a set be reversed. than half.4 In January 2018, regula-
number of digital bitcoins, each of Purchases can be refunded, but that tors ordered the closing of mining
which is simply a set of one public and depends solely on the willingness of the operations that were creating more than
one private cryptographic key. (The establishment to do so. three-fourths of the world’s supply of
units are generally “bitcoins,” while the Bitcoin.5
general system is “Bitcoin.”) The num- SPECULATING IN BITCOIN Extreme volatility has led to problems
ber of solutions that can be discovered Bitcoin’s usage as a currency is a ripple for people trying to make payments
globally per hour (and thus the number compared to the tidal waves of invest- in bitcoins. It’s hard to use a currency
of “blocks” created and bitcoins mined) ment speculation it has fueled. “Invest- when you’re not sure from day to day
is limited by the system’s software code. ing” in bitcoins simply means acquir- whether the amount in your virtual
The total number of bitcoins available ing them through one of the methods wallet is worth enough to buy a Tesla or
to be mined eventually is said to be lim- outlined above. However, to say that a tank of gas. Complicating the issue is
ited to 21 million. However, most users Bitcoin as an investment is volatile is an the fact that the value can vary on dif-
acquire bitcoins either by buying them understatement. Its value has fluctuated ferent Bitcoin exchanges.
with physical currencies such as dollars wildly as speculation and confidence in Worse than not knowing how much
or accepting them as payment for goods it have ebbed and surged. At the begin- your bitcoins will buy is not knowing
and services. ning of 2017, one bitcoin was worth whether they’re available to buy any-
Advocates argue that the advantages about $1,000, and in March 2021 the thing at all. Cryptocurrency has been
of the system are: (1) it’s not controlled price topped $60,000 for the first time. subject to cyberattacks that have halted
by any government’s central bank, (2) In between, Bitcoin investors have been trading briefly on several exchanges.
And at one point, one of the largest Virtual currency still faces a lot of board of directors. Members of IIAR
exchanges abruptly declared bank- challenges. If you’re considering explor- may use the services of Stifel for per-
ruptcy and announced that nearly half ing Bitcoin, either for transactions or sonal and business investments and take
a billion dollars worth of bitcoins held as a speculative investment, you should advantage of the reduced rate structure
there had vanished (though a portion of become far more familiar with it than offered with IIAR membership. For addi-
that amount was subsequently said to simply relying on this discussion. And tional wealth planning assistance, contact
have been located). In addition, law- because of the issues outlined above, your Stifel representative: Jeff Howard or
enforcement scrutiny of digital transac- you should be prepared for dramatic Jim Lenaghan at (251) 340-5044.
tions to combat money laundering could price swings and only use money that
interfere with the ability of Bitcoin hold- Stifel does not provide legal or tax
you aren’t relying on for something else.
ers to spend or exchange their funds. advice. You should consult with your
1-2) Yahoo! Finance, March 17, 2021
If the assets of a digital platform or legal and tax advisors regarding your
exchange are seized, as they were with 3. The Wall Street Journal, February 19, 2021 particular situation.
Silk Road, access to digital wallets could 4. The Wall Street Journal, February 2, 2018
be restricted. These materials are provided for general
5. The Wall Street Journal, January 11, 2018
information and educational purposes
THE WILD WEST RIDES AGAIN based upon publicly available informa-
IMPORTANT DISCLOSURES tion from sources believed to be reliable
So far, regulatory oversight of Bitcoin
has been spotty. The currency is not The IIAR and ARF reserve investment — we cannot assure the accuracy or
backed by either a government or any funds are currently managed by Stifel completeness of these materials. The in-
physical asset such as gold. Major Financial Services under the investment formation in these materials may change
exchanges are located around the world, policy established by their respective at any time and without notice.
and the decentralized nature of the
system makes it more challenging for
government regulators to get a handle
on it. Unlike accounts at FDIC-insured
banks, there is no protection for pos-
sible loss from a digital wallet. More-
over, a fraudster could pose as a Bitcoin
exchange, intermediary, or trader in an
effort to lure victims to send money,
which is then stolen.
The Internal Revenue Service has
said it will treat Bitcoin holdings as
property rather than as a currency for
tax purposes. That means the sale or
exchange of bitcoins that have gained
in value since they were acquired could
potentially trigger a tax liability. Also,
payments made in bitcoins are subject
to the same information reporting re-
quirements as any other payments made
in property. And wages paid in bitcoins
must be reported on a W-2 form and are
taxable as income, like any other wages.
Speculation hasn’t been limited to the
currency itself. Much as the Internet
did in its early days, Bitcoin also has
spawned an entire ecosystem of startup
companies and venture capitalists that
want to be part of building out the tech-
nology and infrastructure involved in
creating and transferring it. In addition
to multiple exchanges, companies have
begun providing data on the virtual
currency’s price and status and creating
Bitcoin-based products. As with early
Internet companies, such ventures are
likely to involve a high degree of uncer-
tainty and risk.
Ready? Really Ready?
K E M R U S S E L L , P. E
H LESSON
aving a well-thought- regular training with their emergency
out and functional teams, employees, and local responders
emergency plan can and these facilities are likely in good
be challenging. I have condition to deal with an ammonia
seen some very good
emergency plans, but
emergency. One advantage to having a
well-developed and functioning ERP is LEARNED?
I have also noticed that several plans are that you can be part of the solution in
not as complete as they could be. This offensively dealing with an emergency.
seems to be a tough lesson to learn, and You also should have more input and
you may have experienced this. Let me possibly control into what happens in
start with an example of a conversa- dealing with an emergency. However,
tion similar to what I have heard many many ammonia facilities don’t have the
times, and then give some consider- people to properly support a response
ations for improving an emergency plan. team and those facilities have an “Emer-
gency Action Plan” (EAP) to protect
“Hey, boss can I talk with you a minute?” people as they coordinate with local to respond to ammonia releases. So how
responders in dealing with an ammonia might a facility develop its emergency
“Sure, I have some time. Come on in.” emergency. plan to address who will respond?
All facilities are to have in place an Some possible approaches come to mind:
“Boss, I have been working on updat- EAP that properly addresses the ele-
• An ERP could be developed. This
ing our emergency plan for each of our ment stated in OSHA 29 CFR 1910.38
depends on the staff at a facility, but
plants and have some questions.” (these elements would also be included
possibly sufficient employees could
in an ERP). In reading this regulation be trained to function as a hazard
“OK. Questions like what?” notice it does not address offensively response team. This may require ad-
responding to an emergency but rather ditional costs to purchase appropriate
“Well, our emergency plan is written as “procedures for reporting a fire or other personal protective equipment (PPE)
an ‘Action Plan’, not a response plan emergency.” Many facilities rely on and to provide the necessary training.
since we don’t have enough people their local responders to do the offen- With your own team in place, you
trained to have a response team. So, we sive actions for any type of emergency. would still coordinate with your local
rely on the local responders which is the EPA has stated that they do not intend responder(s) and between you and
Fire Department near each of our plants. to force a facility to develop emergency them have a much better chance of
But as far as I know none of the Fire De- response capabilities, so facilities rely successfully dealing with an ammonia
partments that will respond to help have on being included in their community emergency. For facilities that have
hazmat capability. Is that right?” emergency plan prepared under EPCRA processes that contain 10,000 lbs. or
(Emergency Planning and Commu- more of ammonia the updated Risk
“Hmmm, well I’m not sure about that nity Right-to-Know Act) regarding a Management Plan rule states that
but we are included in the community response to a potential release, and on facilities will coordinate with local
emergency plan.” their local responders being able to deal emergency response officials required
with whatever the emergency is. by § 68.93, the owner or operator
“Oh good. I was going to check that In addition, The General Duty Clause shall consult with these officials to
out, but I was wondering if we should (GDC) of §112(r)(1) establishes that establish an appropriate frequency for
consider providing the local responders owners and operators of stationary tabletop exercises, and shall conduct a
with what they might need to be able to sources producing, processing, and tabletop exercise before December 21,
respond to an ammonia release?” storing extremely hazardous substances 2026, and at a minimum of at least
have a general duty to identify hazards once every three years thereafter.”
“That has been considered but it would associated with an accidental release, Field exercises should also be done
be too costly, so we are good by being in- design and maintain a safe facility, and and the updated rule states “coordina-
cluded in the community emergency plan.” minimize consequences of any acciden- tion with local emergency response of-
tal releases that occur. Ammonia is clas- ficials required by § 68.93, the owner
In the above discussion of an emergency sified by EPA as an extremely hazardous or operator shall consult with these
action plan are the plants/facilities pre- substance, and as stated in the GDC officials to establish an appropriate
pared for an ammonia incident? the owner or operator is responsible to frequency for field exercises.”
I think improvements can be made. minimize the consequences of any acci-
dentally released chemical. Can your fa- • Coordinate with the local responders
Fortunately, most ammonia systems cility depend on local responders being and see what they need to be prepared
are well designed, well built, and well able to appropriately handle an ammo- to deal with an ammonia emergency.
maintained so emergency situations nia emergency? In many locations, the Again, for facilities that have process-
rarely happen. Many facilities with an local responding organizations do not es that have 10,000 lbs. or more of
“Emergency Response Plan” (ERP) do have the staff, training, nor equipment ammonia the updated Risk Manage-
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LESSON learned
ment Plan rule states “The owner or ammonia emergency. This could be group or organization to arrive on-site
operator performs the annual emer- done by providing them with ammo- would be an important consideration.
gency response coordination activities nia-specific hazmat training so they
required under § 68.93.” This annual better understand what might be done • Review your ammonia system(s) look-
coordination must have occurred by to deal with an ammonia release safely ing for what might be done to mitigate
December 19, 2024.” During this and possibly offensively. The purchase a possible ammonia release quicker.
coordination, it should be determined of additional PPE may not be required This could be accomplished by develop-
how an ammonia emergency will be since local responders i.e., Fire Depart- ing or reviewing procedures to isolate
dealt with. It may be discovered that ments likely already have much of equipment or sections of a system (it
something needs to be done before the what would be needed, but if not, that might be found that installing system
local responders are ready. This coor- could be worked out. The training that isolation valve at some locations would
dination with local responders should the local responders may need might be helpful); how to pump down equip-
also be done for smaller facilities that best be done with both the facility and ment or sections of a system; how to
have less ammonia as part of fulfilling local responders together. Both groups properly shut down equipment or sec-
the intent of the General Duty Clause. participating in this training will help tions of a system, etc. These procedures
coordinate efforts and plans, plus meet should also be supported by ongoing
• If you have an EAP and your local annual required coordination for Risk review and training with all appropriate
responders cannot handle an ammonia Management Program facilities. personnel and possibly other employees
emergency, then during your coordina- could be trained to assist.
tion efforts determine if a neighboring • Are there other groups or organiza-
group has hazmat capability. Through tions that could respond to an ammo- Because you have ammonia and are
a mutual aid agreement possibly that nia emergency? This might be a local responsible for it, is your facility really
group could respond. How far away ammonia refrigeration contractor who prepared for an ammonia emergency,
that group is, will be an important has employees trained as “Hazardous which includes knowing what local
consideration. If, for example, it would Material Technicians,” or an all-hazards responders can and can’t do? Meet with
take them three hours or more to get materials contractor. Most states have your local responders to coordinate and
to your facility, that probably is not emergency response groups or organiza- discuss your emergency plan consider-
going to be much help. tions that may be able to assist, or at ing what will be done to protect your
least help determine what may be best people, the surrounding public, and the
• The local responding organization may to consider in responding to an emer- environment. Don’t leave gray areas in
need help to be able to respond to an gency. Again, the length of time for a your plan. That’s the lesson to learn.
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IIAR Participates in Coalition Amicus Brief to the
Court Regarding Release Investigations
E R I C S M I T H , P. E . , V I C E P R E S I D E N T A N D T E C H N I C A L D I R E C T O R , I I A R
L O W E L L R A N D E L , D I R E C T O R O F G O V E R N M E N T A F FA I R S , I I A R
T
he Occupational Safety action plan was inadequate. OSHA plans for a particular facility? Another
and Health Administra- did not appeal that part of the deci- issue relates to whether an employee
tion (“OSHA”) is appeal- sion. Only Item 2 of that citation was can be said to be in the “immediate
ing to the U.S. Court of further reviewed. It alleges a violation release area” if they are not there to
Appeals for the Eleventh of 29 C.F.R. § 1910.120(q)(3)(iv) and witness a release. Another major issue is
Circuit a recent decision proposes a $9,054 penalty because whether the release was “uncontrolled”
by the Occupational Safety and Health TECO employees who responded to the at all, as the ammonia was released by
Review Commission (“OSHRC”), and ammonia release did not wear positive control equipment in accordance with
an administrative law judge that favored pressure self-contained breathing appa- its designs. All these issues tie back to
the Tampa Electric Company (“TECO”). ratuses (SCBA). The judge also vacated the language of the standard that defines
The case surrounds actions that TECO this item, and OSHA sought Commis- and permits certain response actions to
performed when responding to a release sion review. The majority of the com- be performed if criteria are met.
of ammonia that occurred at a power mission agreed with vacating this item It is IIAR’s opinion that the outcome
of this case before the Court is poten-
tially crucial to the food industry and
many other industries that use ammonia
The case surrounds actions that TECO performed in their processes. Should OSHA pre-
vail, IIAR fears that nearly any release
when responding to a release of ammonia that would be considered uncontrolled, and

not incidental. This could be a severe
detriment to the food industry and
occurred at a power generating facility. TECO others that use ammonia. IIAR also
believes that requiring the use of SCBAs
uses ammonia to reduce nitrous oxide emissions and level A suiting could have the op-
posite effect on safety in many circum-
that are a byproduct of power generation. stances. First responders and hazmat
teams regularly train with and use
protective equipment, compared to the
relatively rare major accidental releases
of ammonia in a facility where such
generating facility. TECO uses ammonia on the ground that the response was not
an “emergency response,” based on the equipment is not regularly used by the
to reduce nitrous oxide emissions that
are a byproduct of power generation. language of the definition of “emer- well-practiced. Many end-users are not
The technicians responding to the release gency response.” positioned to employ, train, and outfit
used their training to ascertain the extent OSHA’s appeal brief to the Eleventh a HAZWOPER response team. As our
of the release, assess the problem, and Circuit repeats its original arguments industry has observed, these consider-
stop the release. In doing so, they did not that because TECO did not know ex- ations may cause employers to adopt
wear respiratory protection and were not actly how much ammonia had escaped, minimal emergency action plans where
injured when performing these functions. and others at the site had symptoms they simply do not address releases but
TECO was issued a two-item serious of ammonia exposure, TECO should instead call emergency services, delaying
citation alleging violations of the Haz- have assumed that the release was response, potentially delaying assistance
ardous Waste Operations and Emergency uncontrolled and that their employees to victims of exposure, and perhaps
Response (“HAZWOPER”) standard, could have been exposed to a hazard- allowing a minor incident that is eas-
29 C.F.R. § 1910.120. These citations ous situation which in OSHA’s opinion ily controlled to become a major one.
were challenged through the OSHRC. constitutes the basis for an “emergency IIAR believes that the use of industry-
The legal and even the technical response.” There are several impor- developed procedures, training, and PPE
arguments of the case are beyond the tant issues at hand. First is the limit can be used to address most releases
scope of this summary. However, the of OSHA’s authority in enforcing an successfully and safely.
following generally describes the initial OSHA performance standard, versus a IIAR has joined with other similarly
decisions of the case. prescriptive standard. Stated a bit differ- concerned trade associations to express
The first item was vacated by the ently: How much room for interpreta- concerns with OSHA’s interpretation of
judge because OSHA did not prove that tion and discernment is an employer the rule. The court will be considering
TECO’s performance-based emergency permitted to use when deciding the best the case in the coming months.
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03 Condenser NOV21

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