GCAP has posted their 10th podcast. This episode they call the National Response Center on a training call.
They’ve edited the call to speed it up, but if you haven’t had to call the NRC before I think you’ll be surprised how long the call takes. Their call lasted 17 minutes, about the same time as the one I had to make for a release last year.
A call to NRC is NOT something you want your Incident Commander to handle!
I’m continually amazed how often I come across underperforming organizations that don’t try to improve because they feel the caliber of their employees is inadequate to achieve higher performance. It may well be true that your team is suboptimal in its makeup but that’s no excuse for failing to optimize the team you have. Donald Rumsfield once said “You go to war with the army you have, not the army you might want or wish to have at a later time.” In this case what’s true in War is true in business: Unless you are the sole proprietor with an unlimited bankroll, you have to accomplish the tasks in front of you with the team you have.
In many cases it’s unfair to label the employees as under-performers because they haven’t actually been given the opportunity to perform. A workplace without a formal system of standardized work is chaos and what emerges from that chaos is leadership by fiat: the loudest and brashest control the process. What I am trying to get across here is that if you don’t set the standard, the loudest and brashest of your employees will set the standard themselves. The standard that they set will be created based on their motivations, not yours! What are their motivations? Minimizing their workload? Transferring responsibility to others? Whatever they are, you can rest assured that unless your employees are of impeccable character, they aren’t going to be the same standards that the business manager or owner would set. Further complicating matters, without a formal standard, each individual employee is going to set their own individual standard. What you’ll have is system of work made of multiple competing standards.
“I do not believe that the solution to our problem is simply to elect the right people. The important thing is to establish a political climate of opinion which will make it politically profitable for the wrong people to do the right thing. Unless it is politically profitable for the wrong people to do the right thing, the right people will not do the right thing either, or if they try, they will shortly be out of office.” –Milton Friedman
While Mr. Friedman is talking about politicians, the same concept is very true about motivating employees to “do the right thing.” With apologies to Milton, let me rewrite that for our purposes:
“The solution to our problem is not simply hiring the right people. The important thing is to establish a work culture which will make it profitable for the wrong people to do the right thing. Unless it is profitable for the wrong people to do the right thing, the right people will not do the right thing either, or if they try, they will shortly be out of a job.”
Deming, the founder of modern process improvement always said that “A bad system will defeat a good person every time” and he’s absolutely right. Without a formal standard your best employees will be driven to lower performance so they don’t “make waves” or alienate their coworkers. Any workplace is a mix of employees of various performance levels. The purpose of standardization is to optimize the performance of the employees you do have. Let’s look at this quick chart:
Since it is unlikely you will be able to significantly change the composition of your team, all we can do is move the distribution along the Employee Performance axis. Standardization moves that distribution to the right, a lack of standardization moves them to the left.
The solution is simple: Standardize the work to improve the performance. Then enforce the standard and involve the employees in continuous improvement to lock in and improve that performance.
Over the past few years I have had the opportunity to work with quite a few Ammonia Operators. Recently I chose to oversee the training of a new operator who had no previous refrigeration experience. In preperation I talked with various members of the maintenance staff and management to see what they wanted to see from this new Operator. This led to many conversations about the varying quality of Operators in the industry. I have the privilege of working alongside a bright young aeronautical engineer who has decided to work in Ammonia Refrigeration. We have some really interesting conversations and I often wish I had recorded them for this site. What follows is a synopsis of my opinion after a fairly long discussion we recently had.
There are three types of Operators in our industry: The ill-suited, the good and the great.
The Ill-Suited: Our field is a challenging one, and those without the proper attitude and skills are usually quickly weeded out*. Still, the ill-suited are not necessarily bad people – they just lack the proper mind-set to work in a technical field like ammonia refrigeration. I’m sure we all have some stories to tell about our dealings with these operators because they usually scare the hell out of you! A lack of knowledge is to be understood when you start out in any field, but these operators tend to be ignorant of their ignorance. They don’t follow SOPs because they know better. They don’t follow safety rules, because they feel those rules shouldn’t apply to them. These are the guys who jack up the rear suspensions on their cars to “improve gas milage – it’s like going downhill!” and think that pilot valves in an ammonia refrigeration system serve the same purpose as a pilot in a stove.** They always have an answer to every problem and that answer is usually wrong! Usually these operators can be identified by the boxes of “may be good” spare parts. They replaced a half dozen parts to rectify a problem and they aren’t sure which one was broken so they put them all back on the shelf. These operators take ownership of nothing! Everything that went wrong wasn’t their fault and anything in disrepair wasn’t their responsibility. They can cost you dozens of times their annual salary and will likely get you on the national news as ammonia spews out your building.
The combination of unwarranted confidence and rampant incompetence should lead them into a field more suitable to their talents and temperament such as government administration. Somewhere a Department of Motor Vehicles is missing their “Employee of the Month”! The sooner we move them out of our engine and control rooms the better off we all are.
The Good: The good operators comprise the bulk of the field. They are diligent in their rounds and conservative in their approach to solving problems. Their understanding of refrigeration is good enough to solve 99% of everyday problems and they are not afraid of asking for help when they get in above their heads. It may be difficult to convince them to try new things (floating head pressures, motor operated valves, electrically operated expansion valves, etc.) but that’s because they don’t see the point in changing “what already works” for something more complicated. If you are willing to work with them they are almost always willing to work with you. It’s not too difficult to get these guys to attend a training, but you had better keep it interesting and pertinent or you will lose them quick. These operators take ownership of the equipment and it’s not rare to see them applying a new coat of paint to a compressor every year. These operators can usually be identified by their grey beards***, well worn uniforms and confident, easygoing attitudes. They are worth every penny you pay them and probably a good deal more. They are the backbone of the industry and we should all be happy to have them.
The Great: The great operators are good operators with an engineer’s soul. They could have easily become actual engineers if they had the inclination to go to college. They don’t just want things to work; they want to know WHY things work. Once they understand that, they want to know if it could work a little bit better. These operators can usually be identified by their stacks of obscure refrigeration papers, magazines and cut sheets. These are the operators you see at RETA meetings and trade shows. It’s hard to keep these guys away from trainings and they’ll attend nearly anything you’ll let them go to. They are worth a lot more than they are being paid but they aren’t there for the money – they are there for the thrill they get when they solve a difficult problem, start up a brand new piece of equipment, or save multiples of their annual salary in electrical costs by optimizing system operation. These operators take ownership of the entire system’s operation. If you are lucky enough to have one of these operators, you had better keep them challenged and rewarded or they will wander off to seek new challenges and rewards.
That’s one man’s opinion – I’d love to hear yours!
* Occasionally you will encounter one of these operators who’ve made a career out of “fixing” the system a half dozen times a week. They are viewed as “heroes” by their ill-informed plant managers because they are always getting “this junk system running again”. In my experience, it’s rarely the “junk system” that is at fault.
** I am NOT making this up. Both of these were told to me by people someone actually trusted to operate an ammonia system.
*** I wish I was kidding. There is an astounding lack of youth in our field, but we’ll leave that conversation for another day.
Update 12/22/10: Check out this post for some follow-up on how to assess your operators and perhaps turn those good operators into the great ones!
South Carolina regulators have fined a Pennsylvania company $91,000 for a string of emergency preparedness failures they say occurred before a fatal chemical leak near its Swansea plant last year.
The Department of Health and Environmental Control says the wrong type of hose was used at Tanner Industries Inc. to transfer ammonia at the company’s plant. On July 15, 2009, a hose linking the Tanner facility to a transfer truck failed and spilled nearly 7,000 pounds of poisonous ammonia gas into the skies along U.S. 321, according to agency records.
Last year’s leak killed Jacqueline Ginyard, a 38-year-old motorist whose car was enveloped in a toxic cloud as she drove to work at about 8 a.m.
It appears it was as simple as using the wrong hose for the job. Tragic and avoidable.
Make sure your charging SOP defines who has the responsibility to ensure the proper hose is used and that it is inspected before use. You should also have an annual (or more frequent if you use them a lot ) work order to check all ammonia hoses for needed replacement.
This video has been around for quite some time. Whenever I’ve been shown it I’ve been told it’s real. Some internet research leads me to believe it may not be.
Still – it’s a good idea to show this to your ammonia technicians. Once they see it, they’ll be talking about it for years to come.
Certainly your ammonia technician will pick up any minor leaks during a regularly scheduled walk-through of the facility. But what if that leak starts at 6pm Friday evening and everyone is gone for the weekend? You had better have some sort of ammonia detection according to the latest EPA fine.
Boston, Oct. 5, 2010) – Tanner Industries, an East Providence, R.I., company that distributes ammonia, faces a $149,080 penalty for violating federal regulations meant to prevent chemical accidents, according to a recent complaint by EPA.
The facility is not routinely staffed except when ammonia is transported into or out of the facility. Tanner’s primary emergency plan is to rely on local emergency responders to respond to any ammonia releases, although the facility has no automatic ammonia sensors to alert emergency responders of potential releases. The facility is about a tenth of a mile from a residential neighborhood, and even closer to other public businesses.
According to the complaint filed by EPA, Tanner failed to do the required analyses or take precautions to address the fact that its facility is not routinely staffed except when ammonia is being actually received or distributed. For instance, Tanner failed to consider the use of sensors or monitors to detect leaks of ammonia or conditions that might lead to leaks. Tanner’s emergency response program also did not include adequate communication and coordination with local emergency response agencies, and the company’s plan did not ensure that the public would receive adequate notice of an accidental release.
Ideally you have ammonia detection that initiates the following actions:
The best thing you can do to minimize false alarms (and you will get them) is to initiate an incident investigation every time the alarm goes off. These incident investigations can act as a driver to make the system improvements that minimize these false alarms.
p.s. I note that SAFTENG.net suggests “an AUTOMATED system that uses detectors at LOW LEVEL SET POINTS to shut the system down!” Most ammonia alarm systems have low and high alarm settings. The low setpoints are usually set to a threshold that protects the employees (somewhere around 35ppm and the PEL is fine) but the high level should be set near the high range of the sensor (100-200ppm usually) so you know that you’ll need a higher level of PPE to enter the affected area. I would NOT suggest shutting down the system at the LOW level alarm as it would cause unnecessary system interruption as well as excessive wear on the system. Some facilities have a high-range sensor in the compressor room that initiates a system shutdown at 1,000ppm which is also a great idea.
“Gemba” is a Japanese term for “where the real work is done.” In manufacturing, one of the best things your Kaizen or Process Improvement team can do is spend some time on the shop floor. There you see the problems of the workplace as they actually are – how the process is conducted and the various obstacles that are overcome by employees in the process.
Why is this relevant to you as a PSM coordinator? Because unless you are also the only ammonia technician on staff, you can’t be absolutely certain how the work is actually being done. Furthermore, if you don’t have an ammonia refrigeration background then you are in for a nearly insurmountable challenge validating SOPs.
So, let’s say you aren’t a qualified ammonia technician and you are in charge of implementing a PSM program. How should you prepare for that role? Here’s my suggestion: Go Gemba! By that I mean: Get some practical hands-on experience.
I’ve attended GCAP Ammonia Operator I & II and think they are excellent. When I attended them I had already studied just about every bit of technical writing I could get my hands on so much of the curriculum was a re-hash. The real value for me was learning how the aspiring ammonia technician thought and watching Randy Williams communicate difficult abstract concepts through everyday language and clever metaphors.
As an ammonia PSM coordinator, attending of the GCAP classes is an investment in your ability to effectively communicate with your ammonia technicians.
You can get more information on the programs they offer at http://www.ammoniatraining.com/. Also, check out their podcasts at http://www.gcapcoolcast.com/
* Note: You could technically skip step 1 & 2 because you’ll get both at a GCAP class. I’ve attended classes with a “new guy” with no experience before and they almost always “felt overwhelmed”. I think you can avoid that entirely if you have SOME practical knowledge – even if it’s a week’s worth.
“OSHA’s scrutiny of the refinery industry and of chemical facilities covered by the Process Safety Management standard will increase, Jordan Barab, deputy assistant secretary of OSHA said in an Oct. 27 speech at the 2010 Mary Kay O’Connor Process Safety Center International Symposium in College Station, Texas, which ended Thursday…
…OSHA already had announced its plan to continue the Chemical NEP until it can be expanded nationwide.”
Here’s a simple spreadsheet I made up a while ago to calculate the possible savings using Variable Frequency Drives.
Download VFD Fan Savings Calculator
One thing you can usually count on when you see a news article about an ammonia release is that the reporter is unfamiliar with ammonia refrigeration. That’s not surprising – they can’t be expected to know everything! This article is an attempt to provide some basic information to reporters so they can write a more cogent article. I’ll update this as I find some more common misconceptions.
What is it?
Ammonia is naturally produced by the anaerobic decay of organic material. First isolated by Joseph Priestley in 1774, it is the combination of one Nitrogen atom and three Hydrogen atoms. It is a colorless gas that is about half the weight of air. It has a boiling point of -28f and about 150 million tons a year are produced commercially from natural gas.
Most people are familiar with the smell of ammonia from its use as a household cleaner which contains 5% ammonia and 95% water.
Why is it used?
About 85% of the ammonia produced in the world is used as a fertilizer. Most commercial dairies, meat packing plants and distribution centers however use it as a refrigerant. Ammonia is an extremely efficient refrigerant that is relatively inexpensive. It is the most environmentally friendly refrigerant in widespread use because it has zero global-warming potential and no effect on the ozone layer.
Where is it located in a facility?
The bulk of the ammonia in a refrigerated facility is usually in the Compressor Room. Ammonia liquid is piped to various heat exchangers throughout a facility to provide cooling in those areas. Some facilities use a secondary loop of glycol or another refrigerant. In those facilities the glycol or other refrigerant is piped to the heat exchangers and the ammonia stays in the Compressor Room and on the roof near the compressor room in the Condensers.
What can happen if I am exposed to it?
Ammonia has a strong irritating pungent odor that most people can detect at 5ppm (parts per million of air). The Occupational Safety and Health Administration (OSHA) has set an acceptable eight-hour exposure limit at 25ppm and the IDLH (Immediately Dangerous to Life and Health – the level to which a healthy worker can be exposed for 30 minutes without suffering irreversible health effects) for ammonia at 300ppm. In my experience, people will voluntarily leave the area at concentrations well below 50ppm. Most facilities have ammonia detectors that detect leaks and notify the system operators that there is a problem. Ammonia is not a carcinogen. Prolonged exposure to minor amounts does not result in bioaccumulation in people and can not cause any known adverse health effects.
High concentrations of Ammonia Gas or Ammonia Liquid are extremely dangerous. Ammonia is highly corrosive to skin and can cause irreversible damage to eyes. It is Anhydrous, meaning “without water” and will merge with moisture to form ammonium hydroxide, a caustic. This caustic will form on moist areas of the body causing chemical burns. Liquid ammonia at ambient air pressure will be 28 degrees below zero and can freeze exposed flesh on contact.
If exposed to liquid or high concentrations of vaporous ammonia, flush the area with copious amounts of water for at least 15 minutes and seek medical attention.
What are the environmental effects of a release?
Ammonia is extremely toxic to fish and amphibians since they cannot metabolize ammonia – this is one of the reasons aquariums have charcoal filters, to remove the ammonia that normally occurs from decay of organic material. Water with extreme amounts of ammonia in it can also harm the bacteria in sewage plants, although this is fairly uncommon. Vapor clouds of ammonia will harm vegetation from caustic burns. This is the same thing that can happen if you put fertilizer full strength on your garden.
Ammonia is not very stable when released in the environment and will usually decay into atmospheric nitrogen and water within a few days. Usually it will not last those few days as it is rapidly taken up by plants and bacteria. Ammonia does not build up in the food chain because it serves as a nutrient for plants and bacteria.
What are all these “valve failures” about?
If a news article mentions a reason for a release, it’s almost always called a “valve failure” or “valve malfunction”. Ammonia systems are equipped with pressure relief valves that operate if the pressure of the system exceeds the rated pressure of the equipment. This is required by law and the reason is fairly obvious: if you must release dangerous pressure in the system you would rather do it in a controlled manner rather than in some big explosion as a vessel catastrophically fails! Once this pressure is released the pressure relief valve should re-seat. Occasionally these relief valves can stick in the open position and dump the entire system charge. In a properly running ammonia refrigeration system these valves should NOT operate – sadly, many times incorrect system operation causes these valves to open and the operator reports it as a “valve malfunction” when the system was running outside of its design and the valve was actually operating correctly.
Actual “valve failures” are rare although they do occur – it’s an imperfect world.
Isn’t ammonia explosive!?
Ammonia can indeed burn in the range of 15-28% (150,000-280,000PPM) concentration in air. This is a VERY rare occurrence and would usually only happen when something has gone terribly wrong in the Compressor Room. The temperature of an ammonia flame is very close to the temperature required to ignite the mixture so there has to be a catalyst of some sort. In a Compressor Room this would usually be the compressor oil separator catastrophically failing and releasing a fine mist of oil into the air. For comparison, Gasoline can burn in much lower concentrations: 1.4-7.6% (14,000-76,000PPM)
