SAFE UPPER & LOWER LIMITS

Understanding &
documenting

Todd Jekel, Ph.D., P.E.

Assistant Director
Industrial Refrigeration Consortium
Overview

■ Where does the requirement to document limits reside in PSM/RMP?

■ What are operating limits? Are they the same a design limits?
■ How to determine operating limits
■ Can operating limits change? If so, how to manage
■ Hard stops & who should know
What is the purpose of establishing
safe upper and lower limits?
■ Limits identify thresholds that, if exceeded, result in some undesirable
outcome
– Increased operational risk
– Decreased equipment life
– …
■ Forces facilities to identify the limits and assess consequences of deviating
outside of the limits
■ Forces facilities to consider how best to get process back into safe range
■ Keep in mind that exceeding established limits often does not result in an
immediate catastrophic outcome; however, sustained operation outside of
established limits may become catastrophic
What needs operating limits?

Operating limits
(d)(2)

Operating Process Hazard Mechanical Process Safety

procedures Analysis Integrity Information
(f)(1)(ii), (f)(1)(iv) (e)(1) (j)(5) (d)(3)
Interaction of Elements
Operating
Limits

PHA/
Safeties/
Alarms

PSI/Design
Limits
 Process safety information

■ 1910.119(d) Process Safety Information

– (2) Information pertaining to the technology of the process
■ (i) Information concerning the technology of the process shall include at
least the following:
– (A) Block flow diagram
– (B) Process chemistry
– (C) Maximum intended inventory
– (D) Safe upper and lower limits for such items as temperatures,
pressures, flows or compositions
– (E) An evaluation of the consequences of deviations…
 Process safety information, cont.

■ 1910.119(d) Process Safety Information

– (3) Information pertaining to the equipment in the process.
■ (i) Information pertaining to the equipment in the process shall include:
– (A) Materials of construction
– (B) Piping and instrument diagrams (P&ID's)
– (C) Electrical classification
.
.
.
– (H) Safety systems (e.g. interlocks, detection or suppression systems)
 Process Hazard Analysis

■ 1910.119(e) Process Hazard Analysis

■ 1910.119(e)(3)(iii)
– Engineering and administrative controls applicable to the
hazards and their interrelationships such as appropriate
application of detection methodologies to provide early
warning of releases.
 Operating Procedures
■ 1910.119(f)(1)
– The employer shall develop and implement written operating
procedures that provide clear instructions for safely conducting
activities involved in each covered process consistent with the
process safety information and shall address at least the following
elements.
■ (i) Steps for each operating phase
■ (ii) Operating limits
– (A) Consequences of deviation; and
– (B) Steps required to correct or avoid deviation.
 Mechanical Integrity

■ 1910.119(j)(5) Equipment deficiencies

The employer shall correct deficiencies in equipment that are
outside acceptable limits (defined by the process safety information
in paragraph (d) of this section) before further use or in a safe and
timely manner when necessary means are taken to assure safe
operation.
 What limits should be included?

■ Temperatures & pressures are pretty common

– Maximum Allowable Working Pressure (MAWP)
– Minimum Design Metal Temperature (MDMT)
■ Flow (mass flow or velocity)
– Harder to pin down. Where in the system?
– Given that refrigeration is simply phase change, this is less
important at the PSI level; however, IIAR Piping Handbook is a
resource for design limits
– Component flow limits (i.e. capacity)
What limits should be included?
■ Compositions
– Ammonia: water concentration
– Secondary fluids (freezing point depression, condenser water
treatment)
– Compressor oil (water in oil)
■ Liquid Level
– High
– Low
■ Physical limits
– Minimum thicknesses
Determination of Operating Limits

■ Practical constraints
– Within design limits
– Within limits that would trigger engineered safeties & interlocks
– Within limits that trigger alarms
■ Consideration of operating limits
– Examples:
■ Conditions that exceed motor power
■ Conditions that exceed maximum oil separator velocity
■ Oil properties (e.g. pour point temperature)
■ Glycol or brine concentration and resultant freezing point
 Where in Operating Procedure?
■ Not part of the step-by-step procedure
■ Part of the “operations manual” portion of 1910.119(f)
– Fits with consequences of deviation & steps to correct deviation

Screw Compressor
Operating Limits Deviation Consequences Corrective Actions
• Process and space temperatures too warm 1) Start additional compressors to lower suction
• Oil carryover for operating compressors pressure
• High motor amps for operating 2) Shutdown connected loads
 26 psig High compressors
Suction • High suction pressure cutout
Pressure Normal operation None
25-26 psig Normal
• Process and space temperatures too cold 1) Check suction pressure parameters for proper
{25 – 26 PSIG} • Potential for freezing secondary settings
refrigerants 2) Manually unload one or more operating
 25 psig Low • Low suction pressure alarm compressor
• Low suction pressure cutout 3) Shutdown one or more operating
compressors
Determination of Compressor Operating
Limits
■ Information needed:
– Compressor motor size
– Oil separator diameter
– Oil separator MAWP
– Oil properties
– Relief valve set pressure
■ Resources:
– Compressor manufacturer’s
selection software
Determination of Compressor Operating
Limits, continued
■ Pressure/Temperature limits
– Suction pressure high limit
■ Load temperature limits
■ Oil separator sizing
■ Motor sizing
– Suction pressure low limit
■ System component MDMT
■ Compressor oil properties
Determination of Compressor Operating
Limits, continued
■ Pressure/Temperature limits, cont.
– Discharge pressure high limit
■ Motor sizing
■ Oil temperature limits
■ Relief valve set pressure (all downstream components)
– Discharge pressure low limit
■ System pressure limits (e.g. defrost relief regulator pressure,
high-pressure liquid delivery limits)
■ Oil separator sizing
■ Oil flow
 Determination of Evaporator Operating
Limits
■ Information needed:
– Fan motor size
– Evaporator design pressure & PRV set
pressure (if applicable)
– Defrost relief valve set pressure
– Space or process temperature requirements
– Secondary fluid or product freezing point
– Compressor oil properties (fouling)
■ Resources:
– Manufacturer’s cut sheet
 Determination of Condenser Operating
Limits
■ Information needed:
– Condenser design pressure
– Pressure relief valve set pressure
(if applicable)
– Water treatment chemical ranges
■ Resources:
– Manufacturer’s cut sheet
 Determination of Vessel Operating
Limits
■ Information needed:
– Vessel MAWP & MDMT
– Pressure relief valve set pressure
– Volume/level alarms
– Volume/level cut-outs
■ Resources:
– U1A & vessel drawing
– Pump curve
Validation steps

■ Do your cut-outs, interlocks, and alarm settings match the

information in your procedures?
■ Do the operating limits include all modes of operation?
 Can the operating limits change?
■ YES
– Could be from a physical change of equipment or other fluid change
– Could be from communication with equipment manufacturer
■ WHY?
– New process requirements require a set point change outside the
current operating limits
■ HOW?
– Document and manage the CHANGE
– Communicate it to all effected persons
 PSM (1910.119 Appendix C)

■ 11. Managing Change. To properly manage changes to process chemicals,

technology, equipment and facilities, one must define what is meant by change.
In this process safety management standard, change includes all modifications
to equipment, procedures, raw materials and processing conditions other than
"replacement in kind." These changes need to be properly managed by identifying
and reviewing them prior to implementation of the change. For example, the
operating procedures contain the operating parameters (pressure limits,
temperature ranges, flow rates, etc.) and the importance of operating within
these limits. While the operator must have the flexibility to maintain safe
operation within the established parameters, any operation outside of these
parameters requires review and approval by a written management of change
procedure.
RMP (68.3) Definitions

■ Major change means introduction of a new process, process

equipment, or regulated substance, an alteration of process
chemistry that results in any change to safe operating limits, or
other alteration that introduces a new hazard.
 Hard stops & communication
■ Hard stops are design limits
– MAWP & MDMT
– Oil pour point temperature
– Minimum thicknesses
■ Who needs to know?
– Production supervisor, Plant manager,…
■ Why do they need to know?
– Understanding the limits of how hard you can push the system
– Operation outside of the established limits increases BOTH
operational and regulatory risk
QUESTIONS & COMMENTS