1. Dailies, Weeklies, Monthlies, PSM Maintenance - Simplify IT If you’d like to reach SCS Engineers, Tracer Environmental Division please contact us at: Service@scsengineers.com Service@scsengineers.com

2. Where do we start? Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) Webster’s Dictionary Mechanical: (a)(1) of or relating to machinery or tools (2) produced or operated by a machine or tool (b) of or relating to manual. Integrity: (1) firm adherence to a code of especially moral or artistic values (incorruptibility) (2) an unimpaired condition (soundness) (3) the quality or state of being complete or undivided (completeness)adherenceincorruptibilitysoundnesscompleteness

3. Where do we start? Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) OSHA Process Safety Management Program EPA Risk Management Program EPA /OSHA General Duty Clause – IIAR Bulletin 110

4. Where do we start? Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) Maintenance Procedures for: Pressure vessels and storage tanks; Piping systems; Relief and vent systems; Emergency shutdown systems; Controls; and Pumps. Ensure all “affected” employees are trained on maintenance procedures.

5. Where do we start? Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) Ensure maintenance, testing, and inspections are performed regularly and are documented. Ensure that all procedures are updated as new equipment is installed. Basis for schedules, tests, inspections: Industry Standards Manufacturer’s Recommendations Facility History

6. Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) Steps to Avoid Deviations (PSI and SOPs) Prepare SOP for Daily Walk / Log System Discharge Pressure System Suction Pressure(s) Visual Walk of Engine Room Unusual Vibrations Normal Sounds Leak Detection Ventilation System Oil / Water Leaks Doors / Security Levels in Vessels Computer Alarms Purge Counts Dump System Counts Evaporators / Roof Equipment (minimum weekly)

7. Where do we start? Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) RECENT CITATIONS – Not following manufacturer’s maintenance schedule for ammonia sensors. EXAMPLE: Manning EC-F9-NH3 Manual states: “Calibration should be performed with certified calibration gas every six months or after major exposure to a leak.” “Response test once between calibrations - expose sensor to ammonia / water solution to verify proper sensor response and alarm functions.” “All tests and calibrations must be logged.” “Typical sensor life in a refrigerated area will be three to four years.” “In addition to timely response checks, a preventative maintenance program of periodic cell replacement should be implemented.”

8. Where do we start? Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) Preparing your program Manufacturer Specification Sheets / O&M Manuals IIAR Bulletin 110 Facility History IIAR Bulletin 110 – 5 Year Independent Mechanical Inspection Understand the ammonia systems AND regulatory criteria. True picture of the condition of your system without undo influence. Prioritize recommendations – solutions. Utilization of staff – employee participation.

12. Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j) Notebook Maintenance Database Online / Handheld system

13. Mechanical Integrity 40 CFR 68.73 & OSHA 1910.119(j)