shg37.doc

VALERO – KROTZ SPRINGS SHG #37 of 16

Revised 06/08/04

Management of Change Authorization Guidelineand

Pre-Startup Safety Review Guideline

1.0 PURPOSE

To manage changes, and ensure the safe startup/commissioning of changes in compliance with the Process Safety Management (PSM) program. (OSHA 29 CFR PART 1910.119)

2.0 SCOPE

The Management of Change Authorization (MOCA) guideline will be used to approve a change, and to document any change that is not "replacement in kind". This guideline covers Temporary, Permanent, and Emergency Changes. (See MOCA /PSSR form)

The Pre-Startup Safety Review (PSSR) guideline will be used to assure that all changes are completed as per the approved MOCA. (See MOCA/PSSR form)

3.0 DEFINITIONS

Change is meant to include “not in kind” changes in or additions of: chemicals, technology or equipment relating to covered processes. See Attachment I for examples of "in kind" and "not in kind" changes.

Originator – the person requesting the change Covered Process – New or existing Operating Units, Tank Farm, Docks, Loading/Unloading

Racks, Lab, Utilities, Pipelines and connecting piping Process Hazard Analysis – an evaluation which identifies, evaluates and recommends

controls of hazards in the process.

4.0 RESPONSIBILITY

ResponsibleGroup /Individual

Responsibilities

Originator Determine the need for the change. Correctly fill out Work Notification, if required. Complete Section “A” of the Management of Change Authorization

“MOCA” form as outlined in 6.1. Assure that reviews under Section "B" are completed and signed. Return the MOCA to their Department Manager to be resolved at a higher

level if any individual refuses to sign-off under Section "B" for any reason. Submit any changes to an approved MOCA as a revision to

Directors/Managers (except ¾” vents or bleeder valves which shall be noted on the P&ID)

Reviewer(s) Review the documentation attached to the MOCA for operability, design, environmental, safety and health considerations.

Complete Section “B” of the Management of Change Authorization “MOCA” form as outlined in 6.2.


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Department Directors/Managers

Upon approval of Section A, assure Section B reviewers are assigned. Assure that required documentation for the change is attached to the

MOCA Complete the Risk Level Assessment Form (Attachment 3) as appropriate

to determine if a PHA is required for change. Complete, Section “C” of the Management of Change Authorization

“MOCA” form as outlined in 6.3. Complete, if required, the MANAGERS REQUIREMENT FOR PRE-

STARTUP SAFETY REVIEW” section as outlined in 6.6. Approve revisions to MOCA. Void an approved MOCA when necessary.

Owning Area/Craft SupervisorOr designee

Review and approve the need for the change. Coordinate or initiate the work. When a PSSR is not required, verify that sections “B” through “D” of

MOCA are complete before commissioning.

Section “D” and “E” Assignees

Complete requirements of Section “D” and/or Section “E” of the Management of Change Authorization “MOCA” form as outlined in 6.4 and 6.5.

MOCA/PSSR Coordinator

Coordinate the PSSR with input from all other departments as outlined in Section 6.6 and 6.7.

PSSR Team Assure that the change reviewed during the PSSR has been performed per the approved MOCA.

Complete the Pre-Startup Safety Review as outlined in Section 6.7.

5.0 AVAILABILITY

Blank MOCA / PSSR forms are available in the Engineering Library or on the electronic Right to Know stations. Original MOCA/PSSR forms are to consist of one pink sheet of paper. The MOCA Form is printed on the front of the sheet with the PSSR printed on the reverse side.

Completed MOCA/PSSR’s and associated documentation will be available for review in the Engineering Library.

6.0 GUIDELINES

The following guidelines contain typical instructions for processing a proposed modification/addition to the refinery, and performing a pre-startup safety review. For special circumstances such as Emergency Changes, Temporary Changes or MOCAs After Business Hours refer to Section 7.0, 8.0 or 9.0 for specific instructions for each case.


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6.1. SECTION “A” – GENERAL INFORMATION

The intent of this section is to formally document the origination of the Management of Change. In completing Section A, the originator should provide a detailed description of the proposed modification, and supply sufficient documentation to obtain approval from the Area Supervisor and the Originator’s Department Director or Manager. Section A should be completed by supplying the following information:

Fill in DATE, W.O./AFE NUMBER, and ORIGINATOR (S) name. Obtain AREA SUPERVISOR APPROVAL (signature required). Obtain ORIGINATOR’S DEPT DIRECTOR/MANAGER APPROVAL (signature required). Check box(s) for EMERGENCY JOB, PERMANENT CHANGE or TEMPORARY

CHANGE. Reference Sections 7.0, 8.0, and 9.0 for specific instructions concerning, Emergency Changes or Temporary Changes.

Check a box(s) for REASON FOR CHANGE. If “PHA REC #” is checked, fill in the reference number from the PHA report. If “OTHER” is checked, state the reason.

Fill in EQUIP./INST. MODIFIED (TAG#). Identify the primary affected equipment/instruments being modified or added.

Write a full detailed description of the modification in DESCRIPTION FOR PROPOSED CHANGE (ATTACH JUSTIFICATION AS REQUIRED).

Upon completion of Section A, a change review should be performed by the assigned individuals as specified in Section B.

6.2. SECTION “B” – REQUIREMENTS FOR CHANGE REVIEW

The intent of this section is to perform a detailed review and obtain approval to ensure operational requirements, design specifications, environmental, health and safety standards are met. Section B is completed by having the following information reviewed and approved:

PROCESS SKETCH/OPERABILITY REVIEW - A review of the package to assure operational requirements are met by reviewing marked up P&ID’s, loop drawings, other sketches and/or other documentation.

BASIC DESIGN REVIEW - A review of the detailed design information to assure that equipment, piping and other components complies with recognized and generally accepted good engineering practices. This review will also assure that all required documentation is attached.

ENVIRONMENTAL REVIEW - A review of the documentation to assure compliance with applicable environmental regulations

HEALTH AND SAFETY REVIEW - A review of the documentation to assure compliance with applicable OSHA standards, NFPA Standards, Valero company standards, etc.

FACILITY SECURITY REVIEW – A review of the documentation to assure compliance with the Facility Security Plan.

Approval is documented by obtaining the required signature/initials and date from the individual specified in the department and person column. If any individual refuses to approve the change, the originator MUST return the MOCA to their Manager or Director to be resolved at a higher level.

Upon completion of Section B, the MOCA package should be submitted to the Directors/ Managers for review as specified in Section C.


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6.3. SECTION “C” – MANAGEMENT REVIEW/APPROVAL

The intent of this section is to obtain final approval from management to perform the work requested by the Management of Change. Section C is completed by having the following information reviewed and approved:

TECH. SERVICE – The department Manager or designee will review the detailed design information to assure that equipment, piping and other components have been reviewed against recognized and generally accepted good engineering practices.

OPERATIONS – The department Director or designee will review the initial package to assure operational requirements are met by reviewing marked up P&ID’s, loop drawings, other sketches and/or other documentation.

MAINTENANCE - The department Director or designee will review the detailed design information to assure that equipment, piping and other components have been reviewed against recognized and generally accepted good engineering practices.

HEALTH, SAFETY AND ENVIRONMENTAL - The department Director or designee will review the documentation against applicable environmental regulations, OSHA standards, NFPA Standards, Valero company standards, etc.

CONTROL SYSTEMS – The department Manager or designee will review the detailed design information to assure that control systems and logic have been reviewed against recognized and generally accepted good engineering practices.

Approval of the original MOCA or any revision is documented by obtaining the required signatures and date from the department Directors or designee. If any individual refuses to sign-off on the change, the MOCA package is returned to the originator to resolve any documentation issues for re-submittal.

Upon approval in Section “C”, the Director or designee is to assign responsibilities in Section “D” and “E”. Also, if a Pre-Startup Safety Review (PSSR) is necessary, the “managers requirement for pre-startup safety review” form is to be completed.

Additionally, the Department Directors or designee will complete the Risk Level Assessment Form, as appropriate, to determine if the change required that a PHA be performed.


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6.4. SECTION ”D” – REQUIREMENTS TO BE COMPLETED BEFORE CHANGE IS COMMISSIONED

The intent of this section is to assign responsibilities, and document that the specified responsibilities are performed before commissioning the change. The following are checked “yes” or “no” and assignments are made as required.

PROCESS HAZARD ANALYSIS – If the complexity of the change warrants a more in-depth review than the MOCA and PSSR can supply, a HAZOP, What-If or Checklist type Process Hazards Analysis (PHA) may be required. The PHA is considered to be complete after the PHA has been performed, and all recommendations have been addressed, and target completion dates have been assigned and approved for each recommendation.

Typically, the Department Directors or designees will make this determination during their review of the MOCA. However, the originator or person performing the basic design review may indicate that a PHA is necessary prior to the Department Directors review.

DCS UPDATE - Update the DCS as required. Because of the nature of the Distributed Control System, some software changes are necessary before the hardware is commissioned. Also, see Attachment 1 for examples of “not in kind” changes.

UPDATE CARSEAL LIST – update the Complex carseal list as required. NEW/REVISED OPERATING/ISOLATION PROCEDURES – Review and update any changes

which affect operating manuals and equipment isolation procedures (equipment numbers, operating parameters, etc.).

OPERATOR TRAINING/AWARENESS – Determine and coordinate the training or awareness requirements. Depending on the impact of specific safety/health/environmental hazards, operation complexity, safe work practices, and/or employee job task, operators and contractors may have to be trained in the change, or made aware of the change.

NEW/REVISED MAINTENANCE PROCEDURES – Review and update any changes which affect maintenance craft procedures

MAINTENANCE TRAINING/AWARENESS - – Determine and coordinate the training or awareness requirements. Depending on the impact of specific safety/health/environmental hazards, mechanical/maintenance complexity, safe work practices, and employee job task, maintenance employees and contractors may have to be trained in the change, or made aware of the change.

NEW MSDS/SAFETY PROCEDURE/TRAINING – Review, update and/or add documentation if there is a new MSDS or new/revised safety procedures. Provide training as needed.

ERT/PLANTWIDE TRAINING/AWARENESS – Depending on the impact of the change, Emergency Response Personnel or all employees may have to be trained on the change, or made aware of the change.

PRE-STARTUP SAFETY REVIEW – If the change is significant enough to require a change to process safety information, a pre-startup safety review will be required. Reference Section 6.7. The need for a Pre-Startup Safety Review is determined by agreement of the individuals giving final approval to the MOCA.


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Completion of this section is signified by the responsible person initialing and dating the time at which the assignment is completed. Note that employees who are not present at the time of commissioning, but are affected by the change, are required to be trained or made aware of the change before operating or maintaining the equipment related to the change.

6.5. SECTION “E” – REQUIREMENTS TO BE COMPLETED SHORTLY AFTER COMMISSIONING

The intent of this section is to ensure that all documentation related to the change is accurate, complete and updated. Updates are needed when any additions, deletions or modifications are made to process safety information and other items listed below. The following are “checked” “yes” or “no” and assignments are made as required.

PROCESS FLOW DIAGRAM UPDATE – Update and attach any appropriate Process Flow Diagram if primary flow, major equipment, and/or major instrumentation is changed.

P&ID UPDATE – Update and attach existing and revised copy of P&ID. DATABOOK UPDATE – Update any process safety information related to the change such as

equipment specification sheets, pump curves, PSV calculations, design data, drawings, etc. INFO PLUS – Update the Info Plus data as required. LOOP/ONE LINE DRAWING UPDATE – Update and attach any affected Loop Diagrams and/or

Electrical One Line drawings. ISOMETRIC DRAWING UPDATE – Update isometric drawings as necessary. SAP UPDATE – Update any information related to SAP. INSPECTION RECORDS UPDATE – Update the inspection records affected by any piping or

equipment changes. ROTATING EQUIPMENT UPDATE – Update the rotating equipment records affected by any

changes to a pump, compressor, blower, etc. SPARE PARTS UPDATE – Update and attach the spare parts information as needed for piping,

piping components, rotating equipment, fixed equipment, etc. ENVIRONMENTAL FUGITIVE TAGGING UPDATE – Update environmental fugitive tagging as

required. SPEC. SHEET UPDATE – Update and attach any mechanical specification sheets as noted. RIGHT TO KNOW UPDATE – IS initial after completing the Right To Know Update. OTHER – Update and attach any documentation listed in “other”.

Completion of this section is signified by the responsible person initialing and dating the time at which the assignment is completed.

6.6. MANAGERS REQUIREMENT FOR PRE-STARTUP SAFETY REVIEW

The intent of this section is to assign primary contacts for performance of the Pre-Startup Safety Review (PSSR). This section is filled out, only if a PSSR is required, as indicated in Section “D”. The Director or their designee should initial their decision and specify an individual, when “yes” is selected.

OPERATIONS REVIEW – A member of Operations is mandatory as a primary contact for all PSSR’s.

MAINTENANCE REVIEW – A member of Maintenance is mandatory as a primary contact for all PSSR’s.


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ENGINEERING REVIEW – Depending on the nature of the change, this can be selected “yes” or “no”.

ENVIRONMENTAL REVIEW - Depending on the nature of the change, this can be selected “yes” or “no”.

HEALTH/SAFETY/FACILITY SECURITY REVIEW - Depending on the nature of the change, this can be selected “yes” or “no”.

6.7. PRE-STARTUP SAFETY REVIEW (PSSR)

The intent of this section is to ensure that a PSSR is performed and completed as required per the management of change authorization form and pre-startup safety review form. After the Directors/Managers approve the change in Section C of the MOCA form, the Owning

Area Lead Tech. or designee will attach "PSSR REQUIRED" tags to the isolation point or valves of the equipment to be commissioned.

A PSSR is initiated when the pre-startup safety review is checked “yes” in Section “D” of the Management of Change Authorization form. At that time, the primary contacts shall be identified on the Managers Requirement for Pre-Startup Safety Review.

Once the need for a PSSR has been determined, the MOCA/PSSR Coordinator or his/her designee will coordinate with Operations, Maintenance, Environmental, Tech Services, and Safety/Health Departments as needed to complete the PSSR.

Under NO circumstances shall a PSSR be considered complete and the equipment commissioned, until three (3) employees knowledgeable of the change and trained in the PSSR procedure, sign off on the PSSR that the change is ready for commissioning.

The PSSR must be completed PRIOR to the project being commissioned. When the Lead Tech. or designee has ensured that the PSSR has been approved and completed, the “PSSR REQUIRED” tags will be removed and the change implemented. All items are self-explanatory and each item listed must be marked in the applicable box. Those items to which an answer of "NO" is given must be provided with an explanation and the change will not be commissioned until the negatives are resolved and the resolution recorded on the PSSR.

After required signatures have been obtained, the Area Supervisor or their designee shall route the original MOCA which contains the PSSR along with all attachments to Process Safety Management for document updating and archiving.

7.0 EMERGENCY MANAGEMENT OF CHANGE

If the requested change is an emergency (IMMINENT SAFETY OR ENVIRONMENTAL IMPACT), the Shift Supervisor will write a Work Order and contact the Operations Director or the designee and other Directors affected by the change for approval.

The Shift Supervisor will initiate the MOCA form prior to end of the shift and give it to the Area Supervisor or their designee for completion.

Before an emergency change is commissioned it is the responsibility of the Shift Supervisor to inform affected employees and contractors that are present of the change, ensure their understanding of the change and obtain their signatures on the Change Notification Form.

The Shift Supervisor will ensure that all affected incoming employees/contractors are informed of the change and obtain their signatures on the Change Notification Form before working the process.

The Shift Supervisor will be responsible for completing a Pre-Startup Safety Review before commissioning change.


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The MOCA form will be completed no later than the Area Supervisor's or their designee's next work day and turned in to Directors/Managers along with a copy of the Work Order for final approval.

8.0 TEMPORARY CHANGES

A date will be given stating when the change is to be returned to the original state. Prior to the expiration date, Operations will follow up to ensure that the temporary change is

reviewed to determine if the change date should be extended, changes made permanent or if it can be returned to the original state.

If the temporary change date should be extended, the originator and Operations will determine the new date and resubmit the original MOCA, as a revision, to the Directors/Managers for approval.

If a temporary change is made permanent, a new MOCA must be prepared and submitted by the originator.

If the temporary change is returned to original state, a copy of the change and a revised Change Notification Form will be reissued by the Area or Craft Supervisor.

9.0 MOCA AFTER BUSINESS HOURS

If the need for a change requiring an MOCA should occur after business hours and has to be commissioned before the next scheduled work day, the Shift Supervisor will be responsible for contacting all Department Directors/Managers or their designees to sign or give verbal approval before the change can be initiated. This will be documented on Sections A, B, C & D of the MOCA form.

The Directors/Managers Requirements for Pre-Startup Safety Review will be completed and if a representative is required, that individual will be called. The Shift Supervisor will be responsible for completing a Pre-Startup Safety Review before commissioning the change.

Section E will need to be completed shortly after the commissioning of the MOCA. The MOCA will then be forwarded to the Area Supervisor on the next working day to be

reviewed by the Directors and assigned a MOCA number. Before the change is commissioned, it is the responsibility of the Shift Supervisor to inform

affected employees and contractors that are present of the change, ensure their understanding of the change and obtain their signatures on the Change Notification Form.

The Shift Supervisor will ensure that all affected incoming employees/contractors are informed of the change and obtain their signatures on the Change Notification Form before working the process.


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ATTACHMENT I

IN-KIND CHANGES

VALVES:

1. Must be same style. Example: Gate to Gate, Globe to Globe. 2. Must be same specification. 3. Must be same rating. Example: 150# to 150#, 300# to 300#.4. Must be same size. Example: 4" to 4", 6" to 6".

PIPING AND FLANGES

1. Must be same size. Example: 6" to 6", 8" to 8".2. Piping must be same schedule. Example: Sch.40 to Sch.40, Sch.80 to Sch.80.3. Must be same specification. 4. Flanges must have same rating. Example: 150# to 150#, 300# to 300#.5. Flanges must have same facing. Example: Raised Face to Raised Face, Ring Joint to Ring

Joint.6. Temporary piping when process is not involved. Example: Temporary piping used for the

purpose of cleaning units for shutdowns.

PUMPS AND COMPRESSORS

1. Must be same material (includes internals).2. Must have same flange rating, size, and facing.3. Must have same capacity and head. Example: 300 GPM to 300 GPM, 2000 SCFD to 2000

SCFD, 300 psi to 300 psi.4. Must have same type, manufacturer and model number of seal.5. Must be same manufacturer and model number.

TURBINES, STEAM DRIVERS (Reciprocating), AND MOTORS

1. Must be same material (includes internals).2. Turbines and steam drivers must have same flange rating, size, and facing.3. Must have same capacity. Example: 200 HP to 200 HP, 400 HP to 400 HP.4. Must have same type, manufacturer and model number of seal. Example: Mechanical to

Mechanical.5. Motors must have same electrical rating. Example: 460 volts to 460 volts, 240 volts to 240

volts.6. Must have same type of lubrication system. Example: Pure Mist to Pure Mist, Purge Mist to

Purge Mist.7. Must be same manufacturer and model number. (Does not apply to electrical motors.)


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INSTRUMENTATION

1. Must have same range. Example: 0-10, 0-150.2. Must have same multiplier. Example: X10, X50, X100.3. Must measure same units. Example: GPM, SCFD, Lb/HR.4. Must use same sensing element. Example: Orifice Plate, P/D Cell.5. Changes to deviation/discretionary alarms.6. Must be same manufacturer and model number.

MISCELLANEOUS

1. Temporary changes that occur during a shift and will not last past that shift do not require MOCA.

2. Safety and Fire protection equipment taken out of service for repair will not require a MOCA if its temporary removal for repairs has no effect on emergency response or normal operating procedures or if existing procedures provide guidance on how to operate the affected system during the temporary outage. In any case, prompt notification of affected personnel will be done via e-mail, postings, orders, etc. in addition to any MOCA required.


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NOT IN KIND CHANGESVALVES

1. Change in style. Example: Gate to Globe, Globe to Gate.2. Change in specification.3. Change in rating. Example: 150# to 300#, 300# to 600#.4. Change in size. Example: 4" to 6", 6" to 8".5. Change in packing material.

PIPING AND FLANGES

1. Change in size. Example: 6" to 8", 8" to 6".2. Change in piping schedule. Example: Sch.40 to Sch.80, Sch.80 to Sch.40.3. Change in specification. 4. Change in flange rating. Example: 150# to 300#, 300# to 150#.5. Change in flange facing. Example: Raised Face to Ring Joint, Ring Joint to Raised Face.

PUMPS AND COMPRESSORS

1. Change in material (includes internals).2. Change in flange rating, size, and facing.3. Change in capacity or head. Example: 300 GPM to 500 GPM, 2000 SCFD to 1000 SCFD,

300 psi to 500 psi.2. Change in type of seal.3. Change in manufacturer or model number.

TURBINES, STEAM DRIVERS (Reciprocating), AND MOTORS

1. Change in material (includes internals).2. Turbines and steam drivers change in flange rating, size, and facing.3. Change in capacity. Example: 200 HP to 500 HP, 400 HP to 800 HP.4. Change in type of seal.


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5. Change in motors electrical rating. Example: 460 volts to 240 volts, 240 volts to 460 volts.6. Change of lubrication system. Example: Pure Mist to Purge Mist, Purge Mist to Pure Mist.7. Change in manufacturer or model number. (Does not apply to electrical motors.)

INSTRUMENTATION

1. Change in range. Example: 0-10 to 0-150, 0-150 to 0-20.2. Change in multiplier. Example: X10 to X50, X100 to X200.3. Change in measuring units. Example: GPM to Lb/HR, SCFD to SCFH.4. Change in DCS set point clamps.5. Change in scan phase/period.6. Changes to DCS historian.7. Change in manufacturer or model number.

CHEMICALS AND CATALYST

1. Change in composition or manufacturer.2. Change in function/reaction.


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MAINTENANCE CHANGES

1. A maintenance procedure change that affects the way a piece of equipment is repaired, handled or replaced in-field or in-shop. Example: Changing a weld procedure.

OPERATIONAL CHANGES

1. An operating procedure change that affects plant operation or the process.

a. A change in the start-up or shutdown procedures.b. A change in the emergency procedures.c. A change in the normal operating procedures.d. Resetting alarm limits except for deviation/discretionary alarms.e. Resetting control parameters out of the normal high or low limits.f. Changing to a feedstock that a plant is not designed for.g. Bypassing equipment in-service (new bypasses).

2. A change in operational software that could affect plant operations.3. A change in computer control schemes that could affect plant operations.

MISCELLANEOUS CHANGES

1. Relocation of equipment. Example: Moving a pump from one tank to another tank.2. Installing new bleeders in existing lines.3. Installing new vents in existing lines.4. New piping tie-ins.

a. New lines to flare/blowoff systems. b. New lines to tank fill/suction lines.c. New lines to pump suction/discharge lines.d. New lines to utility lines (water, steam, air).

5. Temporary piping when process is involved.a. Temporary tank fill line tie-in to remove another tank from service.b. Temporary pump suction/discharge line tie-in to remove another pump from service.

6. Pipe clamps/temporary leak repairs.7. Hot taps/stopples.8. Lighting changes. 9. Relief valve changes. Example: Changing settings (Pop at 25# instead of 30#).10. Changing a sampling procedure.11. A change in technical procedures. Example: Changing piping specifications.12. A change in a safety and health guide.


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ATTACHMENT II

PROCESS SAFETY INFORMATION

I. PROCESS CHEMICALS INFORMATION

Following is the minimum required information pertaining to the hazardous chemicals used in the process units.

1. Toxicity Information2. Permissible Exposure Limits3. Physical Data4. Reactivity Data5. Corrosive Data6. Thermal and Chemical Stability Data7. Hazardous Effects of Inadvertently Mixing of Different Materials that Could Foreseeable

Occur

NOTE: MATERIAL SAFETY DATA SHEETS MEETING THE REQUIREMENTS OF 29CFR1910.1200 (g) MAY BE USED TO COMPLY WITH THIS REQUIREMENT TO THE EXTENT THEY CONTAIN THE INFORMATION REQUIRED.

II. PROCESS DESIGN INFORMATION

Following is the minimum process design information required by Process Safety Management.

1. Block Flow/Simplified Process Flow Diagrams2. Process Chemistry3. Maximum Intended Inventory4. Safe Upper/Lower Limits (Temperature, Flow, Pressure, etc.)5. Evaluation of the Consequences of Deviation

NOTE: WHERE THE ORIGINAL TECHNICAL INFORMATION NO LONGER EXISTS, SUCH INFORMATION MAY BE DEVELOPED IN CONJUNCTION WITH THE PROCESS HAZARDS ANALYSIS IN SUFFICIENT DETAIL TO SUPPORT THE ANALYSIS.

III. PROCESS MECHANICAL DESIGN

Following is the minimum process mechanical design information required by Process Safety Management.

1. Material of Construction2. Piping and Instrument Diagrams3. Electrical Classification4. Relief System Design and Design Basis5. Ventilation System Design6. Design Codes and Standards Employed7. Material and Energy Balances for Processes Built After Effective Date of Standard8. Safety System (Such as Interlocks, Detection and Suppression Systems)


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ATTACHMENT III

RISK LEVEL ASSESSMENT

MOCA Number: WO / AFE # Date:

Risk Assessment Performed by:

MOCA Description of proposed change: ________________________________________________________

Note: Completion of this form may not be required for: 1. Changes in documentation; 2. Changes in equipment where the functionality of the equipment remains the same; 3. HAZOP Action Items

Section I – Degree of Hazard

1. Does the change introduce or substantially affect a significant source of chemical, mechanical, thermal, or electrical energy? (1 point for yes, 0 points for no)Examples: Installation/modification of a motor; Increasing steam supply pressure to a vessel

2. Does the change result in any increase in inventory of toxic, flammable, or reactive (equivalent to a "4" rating in the NFPA or HMIS systems) materials? If so, is this a new threshold for PSM or RMP covered chemicals? (1 point for yes, 0 points for no)

3. Are established PSM or RMP boundaries extended to new piping or equipment? (3 points for yes, 0 points for no)

4. Will the changed process system contain any materials known or suspected to be thermally, chemically, or physically unstable in quantities or concentrations high enough to cause a hazard? (3 points for yes, 0 points for no)

5. Does the change significantly increase the potential for personnel exposure to a hazardous material? (2 points for yes, 0 points for no)

6. Does the change introduce or substantially affect any special or unique hazards that could cause significant negative community impact? (2 points for yes, 0 points for no)HAZARD RULE: "Higher" if answers 1-6 total more than 2 points, otherwise "Lower"

Section II – Significance of Proposed Change

1. Could the change take the process or system outside previous limits of normal operation (that is, outside the well understood and documented "safe operating envelope") during steady state or transient conditions? (2 points for yes, 0 points for no)

2. Does the change introduce substances not already present in the process? (1 point for yes, 0 points for no)

3. Are PSV’s or rupture disks affected, changed or bypassed? (1 point for yes, 0 points for no) 4. Does the change re-order or alter the processing sequence and consequently by this alteration

introduce a hazard? (2 points for yes, 0 points for no) 5. Does the change significantly impact the energy balance or mass balance? (1 point for yes, 0

points for no) 6. Does the change affect a safety device? (1 point for yes, 0 points for no) 7. Does the change alter or bypass a critical control system (2 point for yes, 0 points for no) 8. Does the change necessitate significant or unique training for operators or technical personnel?

(1 point for yes, 0 points for no) 9. Does the existing system handle reactively incompatible materials in the same equipment during

different sequences or campaigns? (2 points for yes, 0 points for no)__ 10. Does the proposed change require the development of a new Maintenance Procedure/Guideline?

(1 point for yes, 0 points for no)SIGNIFICANCE RULE: "Higher" if answers 1-10 total more than 2 points, otherwise "Lower"


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Section III – Risk Level

Using the Degree of Hazard and Significance of Change results from Sections I and II, determine and circle the Risk Level of the proposed change:

SIGNIFICANCE OF CHANGE

LOWER HIGHER

DEGREE OF HAZARD LOWER Level 1 Level 2

HIGHER Level 3 Level 4

Risk Assessment Requirements

Level 1:Complete MOCA form onlyLevel 2:Complete MOCA form and perform informal PHA at the Review Team’s Discretion

(Note reasons for not performing PHA in comments section)Level 3:Complete MOCA form and perform an informal PHALevel 4:Complete MOCA form and perform a HAZOP or informal PHA

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