Training Session Purpose Goals/Objectives –Learn to talk-the-talk –Learn why PSM and RMP exist...

Training Session Purpose

Goals/Objectives– Learn to ‘talk-the-talk’– Learn why PSM and RMP exist– Learn a bit about ammonia– Learn the PSM ‘schedule’– Understand the consequences of failure to follow– Learn to better understand your existing program– Understand requirement changes and trends in PSM and where

EPA and OSHA focus now– Learn those areas that may change when your system changes

1

Process Safety Management (PSM) – Occupational Safety & Health Administration (OSHA) – OSHA 29 CFR 1910.110 (Process Safety Management of Highly

Hazardous Chemicals)– “inside” the plant (loosely speaking)

Risk Management Program (RMP)– Environmental Protection Agency (EPA)– EPA 40 CFR Part 68 (Accidental Release Prevention Requirements:

Risk Management Programs Under Clean Air Act Section 112(r)(7)– “outside” the plant (loosely speaking)

Lingo– Are PSM/RMP Interchangeable? - No!

Department of Homeland Security– Site security plans

PLUS the General Duty Clause!!!

What are PSM and RMP?

2

What is the General Duty Clause All About? - 1

General Duty Clause(s)– EPA “Purpose and General Duty – “It shall be the objective of the

regulations and programs authorized under this subsection to prevent the accidental release and to minimize the consequences of any such release of any substance listed pursuant to paragraph (3) or any other extremely hazardous substance. The owners and operators of stationary sources producing, processing, handling or storing such substances have a general duty, in the same manner and to the same extent as section 654, title 29 of the United States Code, to identify hazards which may result from such releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.” (Section 112(r)(1) of the Clean Air Act)

– OSHA Act of 1970: “The owner shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” (29 USC 654 )

3

What is the General Duty Clause All About? - 2

General Duty Clause– You can be in violation if:

• A known hazard exists• This hazard poses a threat to employees lives or personal safety• If the hazard is recognized and addressed by the industry• Employees are regularly exposed to that hazard

– Very open ended– Basically, if the industry recommends it, you must do it!!!

4

The Unofficial Phases of PSM Implementation

Phase 1: Installation of Kryptonite!– PSM Programs Initially Created in accordance with OSHA/EPA– OSHA/EPA Knowledge Is Limited

Phase 2 – The Era of the Kryptonite!– Programs sit on the Shelf– OSHA/EPA Knowledge of NH3 PSM Begins to Grow

Phase 3 – Our Kryptonite Needs Fixed???!!!– Programs sit on the Shelf– OSHA/EPA Personnel Have Extensive Knowledge of NH3 PSM

– The fines are coming!

5

Why PSM and RMP? - 1

December 2, 1984 - Bhopal, India– 100,800 lbs of methyl isocyanate (MIC) gas released from

underground storage tanks– Union Carbide India Limited (UCIL)– Potential employee sabotage– Nocturnal temperature inversion– Substandard living/housing conditions– By the following morning, over 2,000 dead and 300,000 were

injured by morning– 1,500 people died in subsequent months– Emergency services were completely overwhelmed – Emergency Services/Police provided complicating instructions– Residents were unaware that the simple act of covering their

faces with wet cloths and lying indoors on the floor provided effective protection against the gas

6

Why PSM and RMP? - 2

December, 1984 – Institute, West Virginia– Union Carbide– Cyanide– 135 Hospitalized– No temperature inversion– America’s wake-up call!

Barbour

Berk e ley

Boone

Brax ton

Brook e

Cabel l

Ca lhoun

Clay

Doddridge

Fay ette

Gi lmer

Grant

Greenbrier

Hamps hire

Hanc oc k

Hardy

Harris on J effers on

Lewis

L inc o ln

Logan

Mc Dowel l

Marion

Mars ha l l

Merc er

Minera l

Mingo

Monongal ia

Monroe

Morgan

Nic ho las

Ohio

Pendle ton

Pleas ants

Poc ahontas

Pres ton

Rale igh

Randolph

Ri tc h ie

Summers

Tay lor

Tuc k er

Ty ler

Ups hur

Way ne

Webs ter

Wetz e l

Wy oming

J ac k s on

Kanawha

Mas on

Putnam

Roane

Wirt

Wood

7

Our Industry

Various Industry Organizations– International Institute of Ammonia Refrigeration (IIAR)– American National Standards Institute (ANSI)– American Society of Heating, Refrigerating, and Air Conditioning

Engineers (ASHRAE) – American Society of Mechanical Engineers (ASME)– Refrigerating Engineers and Technicians Association (RETA)– Other organizations indirectly will affect as well

8

The “What’s” About Ammonia

Basic Facts about ammonia– Ammonia is considered “highly hazardous” by OSHA– Ammonia is stable and naturally occurring– Ammonia is a strong alkali– Lighter than air (when not saturated with water– Ammonia has an “affinity” for water– Human body is approximately 65% water– Readily damages all body tissues

• Target easily accessible/exposed water sources on body (eyes, ears, mouth, etc.)

– Personal protective equipment (PPE) is required– Incompatible with copper (and copper alloys) and galvanized steel– Incompatible with certain kinds of rubber– Considered Non Flammable for Shipping– Upper and Lower Flammability Limits: 15-28% Concentration– Auto Ignition Temperature: 1,200+ °F

9

If It Does This to a Buck…

Dollar Shrinking – It Isn’t Inflation Either

If it can do this to a dollar, imagine what it will do to your unprotected eyes (which has MORE water than the bill)!!!

10

Ammonia and How It Affects You

Various Exposure Limits– 0-50 ppm - Detectable odor – 50-100 ppm - Mild eye, nose, and throat irritation; may develop

tolerance in 1-2 weeks with no adverse effects thereafter – 140 ppm - Moderate eye irritation; no long-term tissue injury in

exposures of less than 2 hours – 300 ppm - IDLH – 400 ppm - Moderate throat irritation – 700 ppm - Immediate eye irritation/injury – 1000-2500 ppm - Directly caustic to airway, spasms of the larynx and

bronchospasms, severe eye and skin injury/irritation– 1700 ppm – Uncontrollable spasm of the larynx – 2500 ppm - Fatality (after half-hour exposure) – 2500-6500 ppm – permanent destruction of lung, sinus, and throat

tissues. Also significant pain– 5000 ppm - Rapidly fatal exposure

11

Is Ammonia All THAT Terrible?

Keep Things in Perspective– Naturally Occurring– Commonly Used on Farms

Like Any Tool– If You Fail to Respect Ammonia, Ammonia Will Fail to Respect

you

12

Why Ammonia Then? Why not Freon

Ammonia – Naturally occurring– Environmentally friendly– Self alarming– Inexpensive– If You Fail to Respect Ammonia, Ammonia Will Fail to Respect

you

Freon and Fluorocarbons– Fire creates phosgene gas (mustard gas)– Suffocant (heavier than air)– Can’t smell it– Expensive

13

Who Has a Role?

EVERYONE!– Management– PSM Coordinator– Operators– Mechanics– Floor Personnel– Contractors!

Remember that these are REQUIRED by OSHA and EPA!!!

14

The “When’s” of PSM/RMP

Every Year– Safety Inspection Forms– Review Standard Operating Procedures (SOPS) and SIGN OFF– Review contractors performance

Every three years– Compliance Audit– Operator and Mechanic Refresher training

Every five (5) years– Submit RMP to the EPA– Process Hazard Analysis (PHA) revalidation

If you have electronic maintenance system (e.g., Maximo), this would be a good tool to use

15

Consequences – “OSHA/EPA Shock and Awe” - 1

February 12, 2004– John Morrell Company - Sioux Falls, South Dakota– People living within ¾ miles told to stay in home– 19,300 pound release from a 5” line– 77 Injuries– Full facility evacuation– High pressure liquid– $57,000 in fines– Federal investigators said that John Morrell should have done a

better job of watching out for corrosion on pipes [mechanical integrity]…

16


March 27, 1999– Albertsons Distribution Center – Denver, Pennsylvania– NO RELEASE– Potential disgruntled employee– $170,000– ONLY ammonia PSM related

October 10, 2010– Tanner Industries, East Providence, Rhode Island– NO RELEASE– $149,080– Emergency Response Plan didn’t address

releases during times when facility isn’t

occupied.

17


January 22, 2000– Wells Dairy – LeMar, Iowa– 100,000 pound release– Loss of ammonia compressor room

and additional areas– $15,000 fine issued (originally

$20,000) by Iowa’s OSHA– Worst enemy (fire) may have been

their best friend?– As of October 2010, courts are still

resolving the civil liability. Wells Dairy, the construction firm, and RVS were found to be at fault, but no financial rulings have been awarded

18


September, 2010– Tree Top Incorporated, Selah, Washington– 1,100 pounds of ammonia released from relief valve on July 10,

2009– Facility incident occurred around 7pm am, but didn’t inform EPA

until 1:30 pm on July 11, 2009– $107,000 fine

September, 2010– Pilgrim's Pride, Russellville, Alabama– Incident investigation from ammonia odors, tripping hazards, and

cutting and stabbing injuries (Source: TimesDaily.com)– Improper Ventilation $5,000 fine– Inadequate emergency preparedness for ammonia release -

$5,000– Fines were issued as a result of other OSHA issues.

19


October 28, 2010– American Seafoods International, LLC, New Bedford, Massachusetts– NO INJURIES– $195,000 fine for inadequate PSM program including inadequate SOPs

and lack of inspections (Mechanical Integrity Program)– Additional $84,000 fine for failure to update Process Safety Information

and failure to investigate a 2001 incidentDecember 1, 2004

– Associated Milk Producers – New Ulm, Illinois– $88,400 fine– “…for failure to immediately notify the NRC of a 3,873-pound anhydrous

ammonia release during a fire at the facility…” (approximately a 5 hour delay) and follow up wasn’t reported for 80 days

June 18, 2010– Creekstone Farms Premium Beef, Arkansas City, Kansas– $130,00 fine– Inadequate or missing: employee participation, employee training,

process hazard analysis, SOPs, emergency response program, and mechanical integrity

20


LAST BUT NOT LEAST!!!

January 24, 2001– Ammonia Theft– A couple of young thieves trying to steal the anhydrous ammonia

from a nursing tank in a cotton field in Mississippi had an accident and the pressurized gas escaped, burning them and about 25 to 30 acres of the field. "They were extracting it from the tank, and because it was pressurized, they either couldn't cap it back off or couldn't contain it in their tank," an officer said. "The chemical began to release and got on their clothes and burned them. "They stripped off their clothes and ran to a creek where the sheriff found them buck naked and arrested them," he said.

Ammonia theft is a huge industry issue!

21


Are these image you want your customers to remember about you?

22

PSM (and RMP) Elements/Programs

– Employee Participation– Mechanical Integrity – Incident Investigations– Trade Secrets– Process Safety Information (PSI)– Process Hazard Analysis (PHA)– Standard Operating Procedures (SOPS)– Pre-Startup Safety Review– Management of Change– Contractor Qualification– Compliance Audit– [Operator and Mechanic] Training– Hot Work – Emergency Planning and Response

23

Employee Participation Program

General Program Description– Ensures employees are actively involved in the creation and

maintenance of the PSM Program.

Basic Principals– To ensure employee involvement in the PSM/RMP Program– To ensure employee access to information to the PSM/RMP

Program– To ensure proper program information dissemination

Specific Areas of Interest/Attention– Process Hazard Analysis (PHA)– Standard Operating Procedures (SOPs)– Consider basic ammonia awareness for all employees

DOCUMENTATION IS IMPORTANT!!!

24

Mechanical Integrity Program - 1

General Program Description– Creates a structure of procedures and schedules to ensure safe

operation of ammonia refrigeration equipment, piping, and systems.

Basic Principals– To properly identify all equipment in the ammonia refrigeration

system– To ensure accurate operating and maintenance procedures have

been created– To ensure adequate operator and mechanic training has been

established– To ensure all necessary testing, inspection, and preventative

maintenance is scheduled– To identify all equipment deficiencies and to take corrective

actions to address those deficiencies

25

Mechanical Integrity Program - 2

Specific Areas of Interest– Standard Operating Procedures– Operator Training– Maintenance Procedures– Computerized Databases (e.g., Maximo or other maintenance

planning programs)

This is a MAJOR thrust of recent OSHA inspections– Do you have a Mechanical Integrity or “break it/fix it” program– Documentation, documentation, and more documentation

26

Incident Investigation Program

General Program Purpose – Implements procedures for investigating serious incidents and

near‑misses and to prevent any recurrence of similar incidents.

Basic Principals– Define what constitutes an incident and a ‘near-miss’– Create a structure for performing incident (and ‘near-miss’)

investigations– Identify methods for addressing recommendations as the result

of near incidents (and ‘near-misses’)– Establishing methods of communicating the status of the

investigation team– 100 Pounds in 24 hours constitutes an ‘incident’

Other Notes– Incident Investigations must be kept for five (5) years

27

Process Safety Information - 1

General Program Purpose– To identify the hazards posed by anhydrous ammonia and the

process (the refrigeration system) in which it is used including:• The specific [chemical] hazards of anhydrous ammonia• The technology used in the ammonia refrigeration system, and• The equipment used in the ammonia refrigeration system.

Basic Principals– Hazards of anhydrous ammonia including discussions of:

• Toxicity information for anhydrous ammonia• Physical data of anhydrous ammonia• Reactivity of anhydrous ammonia• Corrosivity of anhydrous ammonia• Thermal and chemical mixing of anhydrous ammonia• Historical reactions to anhydrous ammonia exposure

28


Basic Principals (Continued)– Discussion of technology associated with the anhydrous

ammonia refrigeration system• simplified process or block flow diagram• process chemistry• maximum intended inventory• safe lower and upper operating limits• consequences of deviation from normal operating limits• Lost or missing information/data

29


Basic Principals (Continued)– Discussion of equipment associated with and used in the

ammonia refrigeration system• materials of construction• piping and instrumentation diagrams (P&IDs) • electrical classification• relief system design and design basis• ventilation system design and design basis• design codes and standards employed• material and energy balance (system load estimate)• safety systems

30


Piping and Instrumentation Diagrams (P&IDs) and Block/Process Flow Diagrams – The Difference Between…

Evap C ondensers(4 C ondensers T otal)

D edicated C ompressorfor Pack Off C hillers

(1 U nit T otal)

H ig h T empR ecip C ompressors

(5 U nits T otal)

Open C oils (EV-8)(2 Surg e D rums and

2 C oils T otal)

C ontinuous C ook/C hillShell/T ube H eat Exchang ers

(2 Surg e D rums and2 H eat Exchang ers T otal)

C hill H ouse #2(1 U nit T otal)

C hill T anks(10 T anks T otal)

D esiccant M ake U p Air(1 U nit T otal)

[F looded] West F reezers(T otal of 2 Surg e D rums

and 4 Air U nits)

R ecirculatingPumps

(3 U nits T otal)

Air Purg er(1 U nit T otal)

Pack O ff Area Air U nits(4 U nits T otal)

HT

RL

CR

OS

S-O

VE

R

+ 38F Assembly (3)Var iety M eats/Box R oom (8)

+ 38F Production (5)R eceiving (2)

Link C ooler (4)(22 U nits T otal)

Pre Blend C ooler (2)Pre Blend D ock (1)

(3 U nits T otal)

D eser t Air /Eng lehard U nit(1 U nit T otal)

T unnel C ooling C oils(3 U nits T otal)

R aw Production Area (1)C ooked Product Area (1)C ooked H old C ooler (2)

C ryovac Area (2)Pack O ff Area (2)

(8 U nits T otal)

King U nit over Var iety M eats(1 U nit T otal)

Screw C ompressorsin Aux R oom

(1 U nits T otal)

King U nitsC ryovac R ooms

Pasteur iz ing R oom(2 U nits T otal)

T urbo C hiller(1 Surg e D rum and

1 H eat Plate C hiller T otal)

Pasteur iz ing R oom U nits(2 Eig ht F an U nits and2 Surg e D rums T otal)

Slice R oom King U nit(1 T otal U nits)

Arby Area Br ing C hill T ank(1 U nit T otal)

C hill H ouse #1(1 Surg e D rum & 1 U nit)

H ig h Pressure R eceiver(1 U nit T otal)

H ig h T empPump R ecir .(1 U nit T otal)

SuctionAccumulator(1 U nit T otal)

T ransferD rum

(1 U nit T otal)

D edicated C ompressorfor West F reezer

(1 U nit T otal)

Low T empR ecip C ompressors

(4 U nits T otal)

LT SLT SLT S

LT S

LT S LT S

LT S LT S

LT S

LT S

LT

S

LT

SL

TS

LT

S

LT

S

HP L HP L

HP LHP L

HP L

HP L

LI L I L I

HP L

HP L

L I

HP L HP L

HP L (MA K E UP )

HP LHP L

HP L

HP L

HP L

HP L

HP L

HP

L

HP

L

HP

L

HP

L

HP

L

HP

L

HP

LH

PL

HP

L

HP

L

HP

L

LI

LI

LI

LI

LI

LI

HP

L

HT SHT SHT S

HT S

HT S

HT SHT S HT S

HT S

HT SHT S

HT S

HT S

HT S

HT S CR OS S -OV E R

HT S HT S

HT RL C ROS S -OV E R

HT S

HT SHT SHT SHT S

HT S

HT S

LT S

HT

SH

TS

HT

S

HT

S

HT

S

HT

S

HT

S

HT

S HT

S

HT

S

HT

S

HT

S

HT

S

HT

S

CD CD CD CD CD

T RA NS

CD

E QL E QL E QL E QL E QL

FG FG

HG

HG

HG

HG

HG

HG

HG

HG

HT RL

HT RL

HT RL HT RL

HT RL

HT RL HT RL

HT RL

HP LHP L

LT

S

HT

RL

HT

RL

HT

RL

HT

RL

HT RL

HT RL

HT

RL

HP L

LT S

HS S HS S HS SHS S

HS S HS S

HS

S

LT S LT S LT S LT S

LT

SL

TS

LT

S

LT

S

LT

S

LT

S

CD

CD

CD

EQ

LE

QL

EQ

L

31


Special Considerations– Relief Valve Calculations

• Modifications to ANSI/ASHRAE 15– More strict requirements for maximum distance from valve to header (or

direct atmospheric discharge, when applicable)– Header diameter requirements can be affected– These lines are grandfathered if there is no modification to that run

– This is a general duty clause issue and a code/ordinance compliance issue

32

Process Hazard Analysis - 1

General Program Purpose – to analyze potential hazards associated with the anhydrous

ammonia refrigeration system

Basic Principals– Establish an acceptable methodology– Determine appropriate potential hazards to address– Develop an appropriate PHA Team– Identify recommendations to improve the safety of the

anhydrous ammonia refrigeration system– Create a structure to track recommendations and ensure their

resolutions

33


Acceptable Methodologies– What if– Checklist– What if/checklist– Hazard and Operability Study (HAZOP)– Failure and Mode and Effects Analysis (FMEA)– Fault Tree Analysis– “Or other equivalent method”

Generally What If/Checklists are performed

34


What should be addressed?– Known hazards– Previous incidents – Engineering and administrative controls– Consequences of control failures– Facility site issues– Human Factors– A facility walk through and inspection should be performed by

the Team!

Who does it?– Someone knowledgeable in the analysis method used– Someone knowledgeable in refrigeration plant design– Someone knowledgeable in refrigeration plant operations

35


Additional Notes– A listing of recommendations must be made– Recommendations must be reviewed in a ‘timely’ manner

• The EPA and OSHA both review for completeness during audits– The PHA should be an open dialog of potential hazards seen by

the each member of the team based on their own experiences– The team should NOT be exclusively from the facility– Only each unique type of equipment needs to be reviewed and

not each individual piece of equipment– Since over 5 years, perspectives, experience, personnel, and

the methods of performing PHAs changes, it is recommended to ‘start over” and not just review the previous PHA.

Unofficial term/concept – equipment classification

36

Standard Operating Procedures - 1

General Program Purpose – To provide clear instructions for anhydrous ammonia

refrigeration system operation

Basic Principals– Identify safety and health information regarding anhydrous

ammonia– Identify the required operating phases– Identification of safety features associated with each type of

ammonia refrigeration equipment– Identify the operating limits of each type of ammonia

refrigeration equipment

37


Operating Phases– Initial Startup– Normal Operations– Temporary Operations– Emergency Shutdown– Emergency Operations– Normal Shutdown– Startup Following a Turnaround or after an Emergency

Shutdown

Applicability– Not All Are Applicable to Ammonia Refrigeration– Some Are Combined (Emergency Shutdown and Emergency

Operations)38


Safe Work Practices– Hot Work– Confined Space Entry– Lockout/Tagout (LOTO)– Line Opening Procedure

Other notes– When the system changes, the SOPs may as well– These must be annually reviewed

• The annual review MUST be documented. The EPA and OSHA will fine you during an audit if you do not show record of SOP annual review!

– These should be in easy access to operators/mechanics

39

Operator and Mechanic Training Program - 1

General Program Purpose – provides on and off the job training for mechanic/operators to

enable them to safely operate the ammonia refrigeration system

Basic Principals– Define qualification– Identify employees requiring training

• If someone is touching the system, they better have records showing they are qualified to do what they are doing.

– System wide training versus task training– Identify acceptable training types– Identify documentation to be completed– Define general requirements– Identify terms of refresher training– Identify appropriate ‘grandfathering’

40

Operator and Mechanic Training Program - 2

Important Notes– What is Qualification

• Task related training• System related training

– Refresher Training• Every three (3) years (required)

– Can be open ended and subjective– Internal and external– Annual review of training is recommended (this eliminates the

confusion of the three year timing)• May be required if new equipment is added

– Grandfathering• If you’ve been running the system since before May 26, 1992

– Documentation is the difference!!!

41

Contractor Qualification Program - 1

General Program Purpose – evaluates contractors’ safety performance

while ensuring contractors understand known hazards and can work safely

Basic Principals– Define means used to select contractors– Define the steps necessary to qualify a

contactor– Identify the facility’s requirements and

responsibilities to contractors working at the facility

– Identify the contractors requirements and responsibilities

42


Facility’s Responsibilities the Contractor– evaluating the contractor’s qualifications to perform the work projected– informing the contractor of known fire, explosion, and toxic release

hazards (especially for non ammonia contractors)– explaining applicable OSHA regulations and how they affect the project– implementing and employing safe work practices contractor entry and

exit– periodic contractor evaluation– providing facility safe work practices and emergency response plan– reviewing and evaluating the contractor’s safe work practices and

training and ensuring that each contract employee has been informed and trained and understood the training

– reviewing the design, engineering, and P & IDs for the project with the contractor

– performing site walk through noting the hazards associated with ammonia system

– maintaining a separate contractor employee injury and illness log related to the contractor’s work on the project

43


Contractor’s Responsibilities to Their Employees – ensuring contractor employees are trained in the work practices

(especially safe work practices)– instructing employees of known potential fire, explosion or toxic

release hazards and the applicable provisions of emergency response plan

– documenting that each employee has received and understood the instructions and training

– ensuring that employees follows safety rules. – advising your company of any unique hazards presented by the

contractor’s work or of any hazards found by the contractor’s work.

– Additional Notes• Contractor information must be updated annually• Documentation is a MUST!• OSHA and the EPA will fine you if you do not have documentation

for your contractors during audits44

Management of Change Program

General Program Purpose – establishes and implements written procedures for managing

changes to the technology, equipment, and procedures for the anhydrous ammonia refrigeration system.

Basic Principals– ensure all appropriate anticipated reviews are considered prior

to commencing a refrigeration plant modification– Identify potential documentation changes required as the result

of proposed changes– Ensure appropriate document updating is completed– Ensure design reviews are completed– Ensure safety and health considerations are addressed as the

result of changes– Does NOT apply to “Replacement in Kind”… but…

45

Pre-Startup Safety Review Program

General Program Purpose – ensures all PSM and RMP Program related areas have been

addressed prior to introducing ammonia to the refrigeration system.

Basic Principals– Ensure all PSM documentation has been modified to suit the

modified facility prior to introducing ammonia into the new system/component

– Ensure all necessary training has been performed regarding new equipment/processes prior to introducing ammonia into the new system/component

46

Compliance Audit Program

General Program Purpose – To verify that the PSM and RMP programs meets federal

requirements and are implemented

Basic Principals– Establish audit frequency and timing– Define the requirements of the auditor and/or team– Identify the scope of the audit– Define requirements for addressing and tracking audit

recommendations

Additional Notes– The “team”

• You can have a team; however, having an individual with experience auditing programs is a must!

• Don’t audit yourself!– Two most recent audits must be maintained

47

Trade Secret Program

General Program Purpose – Defines the rights of employees regarding access to PSM and

the effects of trade secrets

Basic Principals– Regardless of potential industry secrets, the employer must

inform employees working with the process about the process– Not applicable to ammonia refrigeration system except in rare

circumstances

48

Risk Management Program - 1

General Program Purpose – To summarize, document and communicate the elements of the

Risk Management Program (RMP) to the Environmental Protection Agency (EPA) and other state and federal agencies and responders

Basic Principals– Identify the covered process– Describe the anhydrous ammonia refrigeration system in

general as it relates to the facility and local community (executive summary)

– Describe the Prevention Program 3 information

49


Basic Principals (Continued)– Management System

• A listing of how the PSM/RMP will be administered, but more importantly, by whom

– Risk Management PLAN vs. Risk Management PROGRAM• Risk Management PLAN is a document that is [re]submitted to the

EPA at least every five (5) years or sooner if facility modifications require resubmittal

• The Risk Management PROGRAM discusses how the PSM Program and Emergency programs are administered and provides details about the covered “process”

• BOTH are required – Many facilities do not have a “Program”

50


Basic Principals (Continued)– Provide an Off-Site Consequence Analysis (OCA)

• Worst Case• Alternative Release

– Identify and describe any accidents occurring in the past five (5) years

– Describe the Emergency Planning and Response Program

51

Hot Work Program

General Program Purpose – Provide rules for performing any open flame or open arc work at

the facility

Basic Principals– OSHA 29 CFR 1910.252(a)– If you don’t have one, make sure your contractors program is

sufficient – They could destroy your facility!

52

Did you say something,

Hank?

Confined Space Entry Program

General Program Purpose – Provides rules/restrictions for entering confined spaces at the

facility

Basic Principals– OSHA 29 CFR 1910.146

• Is large enough and so configured that an employee can bodily enter and perform assigned work; and

• Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and

• Is not designed for continuous employee occupancy.– Most ammonia system do not have confined spaces… BUT

• Condensers• Penthouse air units• Confined space or PERMIT REQUIRED confined space

53

Lockout Tagout Program

General Program Purpose – Provide rules for working with and controlling stored energy

systems (electrical, mechanical, and electro-mechanical)

Basic Principals– OSHA 29 CFR 1910.147 (The control of hazardous energy

(lockout/tagout)

“Suicide Prevention Program!”

54

What Has Changed Recently and OSHA/EPA Trends - 1

– ANSI/ASHRAE 15-2001• Methods for determining relief valve discharge pipe size

– Reduces allowable lengths from valve to header– Changes discharge calculations for valves discharging vapor back into

system via a relief valve

– Fire Control Boxes• IIAR and RETA with assistance from International Codes

Consultants (ICC) have been successful in convincing many localities that fire control boxes (“dump boxes”) should not be required

• Many responders don’t understand what they are for and how to operate them

– OSHA has changed target from Petro/Chemical industry to ammonia

55

What Has Changed Recently and OSHA/EPA Trends - 2

– Audit Focus• Major aim has been Mechanical Integrity

– Documentation!– Paper versus electronic - REAL Signatures

• Training – review of training documentation• Safe Work Practices• Ammonia detection systems calibrated and documented• “Non Negotiables”

– SOPs annually signed off– PHA performed at five (5) years– All contractors have documentation– Audits performed every three years promptly– Recommendations from audits and PHAs are addressed– RMP resubmittal on-time

56

What Changes if the System Changes… - 1

Employee Participation– ONLY completion of employee Participation Forms

Process Safety Information– Information Relevant to the Technology of the System

• Block/Process Flow Diagram• Process Chemistry (ONLY if a new classification of equipment is

added)• Inventory Analysis• Safe Lower and Upper Operating Limits (ONLY if a new

classification of equipment is added)• Consequences of Deviation (ONLY if a new classification of

equipment is added)

57


Process Safety Information (Continued)– Information Relevant to the Equipment in the Process

• Piping and Instrumentation Diagram (P&ID)• Relief System and Design Basis• Material and Energy Balance• Safety Systems

Standard Operating Procedures (SOPs) – If a new classification of equipment is installed, there may be an

additional chapter needed– Most changes would be clerical in nature (to include new

equipment numbers) if no new classification of equipment is added

Operator/Mechanic Training– Only new training performed and forms completed

58


Contractor Qualification Program– The program won’t change, but you may need to qualify new

contractors and obtain their documentation

Management of Change (MOC) – An MOC form will be required

Pre-Startup Safety Review (PSSR)– A PSSR form may be required (if not a replacement in kind)

Safe Work Programs– The program won’t change, but forms may require completion

59


Risk Management Program (RMP)– If a new classification of equipment is added and/or the

expansion of the facilities ammonia inventory is sufficiently increased

Emergency Planning and Response Program– If a facility expansion is required, this is likely

60

What Likely Won’t Change…

Parts of the Process Safety Information (PSI)– Information pertaining to the hazards of ammonia

• It is unlikely that this section would change as the result of facility modifications

– Information Relevant to the Equipment in the Process • Materials of Construction • Electrical Classification• Design Codes and Standards Employed

Incident Investigation Program– HOPEFULLY a form doesn’t require completion!

Compliance Audit Program

61

Examples - 1

Valve failure requires replacement– Replacement in kind!!!– No MOC Needed

HOWEVER– Hot Work Permits– Lock Out/Tag Out– Line Opening Procedure

62

Examples - 2

Replacement of an air unit with another– Replacement in kind

BUT– Manufacturer Names– Model Numbers– Serial Numbers

Mechanical Integrity– Equipment Lists– Maintenance Listings

PSI– If unit changed, may change capacity or inventory

Management of Change FormHot Work PermitLock Out/Tag OutLine Opening Procedure

63

Examples - 3

Add an air unit– DEFINITELY!!!


PSI– Inventory Estimate– Load Analysis– P&IDs– Block Flow Diagram (possibly)

SOP– Most likely clerical type issues (assuming a similar type of air unit

currently exists

Hot Work PermitLock Out/Tag OutLine Opening Procedure

64

Examples - 4

Major Renovation– ABSOLUTELY!!!


PSI– Inventory Estimate– Load Analysis– P&IDs– Safe Upper and Lower Operating Limits (possible)– Block Flow Diagram (likely)

SOP– Most likely clerical type issues (assuming a similar type of air unit

currently exists

65

Examples – 4 (Continued)

Process Hazard Analysis (PHA)– If a new process is added – If there is a significant increase in ammonia inventory

Risk Management Program (RMP)– If a PHA has to be performed

Hot Work Permit

Lock Out/Tag Out

Line Opening Procedure

66

Training Session Purpose Goals/Objectives –Learn to talk-the-talk –Learn why PSM and RMP exist...

Documents

Transcript of Training Session Purpose Goals/Objectives –Learn to talk-the-talk –Learn why PSM and RMP exist...