Transcript Slide 1

Training Session Purpose
Goals/Objectives
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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
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What are PSM and RMP?
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!!!
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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 )
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What is the General Duty Clause All About? - 2
General Duty Clause
– You can be in violation if:
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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!!!
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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!
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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
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Why PSM and RMP? - 2
December, 1984 – Institute, West Virginia
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Union Carbide
Cyanide
135 Hospitalized
No temperature inversion
America’s wake-up call!
Ha n co c k
B r o ok e
O h io
M arshal
W e t z e l M o no n g a lia
M organ
M a r io n
B e r ke le y
P r e st o n
P le a sa n t s
M in er a l
T a y lo r
Ha r r is o n
Jef f er son
Ha m p s h ir e
Do d dr id g e
W o od
Rit c hie
B a r bo u r T u c ke r G r an t
T y le r
W ir t
L e wis
Ha r dy
G ilm e r
Ca lh ou n
J a c ks o n
Up s hu r Ra n do lp h
M a so n
Ro a ne
B r a xt o n
P e n dle t o n
P u t na m
Ca b ell
W e bs t e r
Cla y
K a n awh a
Nic h ola s
P o c ah o n t a s
L in c oln
W a yn e
B o o ne
M in goL o g an
F a y et t e
G r ee n b r ie r
Ra le ig h
W y om in g
M c Do we l
S u m m e rMs o nr o e
M ercer
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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
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The “What’s” About Ammonia
Basic Facts about ammonia
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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.)
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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
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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)!!!
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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
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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
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Why Ammonia Then? Why not Freon
Ammonia
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Naturally occurring
Environmentally friendly
Self alarming
Inexpensive
If You Fail to Respect Ammonia, Ammonia Will Fail to Respect
you
Freon and Fluorocarbons
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Fire creates phosgene gas (mustard gas)
Suffocant (heavier than air)
Can’t smell it
Expensive
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Who Has a Role?
EVERYONE!
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Management
PSM Coordinator
Operators
Mechanics
Floor Personnel
Contractors!
Remember that these are REQUIRED by OSHA and EPA!!!
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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
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Consequences – “OSHA/EPA Shock and Awe” - 1
February 12, 2004
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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]…
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Consequences – “OSHA/EPA Shock and Awe” - 2
March 27, 1999
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Albertsons Distribution Center – Denver, Pennsylvania
NO RELEASE
Potential disgruntled employee
$170,000
ONLY ammonia PSM related
October 10, 2010
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Tanner Industries, East Providence, Rhode Island
NO RELEASE
$149,080
Emergency Response Plan didn’t address
releases during times when facility isn’t
occupied.
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Consequences – “OSHA/EPA Shock and Awe” - 3
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
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Consequences – “OSHA/EPA Shock and Awe” - 4
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.
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Consequences – “OSHA/EPA Shock and Awe” - 5
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 incident
December 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
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Consequences – “OSHA/EPA Shock and Awe” - 6
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!
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Consequences – “OSHA/EPA Shock and Awe” - 7
Are these image you want your customers to remember
about you?
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PSM (and RMP) Elements/Programs
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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
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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!!!
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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
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Mechanical Integrity Program - 2
Specific Areas of Interest
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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
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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
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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:
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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
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Process Safety Information - 2
Basic Principals (Continued)
– Discussion of technology associated with the anhydrous
ammonia refrigeration system
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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
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Process Safety Information - 3
Basic Principals (Continued)
– Discussion of equipment associated with and used in the
ammonia refrigeration system
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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
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Process Safety Information - 4
Piping and Instrumentation Diagrams (P&IDs) and Block/Process
Flow Diagrams – The Difference Between…
HTS
LTS
HTS
HPL
HPL
LTS
LTS
HTS
HPL
HPL
Continuous Cook/Chill
Shell/Tube Heat Exchangers
(2 Surge Drums and
2 Heat Exchangers Total)
LTS
HPL
HPL
LTS
HPL
Open Coils (EV-8)
(2 Surge Drums and
2 Coils Total)
LTS
LTS
HTS
LTS
LTS
Desiccant Make Up Air
(1 Unit Total)
HPL
Chill House #1
(1 Surge Drum & 1 Unit)
LTS
LTS
HTS
Chill Tanks
(10 Tanks Total)
Evap Condensers
(4 Condensers Total)
HPL
LI
LI
HPL
FG
CD
CD
CD
HTS
HPL
LTS
HSS
HSS
LI
LTS
HPL
LTS
LTS
LTS
HPL
Suction
Accumulator
(1 Unit Total)
HPL
HPL
Pasteurizing Room Units
(2 Eight Fan Units and
2 Surge Drums Total)
HTS
HTRL CROSS-OVER
Transfer
Drum
(1 Unit Total)
HTS
HTRL
HTS
HTRL
HTRL
King Unit over Variety Meats
(1 Unit Total)
High Pressure Receiver
(1 Unit Total)
HTRL
HTS
HTS
HTS
Recirculating
Pumps
(3 Units Total)
LTS
Dedicated Compressor
for Pack Off Chillers
(1 Unit Total)
HTS
Dedicated Compressor
for West Freezer
(1 Unit Total)
CD
TRANS
HTS
Screw Compressors
in Aux Room
(1 Units Total)
HTS
LTS
EQL
HSS
Air Purger
(1 Unit Total)
HTRLHTS
CROSS-OVER
HTS
HG
HSS
CD
LTS
HPL (MAKEUP)
LI
HTS
LTS
HG
High Temp
Pump Recir.
(1 Unit Total)
High Temp
Recip Compressors
(5 Units Total)
HPL
CD
HPL
HPL
Turbo Chiller
(1 Surge Drum and
1 Heat Plate Chiller Total)
King Units
Cryovac Rooms
Pasteurizing Room
(2 Units Total)
LTS
HG
HSS
EQL
HTS
HPL
HSS
HSS
HTS
HPL
LTS
LI
LTS
LTS
LTS
HG
HPL
HTS
HPL
HG
HPL
HTS
HPL
HPL
LI
LI
HG
HPL
HTS
CD
FG
HTS
EQL
EQL
EQL
CD
EQL
CD
LTS
EQL
EQL
LI
HG
Low Temp
Recip Compressors
(4 Units Total)
Slice Room King Unit
(1 Total Units)
LI
LI
HPL
HPL
HTS
HPL
LTS
HPL
HTS
HTS
HPL
Chill House #2
(1 Unit Total)
HG
Arby Area Bring Chill Tank
(1 Unit Total)
HPL
LTS
HTRL
HTRL
Raw Production Area (1)
Cooked Product Area (1)
Cooked Hold Cooler (2)
Cryovac Area (2)
Pack Off Area (2)
(8 Units Total)
Desert Air/Englehard Unit
(1 Unit Total)
HTS
HTRL
HTS
HTS
HTRL
HTS
HTRL
HTS CROSS-OVER
HTRL
HTRL
HTRL
HTS
HTS
HTRL
HTS
HTS
HTS
HTS
HTRL
HTRL
Pre Blend Cooler (2)
Pre Blend Dock (1)
(3 Units Total)
+38F Assembly (3)
Variety Meats/Box Room (8)
+38F Production (5)
Receiving (2)
Link Cooler (4)
(22 Units Total)
Pack Off Area Air Units
(4 Units Total)
[Flooded] West Freezers
(Total of 2 Surge Drums
and 4 Air Units)
Tunnel Cooling Coils
(3 Units Total)
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Process Safety Information - 5
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
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Process Hazard Analysis - 1
General Program Purpose
– to analyze potential hazards associated with the anhydrous
ammonia refrigeration system
Basic Principals
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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
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Process Hazard Analysis - 2
Acceptable Methodologies
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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
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Process Hazard Analysis - 3
What should be addressed?
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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
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Process Hazard Analysis - 4
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
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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
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Standard Operating Procedures - 2
Operating Phases
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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)
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Standard Operating Procedures - 3
Safe Work Practices
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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
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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.
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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’
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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!!!
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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
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Contractor Qualification Program - 2
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
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Contractor Qualification Program - 3
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 audits
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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…
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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
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Compliance Audit Program
General Program Purpose
– To verify that the PSM and RMP programs meets federal
requirements and are implemented
Basic Principals
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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
Risk Management Program - 2
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
Risk Management Program - 3
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!
Did you say
something,
Hank?
52
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
What Changes if the System Changes… - 2
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
What Changes if the System Changes… - 3
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
What Changes if the System Changes… - 4
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 Form
Hot Work Permit
Lock Out/Tag Out
Line Opening Procedure
63
Examples - 3
Add an air unit
– DEFINITELY!!!
Mechanical Integrity
– Equipment Lists
– Maintenance Listings
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 Permit
Lock Out/Tag Out
Line Opening Procedure
64
Examples - 4
Major Renovation
– ABSOLUTELY!!!
Mechanical Integrity
– Equipment Lists
– Maintenance Listings
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